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State Cyber Crime Grant (SCCG) 2020 Compliance Training

Missouri Department of Public Safety Office of the Director Criminal Justice/Law Enforcement (CJ/LE) Unit. State Cyber Crime Grant (SCCG) 2020 Compliance Training. June 6, 2019. CJ/LE CONTACT INFORMATION. Laura Robinson, Program Specialist P: (573) 526-1928

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State Cyber Crime Grant (SCCG) 2020 Compliance Training

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  1. Missouri Department of Public Safety Office of the Director Criminal Justice/Law Enforcement (CJ/LE) Unit State Cyber Crime Grant (SCCG) 2020 Compliance Training June 6, 2019

  2. CJ/LE CONTACT INFORMATION Laura Robinson, Program Specialist P: (573) 526-1928 E: laura.robinson@dps.mo.gov Becky Block, Program Representative P: (573) 751-5951 E: becky.block@dps.mo.gov Main Phone: (573) 751-4905 Fax Number: (573) 522-1908 Address: MO Department of Public Safety Attn: CJ/LE Unit PO Box 749 1101 Riverside Drive Jefferson City, MO 65102

  3. 2020 DPS “INTERNAL CONTACT” Unless noted otherwise, all grant reports and correspondence will be reviewed and processed by your designated Internal Contact. All questions and concerns should be directed to the Internal Contact as well! Monitoring will be conducted by the Internal Contact.

  4. TRAINING OUTLINE • General Grant Information • Budget Costs • Administrative & Financial Guidelines • Reporting Requirements • Monitoring • WebGrants Demo • Questions?

  5. GENERAL GRANT INFORMATION

  6. BACKGROUND • Supports the continued operation of multi-jurisdictional law enforcement cyber crime task forces. • Prior to SCCG, the cyber crime task forces were funded with state Internet Cyber Crime Grant (ICCG) monies until May 2009 and then with federal Multi-Jurisdictional Cyber Crime Grant (MJCCG) monies until February 2013. • The overall purpose of the SCCG program retains the same mission, which is to support a broad range of activities to prevent and control internet sex crime as it relates to children.

  7. SOURCES OF INFORMATION • DPS – CJ/LE Website: https://dps.mo.gov/dir/programs/cjle/ • CJ/LE Grant Calendar • DPS, CJ/LE – SCCG Website: https://dps.mo.gov/dir/programs/cjle/sccg.php • SCCG Fact Sheet • WebGrants External User Manual • DPS Financial & Administrative Guidelines • DPS Subrecipient Travel Guidelines • 2020 SCCG Solicitation • 2020 SCCG Notice of Funding Opportunity Training (and Audio) • 2020 SCCG Compliance Training (and Audio) • WebGrants: https://dpsgrants.dps.mo.gov • Opportunity (Funding Opportunity) • 2020 SCCG Certified Assurances • 2020 SCCG Solicitation • WebGrants External User Manual • Missouri State Statutes: http://www.moga.mo.gov/

  8. FUNDING OVERVIEW

  9. GENERAL GRANT GUIDELINES • Project Period: June 1, 2019 to May 31, 2020 • No local match • Eligible budget categories: • Personnel • Personnel Benefits • Personnel Overtime • Personnel Overtime Benefits • Travel/Training • Equipment • Supplies/Operations • Contractual

  10. BUDGET COSTS

  11. PERSONNEL COSTS • Personnel costs must be supported with official payroll records and time/attendance reports. • Subrecipient should maintain documents to support all wages and fringe benefits claimed for reimbursement (preferably, but not necessarily, in the grant file) • Timesheets should document all paid hours (including leave, overtime, etc) and should be signed by the employee and authorizing supervisor • If personnel costs (i.e. overtime) are paid from multiple funding sources, be sure to report grant-funded hours clearly. • Section 285.530.1 RSMo indicates that an agency will not knowingly employ, hire for employment, or continue to employ an unauthorized alien to perform work within the State of Missouri. • Federal law requires every employer hiring an individual for employment in the United States to verify his or her identity and employment authorization through completion of a Form I-9, Employment Eligibility Verification. • https://www.uscis.gov/

  12. TRAVEL/TRAINING COSTS • Funds will not be reimbursed prior to the actual travel. • Must submit a copy of the training certificate for travel/training costs to be reimbursed. If a training certificate is not provided, must create a memo. • Should have pre-budgeted for travel expenses based on the location of the travel/training (e.g. airport parking for out-of-state travel by plane). Either: • Submit a budget revision prior to travel if you foresee incurring an expense that isn’t approved in the budget • Don’t claim an expense that isn’t approved in the budget • Some travel costs may be unpredictable – use “Miscellaneous” as a line item for shuttles, taxis, parking, toll bridges, etc. Must be tied to a specific training! • Travel must be by the most practical and direct route! • All costs should be reasonable and prudence should be used when making travel arrangements!

  13. TRAVEL/TRAINING COSTS cont’d • Airfare/Baggage budget line • Reimbursable costs include the airline ticket, baggage fees, and travel agency processing fees • Other applicable fees are subject to review • Does not allow for airport parking or transportation to/from the airport • Costs must be supported by a receipt • Rental Car budget line • Reimbursable for the cost of the rental car • Cost must be supported by a receipt • Fuel budget line • Reimbursable for the fuel for a rental car and/or fuel for a vehicle to and from the airport or training location • Costs must be supported by a receipt

  14. TRAVEL/TRAINING COSTS cont’d • Mileage budget line • Reimbursable based on the state’s mileage allowance • https://oa.mo.gov/travel-portal • Rate calculated on cost to operate the vehicle based on fuel and wear and tear (cannot request fuel and mileage reimbursement) • standard “state” rate represents cost to own and operate a personal vehicle • “fleet” rate represents average cost of operating a fleet vehicle • Must be supported by documentation (e.g. MapQuest, Google Maps) • does not include any miles involved in a normal commute • Lodging budget line • Reimbursable based on the federal GSA rates as determined for the destination • https://www.gsa.gov/travel/plan-book/per-diem-rates • The GSA rate is for the base nightly rate (not inclusive of taxes) • Where possible, should request the hotel to honor the GSA rate since travel is state funded • Does not allow for hotel parking, room service, internet, telephone calls, maid tips, etc. • Costs must be supported by the hotel statement with a $0.00 balance (confirmation emails are not allowed as they are considered quotes and reservations may be cancelled or altered)

  15. TRAVEL/TRAINING COSTS cont’d • Meal budget line • Reimbursable based on the state travel policy adopted by the Missouri Department of Public Safety • State travel policy allows for per diem rate based on the state CONUS rates as determined for the destination and for the particular meal (i.e. breakfast, lunch, or dinner). • Statewide meal per diems are set by region/city. If no city is listed, use the standard (Other) rate, which is the lowest listed. Reimbursement of meal expenses will be based on the location in which the meal expense was incurred. Therefore, the location of meals should be clearly identified. • https://oa.mo.gov/travel-portal • Receipts not required (or requested); still need to maintain some type of record of meals being requested for audit/monitoring purposes (e.g. employee expense report)

  16. TRAVEL/TRAINING COSTS cont’d • Meal budget line (cont’d) • State travel policy states individuals may claim the applicable per diem rate for each eligible meal while in travel status. • Travel status begins when you leave your residence or domicile to travel on business. • Travel status ends when you return to your residence or domicile. • You are not in travel status if any part of your trip involves a commute. When your official domicile and residence are different, the travel status begins and ends based on whichever is less. • However, if your residence is less but it is necessary for you to travel to your domicile before your travel status begins, your travel status begins when you leave your domicile. For example, if you live in Columbia and you work in Jefferson City. If you leave from Jefferson City to go to Kansas City on business, your travel status begins when you leave Jefferson City, but if you leave from Columbia to go to Kansas City on business, your travel status begins when you leave Columbia.

  17. TRAVEL/TRAINING COSTS cont’d • Meal budget line (cont’d) • To qualify for meal per diem when no overnight lodging is indicated, it must be documented that the individual was in travel status for 12 hours or more. Time of travel status start and travel status end must be indicated to confirm. • Eligible meal is defined as follows: • When twelve (12) hour travel status or overnight lodging is indicated: • Breakfast – on the day of departure if travel status begins no later than 7:00 a.m. • Lunch – on the day of departure if travel status begins no later than 10:00 a.m. and continues past 2:00 p.m. • Dinner – on the day of departure if travel status begins no later than 5:00 p.m. and continues past 7:00 p.m.

  18. TRAVEL/TRAINING COSTS cont’d • Meal budget line (cont’d) • Tips on meals are part of the per diem rate and may not be claimed separately. • When attending a meeting or training, the subrecipient may claim the applicable meal per diem for those meal times where it is documented that no meal was provided. However, the traveler must be in 12-hour travel status. • Subrecipients benefitting from a hotel provided meal should not claim that specific meal per diem. If the traveler cannot utilize the meal provided at the hotel, justification should be provided on the expense report or within an attached letter or memo for the request of that meal.

  19. TRAVEL/TRAINING COSTS cont’d • “Miscellaneous” budget line • Allows for reimbursement of the following types of costs: • Taxi or other ground transportation, including tips for taxis/shuttles (receipt required) • To/from the airport to the hotel • To attend official events outside the hotel • To get a meal outside the hotel • Hotel parking (receipt required) • Airport parking (receipt required) • Street parking (no receipt required but must create a receipt or memo as documentation of the type of expense, amount of expense, date of expense, location of expense, and any other pertinent information) • Toll charges for bridges and turnpikes (receipt required)

  20. EQUIPMENT COSTS • Equipment is defined by the State of Missouri as non-expendable personal property having a useful life of more than one year and an acquisition cost of $1,000 or more per unit • Subrecipients may use their own definition of equipment provided that the definition would, at a minimum, include the equipment described above. • Purchases must adhere to the most restrictive procurement policy • Costs must be supported by a vendor invoice or receipt • Equipment must be tagged and identifiable for its source of funds (e.g. subaward number)

  21. SUPPLIES/OPERATIONS COSTS • Includes non-expendable property with an acquisition cost less than $1,000, expendable property, and non-contractual operating costs • Costs must be directly attributable to the approved project • All software must be compatible with the current statewide system • Purchases for goods or services must adhere to the most restrictive procurement policy • Costs must be supported by a vendor invoice or receipt • Printed materials must acknowledge the funding source

  22. CONTRACTUAL COSTS • Includes contractual expenses and consultant fees • All contractual and consultant services shall be supported by written contracts stating the services to be performed, rate of compensation, and length of time over which the services will be performed, as applicable • A copy of all written contracts must be made available to DPS staff during site visit monitoring (or upon request) • Purchases for contractual services must adhere to the most restrictive procurement policy • Costs must be supported by a vendor invoice or receipt • Subrecipients should attempt to enter into contracts that occur within the grant’s project period, where possible

  23. ADMINISTRATIVE AND FINANCIAL GUIDELINES

  24. PROJECT IMPLEMENTATION • “Operational” = beginning activities in which project-approved costs are being incurred (e.g. employing personnel, attending training, obtaining quotes/bids, etc) • If a project is not operational within 60 days of the project start date, the subrecipient must report to DPS, via the “Correspondence” component of the grant within WebGrants, the steps taken to initiate the project, the reasons for delay, and the expected start date. • If a project is still not operational within 90 days of the project start date, the subrecipient must submit a second statement to DPS, via the “Correspondence” component of the grant within WebGrants, explaining the implementation delay. • Upon receipt of the second statement, DPS may decide whether to continue with the project or to terminate the subaward.

  25. FUNDS • Subrecipients must report, on a monthly basis, actual cash expenditures and request reimbursement. • Requests for reimbursement will be handled via a “Claim” report. • Funds must be obligated within the project period and should be expended within 10 days following the project period end date. • Project Period: June 1, 2019 – May 31, 2020 • 10 Days Following: June 10, 2020 • Funds are “obligated” when a legal liability to pay a determinable sum for services or goods is incurred and will require payment during the same or future period. • When a purchase order is issued, funds are considered obligated • Travel expenses will only be allowed for events, training, and other activities held during the project period • Funds are “expended” when payment is made.

  26. INTERNAL CONTROLS • Subrecipients must track, account for, and report on all funds separately from all other funds. • Grant funds may be used in conjunction with other funding as necessary to complete projects but tracking and reporting must be separate. • Subrecipients should ensure appropriateinternal controls exist for the programmatic and financial aspects of the project. • There should be separation of duties (or layers) when it comes to the approval of timesheets/payroll or purchase approvals and payments. • Procurement/purchasing policies generally outline internal controls, such as the selection, award, and administration of purchases.

  27. PROCUREMENT General Grant Guidelines: • All procurement transactions whether negotiated or competitively bid, and without regard to dollar value, shall be conducted in a manner so as to provide maximum open and free competition. • All quotations and the rationale behind the selection of a source of supply must be retained, attached to the purchase order copy, and placed in the accounting files. • When only one bid or positive proposal is received, it is deemed to be sole source procurement. • Sole source procurement on purchases to a single vendor of $3,000 or more requires prior approval from the Missouri Department of Public Safety. • Request for approval shall be submitted via the “Correspondence” component of WebGrants with the rationale and, if available, a copy of the sole source certification letter from the vendor. • Approval of the grant application does not constitute prior approval; must obtain separately. State Procurement Policy: • Purchases to a single vendor totaling less than $3,000 may be purchased with prudence on the open market. • Purchases to a single vendor totaling $3,000 but less than $25,000 must be competitively bid, but need not be solicited by mail or advertisement. • Purchases to a single vendor totaling $25,000 or over shall be advertised for bid in at least two daily newspapers of general circulation in such places as are most likely to reach prospective bidders at least five days before bids for such purchases are to be opened.

  28. ACCOUNTING/FINANCIAL RECORDS • Must establish and maintain accurate financial records and an adequate accounting system. • Records must be retained for a period of five (5) years starting from the date of completion of the Closeout form within WebGrants or from the date of submission of the audit for the project period covered, whichever comes later. • Records must be retained beyond a five (5) year period if an audit is in progress and/or the findings of a completed audit have not been resolved. • Must adhere to local policy if local retention period is longer than those stated herein. • Records must be kept in an orderly manner and be available for audit purposes to DPS and/or representatives from the government of the State of Missouri. • Responsible for protecting records against fire, theft, or other possible damages.

  29. PROPERTY RECORDS • Required to maintain property management records • Records shall contain copies of the purchase order and invoice • Quotes/bids ideally should also be maintained • Records shall include an inventory control listing for non-expendable property • Item Description • Serial Number or other identification number (e.g. VIN, make, model number, control number) • Source of Property (e.g. General Revenue, 2020 SCCG Grant), including the SubawardNumber • Identification of the Title Holder • Acquisition Date • Total Cost of the property • Percentage of State participation in the cost of the property • Location, Use, and Condition of property • Disposition Date • Disposition Method (e.g. trash, sale, trade) • Property must be tagged and identifiable for its source of funds, where feasible • “Purchased with 2020 SCCG Funds” • Subaward Number (e.g. 2020-SCCG-001)

  30. PROPERTY RECORDS cont’d • Control system shall be in effect to ensure adequate safeguards to prevent loss, damage, or theft to the property • Any loss, damage, or theft of non-expendable property shall be investigated, fully documented, and made part of the grant file • Should take a physical inventory of the property and reconcile the results with the property records at least once every 2 years • Adequate maintenance procedures shall be established to keep the property in good condition

  31. PROPERTY DISPOSITION • Subrecipients are expected to use the approved equipment for the purpose for which it was acquired as long as needed. • If a SCCG-funded project ceases and there is still value in the property, DPS may request such property be made available for re-authorization to another SCCG-funded project. • Replacement: May use the equipment to be replaced as a trade-in, or may sell the equipment and use the proceeds to offset the cost of the replacement equipment. • Purchase of replacement property must take place soon enough after the sale of property to show that the sale and the purchase are related. • Disposition: When original or replacement equipment acquired under an award is no longer needed for the original project, subrecipients may dispose of the personal non-expendable property. • Items with a current per unit fair market value of less than $5,000 may be retained, sold, or otherwise disposed of with no further obligation to DPS. • Items with a current per unit fair market value of $5,000 or more may be retained or sold, but the Department of Public Safety (DPS) shall have a right to an amount calculated by multiplying the current market value or proceeds from the sale by DPS’ share of the equipment. • The seller is eligible for limited sale and handling costs of $500 or 10% of the proceeds, whichever is less. • Records for non-expendable property acquired with grant funds shall be retained for five (5) years after final disposition of property.

  32. AUDIT REQUIREMENTS • An audit is required if the subrecipient expended $375,000 or more in state funds within the organization’s fiscal year from any state source (including, but not limited to, SCCG) • If the subrecipient is not required to have an audit, the agency is still responsible for monitoring activities to provide reasonable assurance that the agency administers state awards in compliance with state requirements. • If the subrecipient is required to have an audit: • The audit must be performed organization-wide by an independent firm • The Audit must be conducted with reasonable frequency, usually annually, but not less frequently than every two (2) years • Doesn’t mean that the audit can include every other year though! • Must submit a copy of such audit to DPS via the “Correspondence” component of WebGrants, where possible • Can mail a copy to DPS if unable to scan the audit report • DPS will start contacting agencies if not submitted by 8/1/19

  33. PRINTING AND PUBLICITY • Subrecipients are encouraged to make the results and accomplishments of their activities available to the public through printed publication or media release. • Award of funding • Major cases/investigations • Improvements in services provided as a result of equipment purchases • Educational training • All printed materials, however, must include an acknowledgement of the funding source similar to the following: Funding for this project made available by the State Cyber Crime Grant (SCCG), which is administered by the State of Missouri and the Department of Public Safety.

  34. STATE CIVIL RIGHTS LAWS • Section 213.055 RSMo – Unlawful Employment Practices • Subrecipient may not discriminate on the basis of race, color, religion, national origin, sex, ancestry, age, or disability in its employment practices (e.g. hiring, compensation, conditions, or privileges) • Section 213.065 RSMo – Discrimination in Public Accommodations • Subrecipient may not discriminate on the basis of race, color, religion, national origin, sex, ancestry, or disability in the use and enjoyment of any place of public accommodation • It is unlawful to refuse, withhold from, or deny any of the accommodations, advantages, facilities, services, or privileges made available in any place of public accommodations

  35. REPORTING REQUIREMENTS

  36. REPORTING REQUIREMENT #1 – CLAIMS • Reminder emails will be sent by DPS staff from WebGrants approximately 1-2 weeks prior to the deadline • Subrecipients must report actual expenditures and request reimbursement • Requests for reimbursement are submitted via the “Claims” component of WebGrants • Funds must be obligated no later than May 31, 2020 • Funds should be expended no later than June 10, 2020 • Subrecipients can claim an amount over the total budgeted line item • Allowed up to a 10% increase in a single budget line without a budget revision • Not receiving additional monies but rather “borrowing” it from elsewhere in the budget • Increases in excess of 10% within a particular budget line require a budget revision through the “Subaward Adjustment” component of WebGrants • Exceeding the 10% increase will be subject to review by DPS • Nominal increases over the 10% allowance may be allowable without a budget revision; should consult with DPS Internal Contact • Claims will be reviewed, negotiated, and approved by the designated Internal Contact (if revisions are made by DPS, comments will be added to Feedback) • Payments are made around the 25th of each month via EFT • Vendor Services Portal: https://www.vendorservices.mo.gov/vendorservices/Portal/Default.aspx • SCCG Prefix Payment Code = PG087

  37. CLAIM COMPONENTS There are 5 components (forms) to the Claim report: • General Information: used to identify the reporting period and the type of report • Detail of Expenditure: used to identify the pay date, check number, payee, description, total cost, percent of funding requested, and amount claimed to grant for reimbursement per cost activity • Reimbursement: used to identify the State Share per budget line; the totals are aggregate totals from the ‘Detail of Expenditure’ form • Program Income: used to identify any monies earned and/or expended as a result of the grant-funded project • Attachments: used to upload copies of documentation to support the expenditures

  38. CLAIM REPORT NOTES • Manmade “invoices” will not be accepted in place of official documentation for expenditures • Official employer and vendor documents must be provided to verify costs • Reimbursement is only allowed for subrecipient costs • Watch your payroll and billing periods • Costs must be pro-rated by the total number of days in the billing or payroll period if the expense timing exceeds the grant’s project period • Familiarize yourself with the billings • Pre-tax deductions reduce the amount of Social Security and Medicare withholdings for the employee and employer • Help DPS in identifying which codes or lines are pre-tax deductions! • Insurance premiums are often paid the month prior to the coverage period • Help DPS in identifying the period for which the insurance is being paid • Unemployment Comp is typically paid on the first $12,000 of wages for the calendar year OR not paid at all until a claim is filed by the former employee • Workers Comp is not based on a straight job classification rate • Recommend using the Workers Comp calculator spreadsheet

  39. 2020 SCCG CLAIM REPORT SCHEDULE • The above-mentioned deadlines are extended if the subaward is not “Underway” by the deadline • A Claim report is due every month, even if the Claim total is $0.00, until a report is marked “final” and the project is completed • Only 1 Claim report should be submitted per reporting period

  40. REPORTING REQUIREMENT #2 – STATUS REPORTS • Subrecipients must report statistical data, as well as any other activities, successes, and/or obstacles as desired • Reminder emails will be sent by DPS staff from WebGrants approximately 1-2 weeks prior to the deadline • Reports must be submitted via the “Status Reports” component of WebGrants • Subrecipients must submit a Status Report for each quarter of the project period (even if the grant award is exhausted early; need continuing data) • Status Reports will be reviewed, negotiated, and approved by the designated Internal Contact (if revisions are made by DPS, comments will be added to Feedback) • Compiled by the Missouri State Highway Patrol (MSHP), Statistical Analysis Center (SAC) for publications and state reporting purposes

  41. STATUS REPORT COMPONENTS There are 2 components (forms) to the Status Report: • General Information • used to identify the type of report (quarterly) and the reporting period (as outlined in the reporting schedule) • Cyber Crime Task Force • used to provide statistical information to include, but not limited to, the organization/investment, employees, cybertips, investigations, casework, forensic examinations, arrests, backlog, turnaround time, victims, search warrants, subpoenas, and outreach programs • also used to provide a narrative of information to describe work activities and/or areas of interest not reported elsewhere in the report and/or to provide any details necessary to explain responses in the report

  42. 2020 SCCG STATUS REPORT SCHEDULE • The above-mentioned deadline for #01 is extended if the subaward is not “Underway” by the deadline

  43. MONITORING

  44. MONITORING • CJ/LE will conduct monitoring of the project to ensure compliance with state laws, regulations, and guidelines • Desk Monitoring – tracking telephone and email communication, as well as reviewing all grant documents, reports, and correspondence • Site Visit Monitoring – a visit the subrecipient’s office(s) to review policies, property records, and other documents • CJ/LE will take appropriate action if determined the subrecipient is acting inappropriately, misusing money, and/or not meeting reporting requirements • Such action may result in delay of reimbursement of funds and/or cancellation of the subaward

  45. SITE VISIT MONITORING CHECKLIST – STATE STATUTES FOR LEAs • Section 43.505 RSMo - Uniform Crime Reporting (UCRs) • DPS will verify with MSHP on monthly compliance for the law enforcement agency • Section 590.650 RSMo - Racial Profiling Report • DPS will verify with the Attorney General’s Office on annual compliance for the law enforcement agency • Section 513.653 RSMo - Federal Forfeiture Report • DPS will verify with the State Auditor’s Office on annual compliance, where applicable, for the law enforcement agency • Section 590.700 RSMo - Recording of Custodial Interrogations • Must present DPS with a copy of the law enforcement agency’s written policy • Section 43.544 RSMo - Forwarding Intoxication-Related Offenses • Must present DPS with a copy of the law enforcement agency’s written policy

  46. SITE VISIT MONITORING CHECKLIST - PROGRAMMATIC • Personnel files for grant-funded staff • particularly whether resumes/applications are on file • Training plan for grant-funded staff • Personnel Manual/Standard Operating Procedures • Local travel policy • Local procurement/purchasing policy • Inventory control listing for equipment • Tags/labels on equipment • Internal controls

  47. SITE VISIT MONITORING CHECKLIST – FINANCIAL • Personnel • payroll records to support salary, overtime, and fringe benefits (which is submitted with the Claim report) • timesheets • Travel/Training • receipts and travel vouchers (which is submitted with the Claim report) • certificate of attendance (which is submitted with the Claim report) • Equipment • invoices/receipts from vendor(which is submitted with the Claim report) • bid records and/or sole source letters, where applicable • Supplies/Operations • invoices/receipts from vendor (which is submitted with the Claim report) • bid records and/or sole source letters, where applicable • Contractual • invoices/receipts from the vendor (which is submitted with the Claim report) • bid records and/or sole source letters, where applicable • contractual agreements, where applicable

  48. SITE VISIT MONITORING CHECKLIST – STATE CIVIL RIGHTS • Section 213.055 RSMo – Unlawful Employment Practices For example: • Does the agency’s job announcements and employment applications include an “Equal Opportunity Employer” statement? • Does the agency display the required labor law posters (https://labor.mo.gov/posters)? • Does the agency maintain a written policy on non-discrimination and/or non-harassment in the workplace? • Does the agency maintain a written policy to notify employees on how to file complaints alleging discrimination?

  49. SITE VISIT MONITORING CHECKLIST – STATE CIVIL RIGHTS cont’d • Section 213.065 RSMo – Discrimination in Public Accommodations For example: • Does the agency display the required labor law posters (https://labor.mo.gov/posters) (e.g. Discrimination in Housing and Discrimination in Places of Public Accommodations)? • Does the agency notify its citizens or program participants that it will not discriminate in the delivery of its services (e.g. brochures, posters, website, mission statement)? • Does the agency ensure its facilities are ADA accessible? • Does the agency maintain a written policy on ADA? • Does the agency maintain a written policy to notify employees and/or citizens on how to file complaints alleging discrimination in public accommodations?

  50. WEBGRANTShttps://dpsgrants.dps.mo.gov

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