Edward Byrne Memorial Justice Assistance Grant (JAG) Program 2017 Drug Task Force (D TF)

1. Edward Byrne Memorial Justice Assistance Grant (JAG) Program2017 Drug Task Force (DTF) Compliance Training Missouri Department of Public Safety Criminal Justice/Law Enforcement Unit July 25, 2017

2. CONTACT INFORMATION Heather Haslag, Program Manager P: (573) 751-1318 E: heather.haslag@dps.mo.gov Troy Thurman, Program Specialist P: (573) 751-5997 E: troy.thurman@dps.mo.gov Nancy Capps, Program Representative P: (573) 522-4094 E: nancy.capps@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. 2017 GRANT POINT-OF-CONTACTS“INTERNAL CONTACT” Unless noted otherwise, all reports and correspondence will be reviewed and processed by your designated Internal Contact. All questions and concerns should be directed to your Internal Contact as well! Monitoring will be conducted by the Internal Contact.

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

5. GENERAL GRANT INFORMATION

6. BACKGROUND Edward Byrne Memorial Justice Assistance Grant (JAG) • authorized by 42 U.S.C. 3751(a) • CFDA # 16.738 • awarded to Missouri by the U.S. Department of Justice (DOJ), Office of Justice Programs (OJP) • provides federal criminal justice funding • streamlined the Byrne and LLEBG grant programs

7. FEDERAL FUNDING • Calculated by the Bureau of Justice Statistics (BJS) Missouri Base Allocation <$10K Allocations >$10K Allocations Local Units of Gov’t Department of Public Safety Local Units of Government State Agencies

8. FEDERAL FUNDING cont’d • Things to remember: • Federal Fiscal Year is October 1 - September 30 while State Fiscal Year is July 1 - June 30

9. STATE FUNDING Available funding for FY18 Subawards = $4,707,129.80 (derives from FY 2016 JAG + Uncommitted FY 2015 JAG + Estimated Deobligations + Anticipated Interest + State Funding) *Compared to $4,300,499.28 for FY17 Subawards*

10. GENERAL GRANT GUIDELINES • Project Period: July 1, 2017 to June 30, 2018 (12 months) • Federal awards will be supplemented with state GR dollars • State GR portion has no CFDA # • No Local Match Requirement • Eligible Budget Categories: • Personnel • Personnel Benefits • Personnel Overtime • Personnel Overtime Benefits • Travel/Training • Equipment • Supplies/Operations • Contractual

11. SOURCE OF INFORMATION • DPS Website: http://dps.mo.gov/dir/programs/cjle/jag.php • 2017 JAG DTF Solicitation • 2017 JAG DTF Pre-Bid Training & Audio (3-8-17) • 2017 JAG DTF Compliance Training & Audio (7-25-17) • DPS Financial & Administrative Guidelines (revised 5-1-16) • Radio Interoperability Guidelines (revised 6-29-16) • DPS Subrecipient Travel Guidelines (revised 6-10-16) • WebGrants – Application Manual • WebGrants: https://dpsgrants.dps.mo.gov • Opportunity (Funding Opportunity) • 2017 JAG Certified Assurances • 2017 JAG Solicitation • Mitigation Plan • WebGrants - Application Manual • Office of Justice Programs (OJP) Financial Guide: http://ojp.gov/financialguide/DOJ/ • Office of Management and Budget (OMB) Circulars: http://www.whitehouse.gov/omb/circulars_default • Missouri State Statutes: http://www.moga.mo.gov/

12. BUDGET COSTS

13. PERSONNEL COSTS • Personnel costs must be supported with official payroll records and timesheets. • “Cover letters” will not be accepted to solely support expenses from member agencies • Agency should obtain documents to support all wages and fringe benefits claimed for reimbursement and maintain such documents in the grant files • Timesheets should document all paid hours (including leave, overtime, etc) and should ideally be signed by the employee and authorizing supervisor • If personnel costs (i.e. overtime) are paid from multiple funding sources, be sure to report 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 Form I-9, Employment Eligibility Verification. • http://www.uscis.gov/portal/site/uscis

14. 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. 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!

15. 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

16. TRAVEL/TRAINING COSTS cont’d • Mileage budget line • reimbursable based on the state’s mileage allowance • http://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 • http://www.gsa.gov/portal/category/21287 • 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 (confirmation emails are not allowed as they are considered quotes and reservations may be cancelled)

17. TRAVEL/TRAINING COSTS cont’d • Meal budget line • reimbursable based on the most restrictive travel policy – local or state • 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. • http://oa.mo.gov/travel-portal • receipts not required (or requested) (unless required by your local travel policy); still need to maintain some type of record of meals being requested for audit/monitoring purposes (e.g. employee expense report)

18. TRAVEL/TRAINING COSTS cont’d • Meals (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.

19. TRAVEL/TRAINING COSTS cont’d • Meals (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.

20. TRAVEL/TRAINING COSTS cont’d • Meals (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 subrecipientmay 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. • Subrecipientsbenefitting 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.

21. TRAVEL/TRAINING COSTS cont’d • “Miscellaneous” budget line • Taxi or other ground transportation; includes 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)

22. TRAVEL COSTS - DTFs • Fuel • reimbursable for the cost of fuel for fleet/department vehicles • supported by fuel card invoices/statements, individual receipts from the gas station, logs of department usage from gas tank, etc. • pre-paid gas cards are not allowable due to the restriction to obligate the funds within the project period • Mileage • reimbursable for the number of miles incurred • reimbursable at the state mileage allowance: http://oa.mo.gov/travel-portal • supported by mileage logs • Vehicle Maintenance • reimbursable for the cost of maintenance and upkeep of fleet/department vehicles • includes such costs as oil changes, filters, brakes, tires, engine fluids, belts, fuses, windshield wipers, car washes, collision repair • does not include window tinting, equipment for vehicle, towing, etc.

23. EQUIPMENT COSTS • Equipment is generally defined 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 • Must adhere to most restrictive procurement policy • All equipment must be compatible with the current statewide system • Communication devices must adhere to the state’s interoperability plan • Portable radios, repeaters, and base stations have no specifications • Mobile radios must be P25 compliant and operate in the trunked mode at the time of purchase • List of compliant communication devices available at http://www.dps.mo.gov/dir/programs/cjle/jag.php

24. SUPPLIES/OPERATIONS COSTS • Includes expendable property and operating costs • Costs must be directly attributable to the approved project • All software must be compatible with the current statewide system • Must adhere to most restrictive procurement policy • Printed materials must acknowledge the funding source

25. 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 • Copy of all written contracts must be made available to DPS staff during site visit monitoring (or upon request) • Must adhere to most restrictive procurement policy • Agencies should attempt to enter into contracts that occur within the grant’s project period, where possible

26. ADMINISTRATIVE AND FINANCIAL GUIDELINES

27. PROJECT IMPLEMENTATION STATUS • “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 WebGrants, the steps taken to initiate the project, the reasons for delay, and the expected start date. • If a project is not operational within 90 days of the project start date, the subrecipient must submit a second statement to DPS, via the “Correspondence” component of 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.

28. FUNDS • Subrecipient must report, on a monthly basis, actual cash expenditures and request reimbursement • Request for reimbursement will be handled via a “Claim” report • Funds must be obligated within the project period and expended within 60 days following the project period end date • Project Period: July 1, 2017 – June 30, 2018 • 60 Days Following: August 29, 2018 • 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.

29. 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 appropriate internal controls exist for the programmatic and financial aspects of the project • 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 selection, award, and administration of purchases.

30. 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 a copy of the sole source certification letter from the vendor, if available • 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 between $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

31. ACCOUNTING/FINANCIAL RECORDS • 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 submission of the Closeout form 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.

32. 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 • Description of the item • Serial number or other identification number (e.g. VIN, make, model number, control number) • Source of Property (e.g. GR, RSAT Grant), including the subaward number (if grant-funded) • Identification of the title holder • Acquisition date • Cost of the property • Percentage of state and/or federal participation in the cost of the property • Location of the property • Use and condition of the property • Disposition data, including the date of disposal and sale price • Property must be tagged and identifiable for its source of funds, where feasible • “Purchased with 2017 JAG Funds” • Subaward Number (e.g. 2016-JAG-001)

33. 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

34. PROPERTY DISPOSITION • Subrecipients are expected to use the approved equipment for the purpose for which it was acquired as long as needed. • If a JAG-funded project ceases and there is still value in the property, DPS may request such property be made available for re-authorization to another JAG-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, 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 inexcess of $5,000 may be retained or sold but the 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

35. AUDIT REQUIREMENTS • Comply with OJP Financial Guide, Chapter 3.19, Audit Requirements in accordance with the provisions of Title 2 C.F.R. Subpart F (§ 200.500 et seq.) • Audit is required if the subrecipientexpends $750,000 or more in federal funds (including pass-thru subawards) within the organization’s fiscal year from any federal source • Audit must be performed organization-wide by an independent firm • Audit must be conducted with reasonable frequency, usually annually, but not less frequently than every two 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

36. PRINTING AND PUBLICITY • BJA and DPS encourage recipients of federal funding to share success stories of their project • Award of funding • Major cases/investigations • Improvements in services provided • Educational training • Subrecipients are required to disclose of the source of their funding with language such as: Funding for this project made available by the Edward Byrne Memorial Justice Assistance Grant (JAG), which is administered by the U.S. Department of Justice, Bureau of Justice Assistance and the State of Missouri, Department of Public Safety

37. CIVIL RIGHTS COMPLIANCE

38. STATE CIVIL RIGHTS LAWS • Section 213.055 RSMo – Unlawful Employment Practices • 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 • 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

39. FEDERAL CIVIL RIGHTS LAWS • Civil Rights Act of 1964 (42 U.S.C. § 2000d) • Rehabilitation Act of 1973 (29 U.S.C. § 794) • Title IX of the Education Amendments of 1972 (20 U.S.C. § § 1681, 1683, and 1685-86) • Age Discrimination Act of 1975 (42 U.S.C. § § 6101-07) • Americans with Disabilities Act of 1990 (42 U.S.C. § § 12131-34) • U.S. Department of Justice Regulations – Non-Discrimination; Equal Employment Opportunity; Policies and Procedures (28 C.F.R. pt 42) • U.S. Department of Justice Regulations – Equal Treatment for Faith Based Organizations (28 C.F.R. pt 38) • Executive Order 13279 (equal protection of the laws for faith-based and community organizations)

40. EQUAL EMPLOYMENT OPPORTUNITY PLAN (EEOP) • A workforce report that some organizations must complete as a condition for receiving U.S. Department of Justice funding authorized by the Omnibus Crime Control and Safe Streets Act of 1968. • Intended to ensure recipients (and subrecipients) of federal funding are providing equal employment opportunities to men and women regardless of sex, race, or national origin. • U.S. Department of Justice regulations pertaining to the development of a comprehensive EEOP can be found at 28 C.F.R. § 42.301-42.308. • The U.S. Department of Justice, Office for Civil Rights (OCR) is the federal branch that collects, reviews, and approves EEOPs. • Effective in December 2016, the OCR developed an Equal Employment Opportunity (EEO) Reporting Tool to streamline the EEO reporting process. The deployment of the EEO Reporting Tool, however, changed the reporting requirements for recipients of funding from the U.S. Department of Justice. • Pre-December 2016 is referred to as “Legacy Tool” reporting. • Post-December 2016 is referred to as “EEO Reporting Tool” reporting.

41. OCR’s EEOP WEBPAGE https://ojp.gov/about/ocr/eeop.htm NOTE: The links at the bottom of the page assist in the completion of the EEOP requirements.

42. EEOP REPORTING DETERMINATION OLD = Legacy Tool : NEW = EEO Reporting Tool: For calculating the total number of employees, include part-time and full-time workers but exclude seasonal employees, political appointees, and elected officials.

43. EEOP CERTIFICATION FORM • The Certification Form’s purpose is to identify the EEOP reporting requirement (or lack thereof) of recipients of funding from the U.S. Department of Justice. • Recipients exempt from the EEOP reporting requirements must claim such exemption • During the “Legacy Tool” reporting years, a claim of exemption required Section A of the Certification Form to be completed and the form(s) submitted to OCR. The Form was effective for 2 years, commencing with the date of submission to OCR. • Effective with the “EEO Reporting Tool”, a “Certification of Exemption” form will populate and be submitted to OCR. The Form must be submitted each calendar year for which DOJ funding is received (and be updated in the event a new award is received within the same calendar year that changes the status to no longer being exempt from the EEOP reporting requirement). • Recipients required to prepare an EEOP must acknowledge such requirement • During the “Legacy Tool” reporting years, an acknowledgement of requirement necessitated completion of either Section B or C of the Certification Form and the form(s) submitted to OCR. The Form was effective for 2 years, commencing with the date of submission to OCR. • Effective with the “EEO Reporting Tool”, a “Notice of Acknowledgement of Requirement” form will populate and be submitted to OCR. The Form must be submitted each calendar year for which DOJ funding is received. • Should be prepared for the recipient of the federal funding (i.e. county, city, or state department)

44. EEOP CERTIFICATION FORM cont’d OLD = Legacy Tool : NEW = EEO Reporting Tool: SAMPLE SAMPLE • Completed form includes the header and one of the sections (but not all three) • Email to OCR once completed • Populates the form based on the type of agency, number of employees, & single largest DOJ award • Submitted electronically through the Reporting Tool

45. EEOP UTILIZATION REPORT • OCR developed the EEOP Utilization Report to help recipients of funding from the U.S. Department of Justice comply with the EEOP regulations. • Instead of requiring recipients to report all of the employment data that federal regulations require them to keep (see 28 C.F.R. § 42.301-42.308), OCR uses the EEOP Utilization Report to prompt recipients to collect and analyze key employment data, organized by race, national origin, and sex. • Effective for a 2-year period, commencing with the date of approval of the Report from the OCR • During the “Legacy Tool” reporting years, written approval seemed to only be received by larger metropolitan organizations (i.e. larger award dollars triggered thorough review) • If written approval is not received, the Utilization Report is effective for a 2-year period from the date of preparation of the Report. • Should be prepared for the recipient of the federal funding (i.e. county, city, or state department) Not the same as an EEO4, which is required by the U.S. Equal Employment Opportunity Commission.

46. EEOP UTILIZATION REPORT cont’d OLD = Legacy Tool : NEW = EEO Reporting Tool: SAMPLE COVER SHEET SAMPLE COVER SHEET Date-stamp on cover sheet indicates preparation date Date-stamp on cover sheet indicates print date (not preparation date)

47. EEOP CERTIFICATION FORM RECAP

48. EEOP UTILIZATION REPORT RECAP

49. NON-DISCRIMINATION • Subrecipient may not discriminate on the basis of race, color, national origin, religion, sex, or disability in its employment practices or in the delivery of services • If the subrecipient has 50 or more employees and receives OJP, OVW, or COPS funding of $25,000 or more: • the subrecipient must have written policies or procedures in place to notify program participants and employees on how to file complaints alleging discrimination • the subrecipient must designate a person(s) to coordinate complaints alleging discrimination

50. FINDINGS OF DISCRIMINATION • Subrecipient must notify DPS of any findings of discrimination within 30 days of the court judgment • Submit the Court Judgment with a cover letter, which identifies your DPS-assigned subaward number, as indicated on the Subaward document • DPS must forward to the Office for Civil Rights (OCR) Missouri Department of Public Safety Attn: Director of Public Safety PO Box 749 1101 Riverside Drive Jefferson City, MO 65102