FAQ – Responses for Grants Awarded

After December 26, 2014

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Indirect Rates, Budgets, and Accounting

  1. Question: Since receiving funding for a grant, we have had a new fringe benefit rate approved and would like to add it to the approved budget. Can we do this?
    Answer: If you are going to formally offer this fringe benefit rate agency-wide, yes, you can probably add this. However, you must submit a Grant Adjustment Notice (GAN) to your awarding agency before making the change.
  2. Question: Since we applied for our grant, our indirect rate has changed. What do I do?
    Answer: If your approved indirect cost rate has changed and you would like to utilize the new rate, you must submit a GAN (budget modification) to reflect this change. Any funds moved in or out of indirect cost always require written prior approval.
  3. Question: When submitting an application budget, do we need to just show we have an approved indirect rate, or do we need to provide the rate breakdown?
    Answer: When the Office of the Chief Financial Officer (OCFO) is evaluating grant application budgets, we need to see a breakdown of how you came up with the indirect cost rate. We also need to see the formal negotiated agreement.
  4. Question: Is there a way to know in advance if indirect cost is permissible?
    Answer: Typically, indirect cost is permitted unless it is specifically stated as an unallowable cost in the grant program solicitation. However, if you do not have a federally approved indirect cost rate, you may not charge indirect costs to any grant.
  5. Question: If your grant period is for 24 months, can you increase indirect costs or fringe benefits at the end of the first year?
    Answer: Yes, however prior approval from the awarding agency is required.
  6. Question: How do you know who your Federal cognizant audit agency is?
    Answer: It tends to be the Federal agency through which you receive the majority of your Federal funding.
  7. Question: Should auditor expenses be allocated to direct or indirect costs? Are audit costs always allowable?
    Answer: The costs associated with an audit may be considered direct or indirect. However, audit costs are not allowable under all programs. In order for audit costs to be allowable, the program must allow audit costs and these costs must have been included in the grant application. If you have multiple grant programs, be careful to only account for those programs which allow audit expense.
  8. Question: Is it possible to be too detailed with regard to submitting a budget?
    Answer: No, you can never be too detailed with your budget. This may actually be beneficial to an applicant.
  9. Question: Is it a good idea to include anticipated costs in a budget?
    Answer: Yes, these costs should be broken out in detail.
  10. Question: What level of documentation is needed if the budget indicates a specific training, but instead you schedule a different training? Is this going to be a problem?
    Answer: Whenever you deviate from the proposed budget it is always a good idea to contact your program office. If the specified training relates to the project’s goals and objectives, a deviation in the specified training may be viewed as a change in scope. Required documentation would be written approval from the program office.
  11. Question: If you have a budget category that has a zero amount and you want to reallocate funding to that category, do you need to get prior approval?
    Answer: Yes.
  12. Question: If grantees receive multiple grants, do we account for them separately or cumulatively?
    Answer: You must account for them separately.
  13. Question: If grantees receive multiple grants, are we required to have a separate bank account for each grant?
    Answer: No, but you must be able to track and report on receipt, obligation, and expenditure of funds for each grant separately.
  14. Question: Are promotional items allowed?
    Answer: Yes; however, it will depend on the grant program. If approved to charge promotional costs against a program, you must remember to promote the program, not the agency, with the promotional items. The promotional items must have been part of the approved budget.
  15. Question: Do we need a formal written policy governing salary increases and bonuses for employees if not charged to a Federal program (directly or indirectly), i.e. paid for with general/unrestricted funds?
    Answer: Yes, you need a formal written policy for all salary increases and bonuses.
  16. Question: If a grantee is earning interest on grant funds, does the interest go back to the Department of Justice, or does the grantee get to keep it?
    Answer: It depends on the type of entity. Local units of government may keep interest earned on Federal grant funds up to $100 per fiscal year and nonprofit organizations may keep interest earned on Federal grant funds up to $250 per fiscal year. This maximum limit is not per award; it is inclusive of all interest earned as a result of all Federal funds received per year. Interest earned in excess of the $100 and the $250, excluding Justice Assistance Grants (JAGs) and Juvenile Accountability Block Grants (JABG), must be remitted to the U.S. Department of Health and Human Services. Interest income (placed in an interest-bearing account) on grants such as JAG and JABG must be accounted for, reported as program income, and used for the purposes of the program.
  17. Question: Who is responsible for keeping track of equipment purchased with Federal funding?
    Answer: Grantees are responsible for identifying and tracking all equipment purchased with Federal funds.
  18. Question: If I have a $40K grant, how does the 10% rule affect my grant?
    Answer: The 10% rule applies to awards over $100,000 only; however, if the total award is less than $100,000 and the scope of the project changes, prior approval is required.
  19. Question: What do you recommend as a good control for handing out cash?
    Answer: Use a petty cash process or imprest fund and require receipts. Periodic reconciliations of petty cash must be performed and documented. Establish written policies and procedures for petty cash. If possible, have two people present to witness transactions.
  20. Question: How do you decide if you need to use a reimbursement or an advance process?
    Answer: Your organization should determine what method of drawdowns to utilize. If your organization does not have sufficient working capital you may opt to use the advance process. However, you should time your draw down request to ensure that Federal cash on hand is the minimum amount needed for disbursements to be made immediately or within 10 days.
  21. Question: The indirect cost rate for my grant has expired. Can we now use the de minimis rate (10 percent of modified total direct cost)?
    Answer: No. The de minimis rate is for entities that have not previously had a negotiated indirect cost rate. You should renew your prior indirect cost rate.
  22. Question: In the last year of our grant, we need a budget modification. It involves reallocating dollars to a new budget line item. Our funding was awarded all at one time. When we submit our request for a budget modification, do we need to cover the last several years of our grant? Or only the year for which we’re requesting the modification?
    Answer: A grant adjustment (budget modification) will adjust the entire budget and not a specific year. However, reallocating funds to a new budget line item will always require prior approval regardless of the amount.

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GMS and GPRS System

  1. Question: After I go in the Grants Payment Request System (GPRS) to make my grant selections and request my payments for that day, can I go back in and print screen shots of those particular grants?
    Answer: Yes, but keep in mind that those particular grants will have a “pending” status.
  2. Question: Should GPRS passwords be updated every 90 days?
    Answer: Yes.
  3. Question: How can I identify a drawdown request from the Office of Justice Programs (OJP) separately from other Federal agencies?
    Answer: The Department of the Treasury sends a separate document with payment information/codes to each financial institution identifying the drawdown request from each Federal agency. Typically, the codes will begin with the Federal agency (e.g., OJP), the grant number, and finally the amount of the drawdown.
  4. Question: Why would our password suddenly disappear in the Grants Management System (GMS)?
    Answer: Passwords are set to expire after 90 days. The user has the ability to reset passwords in GMS by using the “change password” link on the web page.
  5. Question: What do you do if GMS will not let you update your progress report?
    Answer: Questions concerning GMS may be addressed to the GMS Help Desk at 1-888-549-9901.
  6. Question: When you submit a document through GMS, who gets it first?
    Answer: Your program manager at the awarding agency.
  7. Question: Is the Financial Point of Contact allowed to share his or her email and password?
    Answer: Yes, if your agency permits this.

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Matching Funds

  1. Question: Can we use Federal funds as part of our match?
    Answer: Typically, you may not used Federal funds as part of your match, but there are two exceptions that allow use of Federal funds for match: 1) Housing and Community Development Act of 1974; and 2) funds appropriated by Congress for the activities of any agency of a tribal government or the Bureau of Indian Affairs performing law enforcement functions on tribal lands.
  2. Question: Are the rules for tracking and expending matching funds different from the rules for Federal funding?
    Answer: The rules are not different. It is viewed as one program; however, matching funds should be tracked separately. Your financial reports should include total project costs, including matching funds.
  3. Question: Can I use program income to meet matching?
    Answer: Generally, it is permissible if given prior approval.
  4. Question: Could you elaborate more about in-kind match?
    Answer: In-kind match (soft) includes, but is not limited to, the fair market value of a donated service, equipment, or property – See 2 C.F.R. § 200.306. If in-kind match is permitted by law (other than cash payments), then the fair market value of the donation can be used to comply with the match requirement.
  5. Question: What level of backup are we required to keep for donated computer equipment being used across multiple projects?
    Answer: You must establish the fair market value of the equipment and then determine the percentage of time and usage for each project. Documentation supporting how you determined the fair market value and the percentage of time/usage must be maintained for the life of the grant.
  6. Question: The cost of furniture is not allowable for a federal grant, but is it okay for in-kind match?
    Answer: No, if the cost is now allowable with federal funds, it is now allowable with match.
  7. Question: By when do I have to meet the match requirement?
    Answer: Unless specifically stated otherwise in the grant agreement, matching funds must be put into the program by the end of the award period.
  8. Question: As a pass-through entity, can I require subrecipients to put in matching funds?
    Answer: Yes. You can require a subrecipient to contribute matching funds to a program to supplement their efforts and confirm their commitment to the project.
  9. Question: Is it possible to reduce the cash or in-kind match requirement in an extenuating circumstance (e.g., if an organization backed out)?
    Answer: Yes, you can request a waiver; however, approval of a waiver is done on a case-by-case basis.

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Travel and Per Diem

  1. Question: Can you explain the General Services Administration (GSA) per diem rate restrictions?
    Answer: In brief, it is the maximum allowance that federal employees are reimbursed for expenses incurred while on federal travel.
  2. Question: Where can I find the GSA per diem rate for my area, or for an area where a training or other event for our program staff will be held?
    Answer: Go to http://www.gsa.gov/portal/category/100120.
  3. Question: If your agency travel policy allows only a certain amount for travel but your destination is in a locality where the cost of living is higher, is there any way that you can be reimbursed by the awarding agency?
    Answer: No. The grantee should follow its own established travel policy. However, the awarding agency reserves the right to determine the reasonableness of those rates. If the grantee does not have a written travel policy, the grantee must comply with the Federal travel policy.
  4. Question: If personal days are taken in conjunction with business travel and the airfare is less or the same as returning at the conclusion of the business trip, is that allowed?
    Answer: Yes, it is allowed. However, you must be able to show the analysis performed to support the actual cost. Also, all lodging and per-diem cost for the personal days must be excluded from the business claim.
  5. Question: Can we use incidental expenses to cover tips?
    Answer: Yes. However, the incidental amount within the GSA per diem amount is only $3-$5 per day.

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Subrecipients, Procurement, and Contracting

  1. Question: What is the difference between a subrecipient and a contractor?
    Answer: A subrecipient is a non-Federal entity that expends Federal funds to carry out part of a Federal program. A contractor is a non-Federal entity that provides goods and services to a recipient, creating a procurement relationship with the recipient.
  2. Question: Is the System for Award Management (SAM) registration required for subrecipients as well?
    Answer: Yes, it is required for first-tier subrecipients (those one level below the immediate recipient). This responsibility includes the responsibility to obtain a Dun & Bradstreet Data Universal Numbering System (DUNS) number.
  3. Question: We have a subrecipient contributing a labor-hour match. Do we need to have timesheets for documentation?
    Answer: Yes, timesheets are required. In addition, the sub-recipient should be able to provide documentation supporting the labor cost.
  4. Question: How do we decide what to pay a consultant with whom we have a signed agreement if we now know he/she will not be able to complete the assignment?
    Answer: The consultant agreement originally signed by all parties should include termination and sanction clauses, which would help determine the level of pay.
  5. Question: We included a proposed consultant contract in our grant application that was approved and awarded. Do we need to have this contract approved again, as it might appear to be sole source?
    Answer: Yes, if the dollar amount of the contract is greater than $150,000, you will need prior approval.
  6. Question: Should your agency have a threshold for sole source procurement?
    Answer: Yes, your agency should have a procurement policy which addresses the threshold for sole source; however, if your agency does not have a procurement policy in place, you must follow the awarding agency policy which states that “all sole-source procurements in excess of $150,000 must receive prior approval from the awarding agency.”
  7. Question: If you are a subrecipient and you have an issue, who should you contact first?
    Answer: You should reach out to the primary recipient.
  8. Question: How do I figure out if a subrecipient I do business with is on the excluded parties list?
    Answer: Look up the entity in SAM at https://www.sam.gov/SAM/ to see if it is among excluded parties. You should conduct this search regularly, as business statuses can change at any time.

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Grant Extensions and Grant Closeout

  1. Question: How far in advance should we request a no cost extension if one is needed to accomplish program activities?
    Answer: The request can be done immediately upon receipt of grant award, but recommended to be done 90 days before the end of the grant period.
  2. Question: Can we request more than one extension—for example, if something comes to our attention after requesting and receiving an approval for the initial extension?
    Answer: Yes, proper justification for each extension is required and will be approved on a case-by-case basis.
  3. Question: Is there a limit to the number of no cost-extensions and the length of time?
    Answer:Yes. A grantee may request an initial extension for no more than 12 months beyond the original end date. Additional requests for no cost extensions will be reviewed and approved on a case-by-case basis.
  4. Question: Does filing for an extension reflect poorly on the project?
    Answer: Reasons for extensions vary greatly among recipients, so it is important to provide adequate justification to support the request for additional time.
  5. Question: What is the normal time for an extension period?
    Answer: The maximum allowable extension period is for 12 months.
  6. Question: Grantees are allowed 90 days past the performance end date to liquidate expenditures. What does that mean?
    Answer: Grantees have 90 days after the end date of the award to pay for all obligations in their accounting system. No new costs or expenditures can be incurred during this timeframe.
  7. Question: Can we close a grant based on the provisional rates?
    Answer: Yes, you can close a grant based on a provisional rate. However, if the final rate is different, you must adjust your records to show the difference and submit a revised SF-425 and refund any excess cash, if applicable.

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Fraud and Conflict of Interest

  1. Question: Can a fraud tipster who contacts the Office of the Inspector General (OIG) remain anonymous?
    Answer: Yes, you can request the OIG not to identify the source of the information.
  2. Question: As a prime recipient, would it be worthwhile during training sessions with subrecipients to cover the topic on fraud?
    Answer: Yes, absolutely—you should build it in to your training curriculum.
  3. Question: An award was given to a local government agency. Can the agency hire certain people for certain activities (friends and associates) to do the work?
    Answer: No, it is a conflict of interest.

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General Administration

  1. Question: If in fact we are put on the high-risk list, would a notification be sent out?
    Answer: Yes, all of the information should be included in a letter, as well as how to correct the issues to remove your agency from the list.
  2. Question: Is a DUNS number attached to an address or to an organization?
    Answer: A DUNS number is attached to the organization.
  3. Question: How does OCFO feel about electronic signatures?
    Answer: Electronic signatures are acceptable. Faxed and email signatures are considered electronic and accepted.

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Conferences/Events

  1. Question: Where can I find detailed information about this policy?
    Answer: Refer to the section of the 2015 DOJ Grants Financial Guide about conference planning, approval, and reporting at http://ojp.gov/financialguide/DOJ/PostawardRequirements/chapter3.10a.htm.
  2. Question: Am I required to obtain OJP’s prior written approval for an event I’ll be holding as part of my program?
    Answer: Cooperative agreements and DOJ contractors are required to obtain written prior approval from OJP before hosting an event. Grant recipients are not required to obtain written prior approval, but must be in compliance with the limitations and cost thresholds in OJP policy (see http://ojp.gov/financialguide/DOJ/PostawardRequirements/chapter3.10a.htm).
  3. Question: Are indirect costs related to events allowable?
    Answer: Yes, if you have a currently approved indirect cost rate agreement. You should submit your agreement to OJP to show it is active at the time of the event.

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Sources of Information

  1. Question: Which should I look to first for information: the 2014 Financial Guide of the OCFO or the 2015 DOJ Grants Financial Guide?
    Answer: The 2015 DOJ Grants Financial Guide is your source for information about financial management of your U.S. Department of Justice grant if your grant was awarded after December 26, 2014. For DOJ awards made before December 26, 2014, the requirements in place at the time of award continue to apply for most grantees, making the 2014 Financial Guide applicable. You can access the 2015 DOJ guide here: http://ojp.gov/financialguide/DOJ/index.htm.
  2. Question: If I am not sure if I’ll need prior approval for a specific expenditure, whom should I contact?
    Answer: Contact the awarding agency.

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