Section 270-RICR-10-00-5.4 - Grant AdministrationA. The PSGAO administers federal grants that are applied for and subsequently awarded to the PSGAO on behalf of the State of Rhode Island. In addition to the federal grants, the PSGAO administers one state grant program, the Rhode Island Neighborhood Crime Prevention Act, conditional upon availability of funds.B. Administrative Responsibilities - PSGAO Grant Administrator 1. Each of the federal/state grant programs that the agency oversees require many administrative activities that include (but are not limited to):a. liaise with and staff the appropriate advisory committee(s);b. develop and submit a program plan and application;c. develop an RFP (request for proposals) and subgrant application; review submitted applications;d. present advisory committee recommendations to the Policy Board; e. create subrecipient databases in MS Access; craft grant awards and distribute to subrecipients; f. create and maintain subgrant files;g. liaise with fiscal administrator to process subgrant payments; h. monitor and evaluate programs/projects via both desk audits and on-site visits;i. prepare program progress reports; in accordance with requirements, as set forth in the Office of Justice Programs Financial Guide.j. provide administrative support/technical assistance to subrecipients;k. perform grant closeout and audit procedures; and l. other requirements unique to the various programs. m. create a Grant Binder for each new federal award. C. Types of Grants 1. There are several different kinds of grants that the agency administers. They are: a. Block Grant (1) A block grant represents a fixed award amount, determined by a formula, made to states to provide assistance to state agencies and local units of government (and potentially private, nonprofit agencies) for programs in accordance with delineated legislative requirements. Block grants tend to have broad purpose areas and a requirement that the PSGAO make complete advance payments to subrecipient agencies. Block grants usually require an annual progress report.b. Formula Grant (1) A formula grant represents a fixed award, determined by a formula (usually based on population and/or crime rates), made to states to provide assistance to state agencies and local units of government (and potentially private, nonprofit agencies) for programs in accordance with delineated legislative requirements. Formula grants tend to have more narrow purpose areas and a requirement that the PSGAO make payments to subrecipients on a reimbursement basis. Formula grants usually require comprehensive annual progress reports.c. Discretionary Grant (1) A discretionary grant represents non-formula programs that encourage states, units of local government, or private organizations to prepare proposals for consideration. Discretionary grants are very competitive by nature. Awards are made on an arbitrary basis based on the quantity of applications and the relative quality of the proposals submitted. The limited funds available are ultimately dispersed to a few grant recipients. These grants usually have many detailed special conditions and require quarterly categorical progress reports to the federal administering agency.d. Quasi-Formula Grant (1) These grants are not common but may combine aspects of block, formula and/or discretionary grants. Quasi-formula grants may have the same amount allocated to each state; and/or may allow for supplemental funding for additional activities. The Statistical Analysis Center Program is an example of a quasi-formula grant. These grants usually require quarterly progress reports.D. Notice of Grant Program Funding 1. Announcement of Federal Formula Grants2. The PSGAO is the designated Rhode Island State Administering Agency (SAA) for the following federal formula grants in fixed funding amounts by the Department of Justice: a. the Byrne Memorial Justice Assistance Grant (JAG) Program; b. the Juvenile Justice Delinquency Prevention Act (JJDPA) Grant Program;c. the Juvenile Justice Title V Community Partnership Grant Program;d. the Juvenile Accountability Block Grant (JABG) Program;e. the Victims of Crime Act (VOCA) Victims' Assistance Grant Program;f. the S.T.O.P. Violence Against Women Act (VAWA) Grant Program;g. the Residential Substance Abuse Treatment (RSAT) Grant Program for State Prisoners;h. the Paul Coverdell Forensic Science Improvement Granti. the National Criminal History Improvement Grant Program (NCHIP)3. The Public Safety Grant Administration Office also administers the following quasi-formula grants that are made available to the state in non-definitive funding amounts: a. the Statistical Analysis Center (SAC) Program;4. Each of the formula and quasi-formula grant programs follow a different timeline for administration, however, the grant administrator anticipates new formula grant funding and together with the Advisory Committee, begins to update the previous year's plan prior to receiving the federal notice. Most grants maintain a core strategy from year to year. 5. The PSGAO usually receives notice six to ten weeks in advance of the deadline for submission of the application/plan to the specific Department of Justice agency that oversees the grant program. The notification normally includes the program announcement, specific program guidelines/funding criteria, and a standard federal grant application package. 6. Each PSGAO grant administrator completely reviews the grant program announcement that he/she is responsible for and discusses the potential impact on the current plan prepared by the administrator and advisory committee. Together, they develop the new plan and the administrator prepares the grant program application.7. Notice of Availability of Discretionary Fundinga. Many discretionary grants are also announced periodically by the Department of Justice as Congress approves new programs or attempts to address criminal justice problems not related to a specific formula grant. Discretionary grant programs are competitive in nature. States, counties and municipalities submit proposals with no guarantee of funding. The PSGAO may apply for the funding on behalf of potential beneficiaries.b. The recommendation to apply for a discretionary grant must be approved by the Administrative Manager. The PSGAO will only approve such an application if the eligibility criteria dictates that a state agency be the applicant.c. Staff of the PSGAO become aware of many funding opportunities, both public and private, that may be of interest to other state agencies, local units of government and private, nonprofit organizations. PSGAO staff will, when time permits, pass along funding information to the appropriate agencies. 8. Notice of Availability of State Funding a. In addition to the federal grants, the PSGAO administers one state grant program: (1) the Rhode Island Neighborhood Crime Prevention Act.b. The Crime Prevention program funds are included in the PSGAO's operational budget and are available for program activities at the beginning of the state fiscal year, conditional upon the availability of funds.E. Advisory Committees 1. The PSGAO Administrative Manager and grant administrators do not make funding decisions. PSGAO grant administrators directly manage the various grant programs with the input of the designated advisory committees. Individuals with expertise in the grant program area comprise the membership of the various advisory committees. Representation includes state, local and private-non-profit entities. No advisory committees exist for those grant programs that are intended solely for distribution to one or two state criminal justice agencies, i.e. RSAT. In this instance, the two agency directors work out an acceptable distribution of funds. If there is a dispute as to the distribution, the Steering Committee will make the final funding recommendations.2. The following advisory groups work with the appropriate PSGAO grant administrator to develop policy initiatives, establish program priorities (with input from the PSGAO Steering Committee), make funding recommendations to the Policy Board and monitor the progress of subgrantee agencies: a. the Juvenile Justice Advisory Committee (JJAC); b. the Victims of Crime Act (VOCA) Advisory Committee; c. the S.T.O.P. Violence Against Women (VAWA) Planning Committee (includes the Subcommittees: Law Enforcement Training; and Curriculum Development); d. the Crime Prevention Planning Committee (CPPC);e. the National Criminal History Improvement Program (NCHIP) Committee; f. the Local Law Enforcement Planning Committee; and g. the Technology Advisory Committee (TAC) with several ad hoc subcommittees.3. The grant administrator acts as staff to the Advisory Committee and is responsible for taking minutes at all committee meetings.4. Membership a. Membership on most Advisory Committees is determined by identifying and including members from a representative sample of those agencies, both public and private that ensure pertinent issues are addressed fully, impartially and completely. Committees may have certain membership requirements set forth by the federal granting authority. In such cases, the grant administrator, with the assistance of the advisory committee, will recommend all federally mandated members for appointment. b. The Governor, Policy Board Chair, or Administrative Manager can appoint members to an Advisory Committee, with the exception of those with membership requirements set forth by the federal granting authority, such as the Juvenile Justice Advisory Committee.5. Meetings a. Advisory Committee meetings are normally scheduled at least a month in advance and on an average of six to eight times per year, depending on the various committees' needs. All meetings are subject to the RI Opening Meetings law and must be handicapped accessible. 6. Notices a. Meeting notices for all grants programs are mandatory. They are to be uniform and include all pertinent information such as: main agenda items, votes to be taken, date, time, and location. The grant administrator's name and contact number are also to be included. b. The meeting notice is to be posted at least one week in advance at no less than the three following locations: the PSGAO, the 1st floor in the Department of Administration (outside the bank of elevators) and one copy to the State House library for posting on the public bulletin board. The meeting notices are also filed with the Secretary of State electronically at least 48 hours in advance of the meeting, pursuant to Rules and Regulations adopted by the secretary of State pursuant to R.I. Gen. Laws Chapter 42-46, as amended.c. Grant administrators must mail, fax or e-mail copies of the minutes along with the meeting notice to all committee members a minimum of one week prior to the meeting to allow sufficient time for review of materials.7. Minutesa. The grant administrator is responsible for ensuring that minutes of all committee meetings are taken. Minutes may be assigned to a secretary elected by the committee. Minutes must contain: the date, time and location of the meeting, the name of the advisory committee and grant, members present, a general description of discussions and a specific record of all votes and/or decisions arrived at by consensus. All recommendations for funding are to be in the form of a motion with a vote ensuing. Motions are to be recorded verbatim indicating the proposer, the seconder and those members voting "nay" or abstaining. Some committees (such as TAC) may make decisions by consensus at the approval of the Administrative Manager. However, decisions are still to be recorded and any pertinent discussion or opposition must be noted.b. The minutes of Policy Board meetings must be electronically filed with the Secretary of State through the Secretary of state's Open Meetings website according to protocols set forth by the Office of the Secretary of State.c. Copies of minutes are to be included in a section of the grant binder and retained with all of the federal grant files for the particular grant year. All grant files are to be retained for a period of three years after the Single Audit Report has been filed for the fiscal year during which the grant has been officially closed by the original funding agency and the final Financial Status Report has been filed with the Office of the Comptroller.8. Plan Development/Approval a. Once an Advisory Committee reviews the newest grant program announcement, it meets to develop specific funding strategies that are based on the grant's delineated eligible priority areas. The grant administrator and Advisory Committee Chair (or other designated committee member) meets with the PSGAO Steering Committee to present the plan. The Steering Committee reviews the Advisory Committee's plan and either approves the plan or makes recommendations to ensure that relevant aspects of any identified criminal justice system problem will be addressed. Specifically, the Steering Committee may direct that any RFP include specific language requiring a focus on certain projects or activities.b. Upon Steering Committee approval, the grant administrator submits the plan and application to the appropriate federal office for review and approval. 9. Plan Submission a. All applications are to be submitted to the Office of Justice Programs electronically via the Grants Management System (GMS), or through Grants.Gov when required.10. Receipt/Acceptance of Grant Award a. Normally, it takes upwards to two months for the plan to be approved and an official federal award forwarded to the PSGAO after submission of the plan/application to Washington. Upon receipt, the Administrator reads all special conditions and advises the Administrative Manager of any concerns. Usually, there are two original grant award documents. The Administrative Manager signs both awards. The grant administrator immediately forwards one original award to the federal granting office and files the other original award in the Grant Binder. The administrator also forwards a copy of the award to the Central Business Office for processing.F. RFP/Application Process 1. Display Advertisement a. Once the Steering Committee has provided its input, the Administrator finalizes the RFP and application package. (1) The RFP is advertised at least once in the Providence Journal, preferably on the highest circulation days of Sunday and/or Wednesday. The display ad is usually two columns wide by 5 to 8 inches tall. The PSGAO requests that the ad be placed in either the main section (front page) or the local section (regional) of the paper. (2) The RFP is also advertised on the PSGAO website and the State of Rhode Island Division of Purchases website. (3) Display advertising is normally charged off to the particular grant program's administrative account. Be sure sufficient funding exists for ad prior to placing the order.(4) The RFP identifies the grant program, the federal (or state) fiscal year, the amount of funds available, the federal program priorities, selection and evaluation criteria, notice of a pre-bidders' conference (if required), grant submission deadline, number of application copies required, PSGAO address and contact name and telephone number.(5) The advertised RFP must allow a minimum of one full month between advertised date and deadline for submission of proposals.(6) All advertisements for RFP's must be approved by the Administrative Manager prior to publication.(7) The Administrator must have application packages and/or related materials available in sufficient quantities on or before the RFP is advertised. The administrator is to provide a copy of the advertisement and the application package to the Administrative Manager, the Grants Assistant and the Administrative Assistant prior to the publication of the RFP ad. (8) A sufficient quantity of application packages are to be placed in a designated location within an area of public access for the life of the RFP cycle.2. Automatic Notificationa. The grant administrator automatically forwards a copy of the RFP/application to all existing subrecipients of the grant program. Further, RFPs are to be mailed to any agency or individual that had requested same since the last RFP.3. Pre-Bidders' Conference a. For all RFP grants, the Grant administrator schedules a pre-bidders' workshop shortly after the RFP is advertised (within 7-10 days). Depending upon the grant program and the decision of the Advisory Committee, the workshop may be mandatory or optional. However, there must be suitable reasons to designate a pre-bidder's workshop as mandatory. Designations of mandatory participation workshops should be discussed with the Administrative Manager.b. Prospective sub-recipients that do not send a representative to a mandatory pre-bidders' workshop are not eligible to apply. Any application submitted by a group that has missed a mandatory pre-bidders' workshop will be not be distributed to committee members for consideration. c. At the pre-bidders' workshop, the Grant administrator discusses all relevant aspects of the subgrant application focusing on the federal intent of the grant program and the state's specific selection and evaluation criteria. The Administrator will describe the application pages thoroughly. The goal of the workshop is to ensure that all prospective subgrantees understand the application and complete it in a timely and accurate manner. All prospective applicants will further be briefed on the provisions of the grant conditions and assurances that they will have to comply with if selected for funding. Included in this briefing will be the provisions of Title VI of the Civil Rights Act of 1964, Executive Order No. 13279 and Justice Department Regulations 28 C.F.R. Part 38 which seeks to prevent discrimination of faith based organizations, protect the organization's autonomy while ensuring no federal funds are used to engage in inherently religious activities (i.e. praying, proselytizing, etc). d. All questions by the attendees are answered to the best of the Administrator's ability. Should there be any significant clarification requiring research by the Administrator, a written response is provided to all attendees within 7 days of the session. Normally, no telephone calls to the Administrator are allowed after the bidders' conference regarding the application. The Administrator may use his/her discretion, however, in answering certain questions that would not give other prospective applicants an advantage over competing proposals.4. Submission of Applications to PSGAOa. The Grant administrator accepts applications up until the deadline for submission. The original application is date stamped upon receipt by the Administrator or other PSGAO staff. Agencies hand-delivering applications are provided a photocopy of the original date stamped cover as proof of receipt. The Administrator anticipates the influx of applications and prepares a holding area for submitted applications and communicates this to other PSGAO staff.b. The Administrator accepts the grant applications and logs them into a program abstract computer database. The abstract database includes the name and address of the agency, proposed project title, a brief project description and amount requested. c. Important Note - Under no circumstances can anyone other than the chief elected official or agency director apply for a grant. Should any other agency representative sign the grant application, the grant administrator should return the application and request that the appropriate official sign the application. However, an application submitted at deadline without the appropriate signature (or with other omissions) may cause the application to be rejected. The Advisory Committee may, however, allow an application to be amended should it deem the proposal worthy of consideration. Should this be the case, the grant administrator would request that the applicant agency make the appropriate amendments and resubmit the document prior to an award being made.d. Late Submissions - Mailed applications must be received at the PSGAO by the deadline day or subsequently with a postmark no later than the deadline date. Those applications received after the deadline or without the appropriate postmark date, will usually be rejected and not reviewed or considered for funding. With the recommendation of the grant administrator, only the Administrative Manager can allow for a waiver of the late submission policy. An exception may be made based on special circumstances and conditions, taken on a case by case basis. 5. Grant Reviewa. The grant administrator disseminates copies of the applications to the various Advisory Committee members. An administrator may require an original application with a sufficient number of copies for distribution to committee members. If insufficient copies of application exist, the grant administrator must make the appropriate number of copies. Normally, each committee member reviews and rates all grants. Any other system whereby all grants would not be reviewed and rated by all committee members will require the approval of the Administrative Manager. b. Sufficient time must be allowed for committee members to review the grants, usually one to two weeks at a minimum.c. Rating Sheets - The PSGAO generally utilizes standardized ratings forms to objectively review grants applications. Grant administrators and their advisory committees may wish to include additional criteria unique to their specific grant program. This is an acceptable procedure; however, the unique criteria should be discussed with the Administrative Manager. Advisory Committee members utilize the rating sheets to assign point values to various sections of the application as detailed in the RFP. Committee members submit the rating sheets to the Administrator who averages the scores and creates a list, ranking the various proposals. The very critical computations must be checked by one other PSGAO employee. All PSGAO staff checking the computations are to initial and date a printout of the figures.d. An Advisory Committee may choose to eliminate from consideration those proposals that score below an arbitrary "cut-off" point. Those grants that survive the "cut" are then discussed at subsequent committee meetings. The Committee may then decide to pare budget line items or amend programmatic activities for any grant proposal in order to bring the total funding requests into line with available grant funds. The Administrator makes note of both discussions and votes and records them in the minutes of the meeting. e. Retention - All meeting minutes and rating sheets are to be kept with the original federal grant file and retained as long as required by state and federal mandate.f. Unsuccessful Applications - All rejected applications for funding are to be kept with the original federal grant file and retained as long as required by state and federal mandate. Successful applications are filed in their individual grant folders.g. Policy Board Involvement - Once the Advisory Committee has determined its funding recommendations, the Administrator creates a detailed summary following the standard mail merge ready form consistent with all other grant awards in style and format. The summary will include all applicants, successful and unsuccessful, the agencies' funding history (under the specific grant program), comments from the Advisory Committee and specific recommended funding allocations. This summary is derived from the original grant database. The administrator submits the summary to the Administrative Manager for review and approval. Approved grant recommendation summaries are mailed or faxed to members of the Policy Board for consideration at least a full week in advance of the next scheduled Policy Board meeting by the Administrative Manager.h. The Chair of the Advisory Committee and/or the grant administrator attend the Policy Board meeting, present the committee's recommendations and entertain questions regarding the grant review process and the funding recommendations. The Policy Board then votes to approve the recommendations.G. Subgrant Awards 1. Create Draft Award Documents a. Grant Summary - Create a one page summary of each approved project following the standard mail merge ready form consistent with all other grant awards in style and format. Be sure that all fields have data inputted.b. Grant Award - The Grant Award should be the standard mail merge ready form consistent with all other grant awards in style and format. Specific grant information can be merged along with other subrecipient information and/or added to the merged document.c. Important Note: The end date for all grant awards must coincide with the end of the state fiscal year, nothing before, even if the project is slated to end prior to the state fiscal year. This practice allows programs more time to encumber and expend grant funds.2. Approval of Awards - Administrative Managera. Award Letter - Prepare award transmittal letter from Administrative Manager to the chief elected official or agency director, whichever is the authorized agency official that signed the grant application.b. Award Process - Place one unsigned award in subrecipient grant folder as a placeholder and have the Administrative Manager sign the remaining three (3) awards and cover letter. Submit the grant award packages to the Administrative Manager in the order and/or format requested. Once documents are signed and returned to the grant administrator, forward the letter of transmittal, the three original awards (and three (3) original cooperative agreements in the case of state agencies) and all appropriate report forms (fiscal and programmatic) to either the chief elected official or project director. (1) Note - A grant administrator may choose to send the award sets to the project director rather than the agency director if that would be beneficial in expediting the award acceptance process. Nonetheless, the awards still need to be signed by the CEO.c. Make two copies of the signed letter. File one in the appropriate section of the subgrantee folder and submit one copy to the Administrative Manager's Executive Assistant. One letter, if standard, may suffice for the Director's correspondence file as long as a list of recipients is attached. (1) Note - If an agency is receiving more than one grant, combine information on all grants in one letter and mail all grants in one envelope. d. Upon receipt of the signed awards from the subgrantee agency, the grant administrator forwards one set to the Central Business Office which sets up the official state account while one original set is filed in the main subgrant file folder.e. Cooperative Agreement - Create a one page cooperative agreement for each state agency project. The end date for all cooperative agreements must coincide with the end of the state fiscal year, even if the project is slated to end prior to the end of the state fiscal year. This practice allows subrecipients more time to encumber and expend grant funds without the grant administrator having to execute an amended grant and/or cooperative agreement. (1) Note - It is allowable to run a project's end date out past the next fiscal year end if the program's timeline dictates.H. Subgrant Files 1. Subgrant File Folder a. The Subgrant file folder is a six-part pressboard folder and is created at the time that the grants are being processed. Using the grant database, merge the state subgrant number, recipient agency name and project title on a file folder label and place on the raised tab of the file folder for ease of identification (see below). (1) Coventry Police Department(2) 96-SI-106 Justice Linkb. The "96" is the federal grant year. The "SI" is an abbreviation for the grant program and the "106" is an arbitrarily designated grant number. Grant numbers should be three numbers and ideally be designated in a sequential order. If an agency has more than one project in any given grant year, the administrator may wish to include a brief project title to differentiate the folders (see Justice Link above).c. The folders for all grants in one fiscal year should all be the same color unless specific circumstances dictate the use of various colors. Each subgrant file folder, regardless of grant program, is organized in the same fashion as follows: (1) Inside Cover (left) - Grant Application submitted by sub recipient;(2) Inside Cover (right) - Grant Award (with cooperative agreement for state agencies as page three of the award document);(3) Middle Section (left) - Financial status reports, most recent on top;(4) Middle Section (right) - Reimbursement Requests, most recent on top;(5) Back Section (left) - Program progress reports (most recent on top) and any press clippings;(6) Back Section (right) - Grant correspondence, to and from subrecipient.d. This uniformity of arrangement ensures that if one wished to peruse a grant, one would expect to find the same type of information, in the same place as in all other PSGAO grant files. This is essential should the Administrative Manager, or other interested party (auditor, federal liaison) need to locate specific information about any particular grant.2. Reimbursements a. The grant reimbursement request form is completed by the subrecipient and forwarded to the grant administrator along with a current fiscal report for review and approval. Upon approval, the grant administrator forwards the request, with the fiscal report, to the Administrative Manager for final approval and signature. Both are then forwarded to the Central Business Office fiscal personnel.3. Monitoring a. Each grant administrator is required to fully monitor the performance of all subgrantee programs. Grant proposals are required to include a budget narrative and measurable objectives. The main reason to monitor is to ensure that grant funds are expended according to the approved project budget and that activities and purchases are impacting stated objectives.b. The two types of monitoring are: (1) Desk audit - reviewing submitted fiscal and progress reports and/or consultation on the telephone; meeting at Public Safety Grant Administration Office; and(2) On-site visit at agency or location of subgrant program.c. Regardless of the type of monitoring used, a monitoring worksheet summary is to be completed by the grant administrator and filed in the subgrantee folder.4. Site Visits a. Grant administrators are to perform a minimum of 6 site visits annually with a goal of visiting all funded programs in each three year period. Grant administrators may wish to have one or more advisory members accompany them on site visits. Further, should concerns exist regarding a subgrantee's financial records or practices, the PSGAO Financial Agent (of the Central Business Office) may be called upon to review the grant file and/or accompany the administrator on a site visit. Always check with the financial agent to determine his/her availability before scheduling a site visit that required his/her presence.b. Schedule site visits after consulting with the subgrantee for a mutually agreeable time. Confirm the site visit, in writing under the Administrative Manager's signature, as soon as the visit has been arranged. Be sure to forward written correspondence to the Chief Elected Official with a cc to the project director (if different from CEO).5. Mandatory Reports a. All reports that are mandated in the grant regulations or in the special conditions, including periodic progress reports and quarterly Financial Status Reports (SF-269) will be filed in a timely manner according to the requirements as set forth in the individual grant.6. Retention of Records a. Records to support all expenditures charged to federal grants, including time and attendance reports for all individuals reimbursed under the award will be retained for three (3) years after the submission of the closure of the single audit report which covers the entire award period. All records pertaining to federal awards are maintained in accordance with the requirement set forth in 28 C.F.R. Parts 66 and 70.270 R.I. Code R. 270-RICR-10-00-5.4