OJP grantees must initiate a GAM in JustGrants for budget modification, if:
- The proposed cumulative change is greater than 10 percent of the total award amount. The 10 percent rule does not apply to an award of less than $250,000. However, for recordkeeping purposes and audit documentation, OJP advises grantees to submit a GAM even if the proposed budget modification is less than 10 percent of the total award amount. This also provides the OJP grant manager with notification of proposed changes.
- The budget modification changes the scope of the project. Examples include altering the purpose of the project, authorizing the use of a subcontractor or other organization that was not identified in the original approved budget, or contracting for or transferring of award-supported efforts.
- A budget adjustment affects a cost category that was not included in the original budget. For example, if the direct cost category “Travel” did not exist in the original budget, the adjustment to transfer funds from “Equipment” to “Travel” requires a GAM.
- There is any dollar increase or decrease to the indirect cost category of an approved budget.
Please refer to 2 C.F.R. § 200.414(f) and the DOJ Grants Financial Guide for information governing the use of the de minimus indirect cost rate.
Grantees must keep detailed accounting records and documentation to track match funding. The grantee’s financial records must clearly show the source, amount, and timing for all matched contributions. The grantee has the primary responsibility for meeting the match requirement and for ensuring subrecipient compliance with match requirements. In addition, if a recipient or subrecipient has included a match that exceeds the required matching portion within the approved budget, the records of those additional amounts must be included and maintained as if they are a part of the regular match amount. Matching funds are restricted to the same use of funds as allowed for the Federal funds, and subject to audit.
Please note that grantees may not use Victims of Crime Act (VOCA) funds, or funds from other Federal awards, as match funding for OVC anti-trafficking awards.
Grantees are required to report the match (both cash and in-kind) on the quarterly Federal Financial Report (FFR). Additionally, the full matching share provided (both cash and in-kind) must be reported on the final FFR submitted at the end of the period of performance. If the matching share is not reported, DOJ will assume the grantee did not meet the required match and will initiate collection of a cash match from the grantee. The DOJ Grants Financial Guide includes additional information on matching and cost sharing requirements.
For general government-wide rules regarding match and match requirements, see 2 C.F.R. § 200.306.
A non-Federal entity that expends $1,000,000 or more during the non-Federal entity’s fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of 2 C.F.R. § 200 Subpart F – Audit Requirements. Audit reports must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or 9 months after the end of the audit period.
Federal agencies can no longer grant due date extensions for submission of single audit reports. The Federal Audit Clearinghouse (FAC) requires all grant award recipients to use the Internet Data Entry System (IDES) to submit the Standard Form-Single Audit Component (SF-SAC) and the Single Audit Reporting package online.
Please send any requests for the auditor of your organization to OJP’s Audit Confirmation email: [email protected].
Under OVC-funded anti-trafficking programs, organizations should not collect “contributions” from survivors to fund services (in whole or in part) or collect funds for other purposes such as encouraging saving by “holding” funds or opening a savings account on behalf of the individual. OVC-funded services should be provided free of charge, and if program participants are encouraged to open a savings account to establish financial stability, it should be in their own name and any contributions should be voluntary.
In some circumstances, OVC may permit housing assistance programs to use a sliding scale or contributory model towards rent and collect funds from program participants; however, the grantee must first consult with their OVC grant manager, as these funds may be subject to the rules governing program income (see DOJ Financial Guide).
Persons who have been subjected to a “severe form of trafficking in persons,” as defined in 22 U.S.C. § 7102(11).
(A) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age; or
(B) the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.
An individual does not need to currently be in a trafficking situation to be eligible for victim services, or have recently exited their trafficking situation. Grantees should remove barriers that prevent individuals currently experiencing trafficking from accessing services, such as policies related to sobriety, engagement in commercial sex, etc.
OVC acknowledges that the amount of time and the process for determining if a person meets the definition of a victim of human trafficking may differ for every client and situation. OVC considers an individual to be a “potential” when the grantee has reason to believe that the person is or might be a trafficking victim and is providing support or services tailored to that individual. This may occur at an initial intake or screening interview, or upon completion of victim needs assessment.
When the information needed to determine eligibility is not immediately available, and the person is not clearly ineligible, a grantee may use OVC funds for a reasonable period of time to provide services until sufficient information to make a determination has been gathered and a determination has been made. If the client is not eligible, they should be referred to other appropriate services and providers.
Your notice of funding opportunity will outline client eligibility and any specific age range limitations, if any exist.
Yes. OVC encourages grantees to coordinate their efforts with other similar OVC-direct funded human trafficking programs within the relevant jurisdiction to enhance the projects and avoid duplication of efforts. Grantees are expected to work together to determine whether OVC discretionary award funds have been, are being, or are to be used (in whole or in part) for one or more of the identical services for the same person or family member (cost items) included in the each of their grant award budgets.
If duplicative costs and services are identified, each grantee must notify their OVC grant manager(s) in writing of the potential duplication and, if requested by OVC, submit a Financial or Programmatic GAM to eliminate any inappropriate duplication of funding.
Yes. As long as there is no duplication in costs or activities, OVC funds may be used to provide services to a client who is already receiving services through another federal funding stream. For example, an OVC grantee could provide legal services to an individual client receiving housing services funded through a different federal award. However, please consult requirements for other funding sources, as they may differ.