1. Indiana Grants Management Policy
Gabrielle Owens, Legal Counsel
Devon McDonald, Deputy Director

2. Presentation Overview
Who is ICJI and what do we do?
Why did ICJI develop our grants management policy?
What is our grants management policy?
How has it changed our process?
How have we implemented the policy?
How are we addressing changes?

3. Overview of the ICJI What is ICJI? Executive branch agency
Established in 1993 by Ind. Code 5-2-6
State Administering Agency
OVC, OVW, BJA
Statistical Analysis Center
Policy Development
Justice Reinvestment
Juvenile Justice (JDAI, Children’s Commission, Compliance Monitoring for JJDPA)
Criminal Justice research
Criminal Code reform

4. Overview of the ICJI Organizational Structure Board of Trustees
Approval authority for funding determinations, agency priorities and strategic planning
Executive staff
Divisions
Drug and Crime Control – BJA
Victim Services – OVC and OVW
Youth Services - OJJDP
Research

5. Why? 2 CFR 200 and updated DOJ Financial Circular Compliance
Lack of internal structure and uniformity
No training for new or existing staff
Staff turnover
Ineffective and inefficient work product
Discovery of multiple internal and external issues identified through monitoring
Updates to ICJI and state processes

6. What is the policy? Intent
To be a singular uniform source of information on ICJI’s business process for administering state and federal funds.
Provide information to new and existing staff on the entire process from application to closeout

7. What’s in the policy? Overview
Describes the purpose and contents of the policy (kind of an executive summary)
Specifics on agency policy, procedures, and processes
Indiana specific process
Federal references, regulations, guidelines
Grant specific requirements

8. Grant application requirements
Policy guiding the making of an award
Funding priorities
Evidence Based Decision Making (EBDM)
Types of awards (cooperative, subgrant, fixed amount)
Conflict of interest disclosures (state and federal)
Decisions and voting
Contracts with financial interest
Notification of funding announcement (NOFO)
Eligibility requirements
Application elements

9. Certified Assurances State Compliance and Certified Assurances
E-Verify
Ethics
Witholdings and outstanding actions
Licensing
Business registration
Procurement
Drug Free Workplace Certification
State Civil Rights requirements

10. Grant review and award acceptance
Application review – basic overview and how to
Award process
Risk assessment – standardized process and agency wide application
Program and operational fiscal responsibilities
Award packet – agreement, exhibits, clearances
Acceptance and Terms
Notifications
Grant period and closeout

11. Payment Standards Standards for approving and processing payments
Internal and state process for making payments
Approving invoices – also look to reporting requirements and supporting documentation

12. Standards for Financial Management
Accounting system criteria
Subrecipient must have an adequate accounting system
Meets DOJ and 2 CFR 200 requirement
Total Cost Budgeting and Accounting
What is the subrecipients total annual budget across all sources of funding
Reporting Irregularities
Subrecipient duty to report to illegal activity or findings

13. Standards for Financial Management
Commingling of Funds
Must account for each separate award
Supplanting
Supplement not replace
Matching or cost sharing
Requirements – look to the individual grant
Types – Cash and In-Kind

14. Reporting requirements
Programmatic reports
Status of the project being funded
Activities completed or deliverables met
Fiscal reports
Supporting Documentation
2 CFR § and DOJ financial guide
Program modification request
Late reports
Notices
Penalties
FFATA reporting – staff requirement

15. Budgeting Budget Categories – balance against allowable costs
Personnel and employee benefits
Travel
Authorization
Dedicated amounts
Equipment
Supplies and operating expenses
Conference costs
Consultants
Indirect cost rate
Source
Revisions and modifications

16. Allowable/Unallowable Costs and Procurement
Allowable and unallowable costs
DOJ financial circular
2 CFR § and
OJP grant specific requirements
BJA, OVC, OVW
Lobbying
Procurement
state and federal guidelines and methods
Conflict of interests
Records
Competitive vs. sole source

17. Monitoring Types of Monitoring On-Site Desk Review Two Year Cycle
Fiscal & Programmatic
Desk Review

18. Audits Audit Considerations Subrecipient responsibilities
ICJI responsibilities
Thresholds
Costs

19. Sanctions Breach and termination of agreement
Failure to adhere to conditions
Addition of agency specific conditions
Risk status
Impact to availability of future funding
Stop payment

20. Changes to our process Forced us to examine our processes
Highlighted shortcomings to current process
Identified needed improvements to technology
Identified need for additional staffing
Streamlined and provided more uniform processes across the agency
Standardized how we deal with subrecipients

21. Implementation Grants management training – thank you NCJA!
Internal unveiling and training
Staff resistance
The shock and awe effect
Revisions to policy
Development of subrecipient manual

22. Future improvements/revisions
Must be a living document
Changes to state and federal policy, guidance, regulations, and law
Technology
Additions or changes to current technology solutions
How can the policy can shape development of new technology?
Changes to internal policy
How can we improve this based on what we have learned?

23. Questions?

24. Indiana Grants Management Policy
Gabrielle Owens, Legal Counsel
Devon McDonald, Deputy Director