AVA/OVW Conference Call – December 2012
Hello STOP Administrators.
I hope you all had a wonderful holiday and are looking forward to a productive new year. The AVA Board of Directors continues to hold monthly conference calls with OVW to discuss topics of concern to STOP administrators. Below is a summary of some recent discussions. We hope you find this information helpful.
Special Condition No. 40: AVA discussed with OVW the special condition dealing with the Civil Rights Compliance. OVW is deferring to OCR for any questions related to the drafting or approval of a state or territory’s policies required by this special condition. They will, however, most likely have someone from OCR at the administrator’s conference in Louisville to speak about this topic.
Michelle Brickley did advise AVA that since OVW is not involved with approving the policy, there will be no hold placed on grant funds pending satisfaction of this condition. Civil rights policies should be sent directly to OCR but OVW recommended that administrators post the policy on GMS once they receive the approval letter from OCR. That way everything is in one place in regards to a particular award.
Some administrators have been asked to provide a narrative in addition to the formal policy. While there is still some confusion around this, it seems that the policy may outline the procedures while the narrative may be more descriptive of how the administering agency will enforce or apply the policy should any action be necessary. Again, please contact OCR for clarification on what they may or may not need from each administrator.
Special Condition 11: This addresses the food & beverage restrictions when using grant monies. OVW has not issued a formal policy; however, they recommended that administrators follow the guidance offered in the letter by Sue Carbon issued earlier this year. States must keep documentation if they are claiming an exemption on food.
Special Condition 28: This condition relates to discrimination on the provision of services. The discussion centered on how providers could offer equivalent services if they were unable to, for example, shelter a victim with older male children. Michelle Brickley indicated it would be sufficient for a provider to show they were able to provide hotel vouchers as an alternative to a shelter bed, as this would be acceptable as equivalent services.
AVA inquired into whether OVW had any information or suggestions on moving forward should Congress not reach an agreement on the fiscal cliff issue. At the time of the call in mid December, no information was available.
There will be no SASP meeting this year. The WOCN will conduct their meetings on February 28 and March 1 in Louisville following the STOP conference. The WOCN regional meetings are being collapsed into the Louisville sessions. An additional session will be held in April in Ohio for those who are unable to stay over in Louisville. Since it was not clear on the conference registration materials that the WOCN regional meetings are no longer occurring, OVW offered that they will send a letter about this meeting to clarify how they will be conducted.
The AVA Board will continue to work with OVW and other national organizations and policy makers on behalf of STOP Administrators in an effort to further enhance the administration of the STOP Grant program. If you need assistance in developing your state’s OCR policies, I have copies of approved policies that I can share with you. The AVA Board has also been working with Congressional staff to help in their understanding of how changes to VAWA will affect the administration of the STOP Grant Program. A separate post will be forthcoming on those efforts and the status of the VAWA Reauthorization.
Please feel free to contact Dorene Whitworth at Dorene.firstname.lastname@example.org should you need any assistance from AVA. Happy New Year!!