AVA/OVW Conference Call – July and August 2012
Hello STOP Administrators:
AVA strives to keep STOP administrators fully informed on a variety of topics affecting the administration of their STOP Program. As such, AVA continues to hold monthly conference calls with OVW to gain clarification on issues that have been voiced by administrators and to continue our involvement with upcoming events like the annual administrator’s conference. Below is a summary of our discussions for July and August 2012.
Administrator Conference Planning Calls:
- Currently OVW is primarily focusing on issuing the STOP awards so the conference planning calls have not been initiated. Planning calls will start in the fall – possibly as early as September. Planning calls will be conducted weekly between OVW, ALSO, and AVA (concept, logistics, topics, etc.) Calls seeking input directly from administrators will be more limited in number and scope.
- It’s looking like Kentucky will most likely be the location of the conference. OVW and ALSO are looking at dates from mid to late February 2013, with the goal of avoiding going into March (to avoid conflicting with annual report due dates). The exact dates should be available soon.
- AVA will be reaching out to ALSO to initiate discussions about the conference. A decision still needs to be made regarding the broad theme of the conference.
OJP Conference Policy:
- In May of this year, OJP issued a policy relating to conference costs. AVA received confirmation from OVW that the OJP policy does not apply to OVW/STOP programs. OVW is in the process of drafting their own policy and should have that out to their grantees soon. OVW’s policy will be similar to that of OJP but some differences will be noted, e.g. food allowances will vary for training events/meetings with victims vs. law enforcement.
- In the meantime, OVW references the memo from Sue Carbon from October 2011 (attached). As grantees, STOP administrators do not have to submit for approvals to OVW but administrators must ensure their subgrantees comply with the federal guidelines. Administrators should continue to operate under the October’s memo until the OVW policy is distributed.
Travel and Meeting Audits by OIG/DOJ
- State administrators have expressed concern when they’ve received an OIG Audit – they’ve received findings when following OVW guidelines. They’ve been told that they must follow the DOJ Financial Guide. AVA reached out to OVW for clarification of which rules apply, the OJP Financial Guidelines or OVW Guidelines.
- It is important to determine the time period of the program being audited, i.e. in 2009 administrators were still following OJP Financial Guide since OVW’s financial office was not up and running. The OVW financial guidelines apply to grants awarded after that guide was issued. Local programs are allowed to set their own travel policies provided they don’t exceed federal guidelines.
- Michelle Brickley discussed that items or questions during the audit are oftentimes things that can be resolved but will not necessarily result in findings. Auditors are often from DOJ but they will come back to the program office (OVW or other federal agency) to better learn the nuances of the specific program.
- Michelle also suggested that perhaps someone from DOJ and/or OIG should present at the new administrators session of the next STOP conference to explain the audit process and what administrators can expect. Administrators may find it helpful to know what they would need to provide during the audit, what their role is during the audit process, etc.
- OVW has indicated the administrator’s manual is currently being finalizing based the input from legal counsel review. At this time OVW indicates that the manual will potentially be available by the end of the year. AVA asks if it would be possible to obtain a draft copy for review or simply view the Table of Contents to share with Administrators what they can expect from the manual. Unfortunately this isn’t possible until OVW obtains approval from legal counsel. AVA stressed the importance of releasing the manual soon since implementation plans will be due again next year.
- OVW is taking time to ensure that the manual is user friendly and that there is clear delineation between administrator role (reporting, etc.) and pass-through agency responsibilities (monitoring, etc.), as well as providing resources to administrators.
- AVA has asked OVW to incorporate a procedure whereby they provide acknowledgement of receipt of subgrantee annual reports from STOP administrators. AVA offered that this could be as simple as an email indicating OVW has received the CD and it is currently under review. AVA recognizes OVW must download the CD to determine if all data is accurate and accessible. OVW has offered to discuss this internally to determine how they might be able to communicate receipt.
Award Process and Status:
- OVW is currently working on the STOP awards – most have been processed beyond the OVW level. Hopefully they will start rolling out by the end of August. All awards must be out by September 30th. Like last year, they will send the awards out on a rolling basis with awards reflecting a July 1st start date. However, Michelle cautions that although administrators could start their solicitation process, they should not be issuing local awards before receiving their award documents.
- This year’s award will contain several new special conditions. As previously discussed, all formula awards will be required to meet the OCR guidelines within 90 days but the money is not tied to this. Awards will not be frozen if states are unable to meet this deadline. OVW will send AVA a copy of the new special conditions and we will share those as soon as we receive them.
Program Income – Sliding Scale Fees and Registration Costs:
- AVA asked for clarification of program income, e.g. how it should be tracked and applied toward funded projects, what is allowable, etc.
- Registration costs – depending on how a project is funded, e.g. 50% STOP funded, then 50% of the program income should apply to that grant project. Registration fees must be tracked like grant dollars. Subgrantees will need to show how those fees are spent, e.g. since food is no longer allowable under the new federal policy, registration fees (program income) can’t be used for food either. Subgrantees should get prior approval from state administrator for use of program income. Program income should be applied toward the costs of the project prior to drawing federal funds. Sub-recipients should be tracking and reporting program income generated, and states must report this information in their Federal Financial Reports.
- Therapy and/or counseling – the project funds a therapist or counselor, the program income could be used toward anything associated with that therapy, e.g. informational brochures, etc. Again the program income should be spent first before drawing down federal funds.
Muskie Forms Expiration:
- The Muskie forms currently show an expiration date of March 2012. AVA asked whether these will be updated or whether this impacts use of the forms. Michelle Brickley will check with Jen Kaplan and Christina Murry on the status of the forms; however, she doesn’t anticipate modifications until VAWA is reauthorized. Most likely administrators will continue to use the forms even though they show an outdated expiration date. OVW will let us know the status if and when things change.
VOCA and STOP:
- Michelle Brickley has been invited to present at the VOCA administrator’s conference in Atlanta. She is uncertain at this point what topic she will be speaking on; however, she encourages STOP administrators who attend the VOCA conference to touch base with her if they have an opportunity. AVA Board Members who also administer the VOCA Program will work with Michelle to educate her on the similarities and differences between the two programs. Both VOCA and Comp will be at that conference.
We hope this information is helpful. If you have additional issues you would like AVA to discuss with OVW during our monthly calls, please contact Dorene Whitworth at Dorene.firstname.lastname@example.org or 775-721-4691. Thank you!