AVA/OVW Conference Call – September 2011
On September 12, 2011, AVA conducted a conference call with OVW to get clarification on some issues that STOP administrators had raised. Those discussions are outlined below:
States/ territories have approximately 90 days to submit a waiver request after award documents are issued. Justification for a match waiver includes evidence of economic distress, such as documentation of high unemployment rates, poverty rates, and designation as a FEMA disaster area and how this affects the State’s ability to provide violence against women matching funds may demonstrate financial need. (See OVW FAQs).
OVW’s goal is to review all requests within 1-2 days of receipt and then send them out to the full STOP team for comment. The STOP staff prepares a recommendation to Michelle Brickley and the request is then processed further up the chain. OVW estimates administrators should receive a response to their request within 30 days. No GAN is issued for match waivers; the administrator should receive a letter or some other correspondence in response.
Please be aware that the waiver applies only to the specific grant under which the waiver request is submitted and not to all open awards. OVW is flexible with the 90-day window for waiver applications.
If needed, a request for an extension must be filed no more than 90 days prior to the close of an award. This has created concerns for administrators when reallocating monies – they need to know prior to this 90-day window whether an extension will be approved.
OVW understands that generally everyone will ask for a 1 year extension of their STOP awards. This is primarily due to the timing of the awards and the varying fiscal years of the states and territories. However, extensions are considered on a case-by-case basis so approval is not totally automatic. OVW needs assurances they are making an informed decision as it relates to the OMB circulars, etc. OVW has indicated that if sufficient information is provided, a first request will most likely always be granted. Extensions become problematic when a state has many award years open at one time.
Administrators should contact their OVW Program Managers as soon as they know they will need an extension. Although they may not accept a formal request prior to the 90-day window, the Program Manager can discuss whether an approval would be viewed favorably once received. This will hopefully provide STOP administrators more confidence in reallocating funds in the later part of the award period.
Review process – OVW has an abbreviated version of the Implementation Planning Toolkit that they use in reviewing for required elements. Each program manager will reach out to a specific state or territory if anything is missing. OVW has 60 days to complete their review and provide feedback. Since the special conditions dictate when Plans are due, OVW has an estimated time frame when they expect to receive and review Plans. If a Plan is submitted beyond the due date, OVW staff may be unable to immediately initiate a review due to other competing demands on their time.
Approval of an Implementation Plan is a 2-GAN process. The OVW Program Manager initiates both GANs but the approval channels differ. First is a programmatic GAN which goes through several levels of approval once the content of the plan is deemed sufficient. The associated release of funds and special condition is a financial GAN – the layers of this are more complex. Administrators should communicate with their program managers if they don’t receive both GANs.
No definitive date has yet been identified for this year’s conference. It will most likely be held the last week in March in Tennessee. This year’s conference will be a dual conference with DV and SA Coalitions. AVA will be involved in the conference planning.
I hope you found this information helpful. If you have any questions or concerns, please don’t hesitate to contact Dorene Whitworth, AVA Coordinator, at email@example.com or 775-721-4691.