AVA/OVW Conference Call – November and December 2013
Hello STOP Administrators!
AVA held their regular monthly conference calls in November and December with OVW to discuss various issues relating to STOP administration and changes involved with the passage of VAWA 2013. Below is a summary of those discussions by topic.
Annual Administrator’s Meeting:
In November AVA had asked OVW to consider identifying a date certain for the annual conference rather than the 4-week window previously provided as this was creating numerous challenges for administrators. Just prior to the December AVA-OVW conference call, the date of February 25-26 was identified as the conference date for 2014. AVA thanked OVW for providing a date certain for the conference so that administrators could work around that date as they continue holding planning meetings, draft their plans and applications, as well as work on their many other deadlines.
FY 2014 Application and Implementation Plan:
AVA inquired into the possibility of moving the due date for the application and implementation plan as this conflicts with the annual conference, other discretionary application due dates, and end-of-the-year reporting? We discussed that the last two applications were due April and May so we were hoping this year’s date could likewise be moved out. OVW explained that they are trying to coordinate due dates, peer reviews, etc. for multiple programs so moving the date would not be possible.
OVW indicated that they would consider extension requests for the application and plans on a case-by-case basis since they recognize attending the conference and other year-end demands may make it difficult to complete everything by the due date. AVA would encourage states and territories to contact their OVW Program Manager if they need additional time to complete their application and statewide plan.
AVA also inquired into the planning process as it relates to having culturally specific representation during the planning process. Some SAAs are finding it awkward to comply with this mandate as it almost creates an environment of tokenism especially in small states where there are no organizations representing the various culturally specific groups. OVW recommends administrators reach out to the Women of Color Network as they might have some suggestions in this area. OVW discussed that the key thing is the outreach being done within the state or territory – at the very least invite them to the table.
This led to the question about how states should document a scenario wherein they’ve invited agencies to the planning table but their invitation was declined. In the case we discussed, the particular organization had indicated they were simply too busy to join in the planning process this year. Others that might be at the planning table, e.g. bilingual advocates, can speak to some challenges but do not necessarily represent a culturally-specific group. OVW suggested a letter from the organization would be sufficient to show they couldn’t participate. Such a letter should include what efforts were made to gain their involvement.
Another question posed to OVW involved what they would like to see to demonstrate the state/territory coordinated with other plans/programs. Michelle Brickley indicated they are still discussing what would be sufficient without overly burdening administrators. OVW is somewhat at a disadvantage in that they don’t know the intent behind this language in VAWA 2013. AVA offered to research where this language originated in order to help interpret the intent.
OVW discussed that this will be the first year SAAs would potentially have access to 100% of their funds immediately upon awards being issued if their plan is deemed sufficient. AVA inquired into the OVW schedule for reviewing plans. Michelle outlined that their internal schedule is that they have until early August to do final approvals. She reiterated that OVW cannot make an award without a plan so states should submit something even if they aren’t certain it will be approved upon initial review. OVW anticipates some back and forth discussions with states during the approval process of the implementation plans. Their ultimate goal is to make awards earlier this year. They’ve also discussed the possibility of issuing awards but only releasing 10% of funding until the plan was approved (similar to what’s been done in past years). The solicitation with guidelines for the plan will be released approximately February 6.
The revised Implementation Planning Toolkit will most likely not be ready prior to the March 30 due date so OVW recommends administrators work from the checklist previously provided.
Gaps to Planning Process – PREA, definitions of healthcare provider, prevention, etc.
Michelle outlined that states have three options relating to PREA – certify compliance, use 5% of funds to bring state into compliance, or turn back 5% of the funds. The tricky part is using 5% to help the state come into compliance. OVW, JJ, and BJA have been in discussions about PREA. AVA asked whether administrators should reference PREA in their plan. Michelle indicated guidance will be provided in the 2014 solicitation; however, most likely states will be given a period of time to provide info on PREA certification after the application deadlines so it won’t need to be covered in the Implementation Plan.
In regards to the definition of “prevention” and how broadly the term “health care provider” will be interpreted, OVW is continuing to work on these. Likewise, they are still discussing the issue of documenting efforts on domestic violence homicide reduction and whether there is an expectation that STOP funds will be spent in this area.
The revised OVW FAQ to account for many of the VAWA 2013 changes is still being drafted. It is OVW’s intent to distribute the FAQs in the very near future; however if they are not release prior to the plan due date, OVW will be more lenient in those areas of the plan to account for further guidance not being provided to STOP Administrators. It is likely that OVW will expect some revisions in some areas during year 2 of the plan period. The OVW attorney advisors continue to meet to discuss these issues further.
AVA asked about the possibility of OVW holding a conference call following the release of the solicitation since more questions may arise. OVW will consider this; however, Michelle feels the previous calls on implementation planning development should provide most information needed.
Expiration of Muskie forms
The current annual reporting forms will expire prior to the next due date of March 30th. OVW has requested an extension of the expiration date on the current forms so grantees can use the existing forms to report activity in calendar year 2013. VAWA 2013 rules will apply to FY 2014 awards so the forms will most likely be revised to accommodate all new information before the end of next year.
The process for extending the expiration date on the current forms involves posting the request to the federal register. The posting allows for a 60 day public comment period – see the link below to access the full language of the extension request. Michelle indicated her unit is not involved in reviewing any feedback received. AVA discussed that they were only concerned about the time identified for administrators and subgrantees to complete the form (60 minutes) as it doesn’t truly represent the burden involved. Michelle discussed that she thought the reference to time burden was a result of the Paperwork Reduction Act. AVA will prepare a comment that discusses a better estimate of the time burden involved in completing these forms. STOP Administrators are encouraged to review the posting and submit comments as they feel appropriate.
Link to Federal Register: http://www.gpo.gov/fdsys/pkg/FR-2013-11-07/html/2013-26745.htm
AVA continues to work with OVW and others to help administrators in their work on the STOP and SASP programs. Please feel free to contact AVA with any issues you would like us to address.