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OCVS Grants Updates Bulletin #15
September 23, 2021
In response to OCVS’ 2018 VOCA Victim Assistance Formula Grant Office of Inspector General (OIG) Audit and recently released guidance from US Department of Justice Office for Victims of Crime (OVC), OCVS has updated our grant policies and procedures and would like to share those updates with our VOCA Subgrantees.
Table of Contents
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OCVS has introduced a new checklist that was in effect for the 2021-2022 VOCA Continuation Application. In response to questions from subgrantees who were unaware of the new form and procedure, OCVS is providing context to the Contractual/Consultant Checklist form below:
Definition of Sub-Awards and Sub-Contracts:
Subawards and contracts are defined in CFR 200 as shown below. For help in determining if an agreement is a subaward or a contract please see CFR 200.331 and the resources provided on the Office of Justice Programs website.
Subaward means an award provided by a pass-through entity to a subrecipient for the
subrecipient to carry out part of a Federal award received by the pass-through entity. It
does not include payments to a contractor or payments to an individual that is a
beneficiary of a Federal program. A subaward may be provided through any form of
legal agreement, including an agreement that the pass-through entity considers a contract.
Contract means a legal instrument by which a non-Federal entity purchases property or
services needed to carry out the project or program under a Federal award.
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OCVS Explanation for Sub-awarding VOCA Funds – Subgrantee Responsibilities:
- Subaward agreements
- Reporting requirements
- Monitoring requirements
- Remedies for non-compliance
OCVS-ConsultantPolicyforGrantRecipients-External-July2021.pdf
OCVS guidance on Subgrantee’s Subaward agreements: Responsibilities and Requirements for Tier Two Monitoring: Subaward-Tier-Two-Monitoring-July2021-WebsiteCopy.pdf
- Implemented Consultant/Contractual Checklist for any sub-contracts
- Verifies either that the federal max consultant/contractual rate was:
- not exceeded OR
- if it was exceeded that
- a competitive process was conducted OR
- there is written justification for a sole source OR
- they are the only provider
- no conflict of interest
- agreement includes the following
- scope of work and services
- date of services
- hourly or daily rate
SAM Exclusions: SAM Exclusions.pdf
The US DOJ Office for Victims of Crime (OVC) recently provided additional guidance regarding System for Award Management (SAM) registration requirements. SAM registration requirements only apply to first-tier subrecipients/subawards (i.e. direct recipients of OCVS federal funds (VOCA, VAWA STOP, and VAWA SASP Subgrantees). Any entity that directly receives federal funds from OCVS must be registered in SAM. The requirement does not pass down to subcontracts or subawards paid by the subrecipient. However, it is required that subcontracts or subawards paid by the subrecipient are not debarred from receiving federal funds. SAM.gov can be used to check if an entity is debarred from receiving federal funds.
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*Required for VOCA Subrecipients only!
The OCVS Grants Team virtual 2021-2022 VOCA Subgrantee Meeting is for all subrecipients of the 2021-2022 VOCA Continuation Grant.
OCVS will provide updates on new or revised VOCA requirements, detail changes to the VOCA guidelines, and ongoing conversation about the impact of the VOCA Fix on Wisconsin VOCA subgrantees.
Attendance is required of the Project Director and Financial Officer for all VOCA subrecipients as indicated in your award documents.
The Virtual 2021-2022 VOCA Subgrantee Meeting will be held on Thursday October 7,2021, 1pm-4pm, via Zoom.
*Feel free to submit a question you would like the OCVS Grants Team to address during or after the meeting. You can type your questions when you register, OR email your questions to me at varnadoela@doj.state.wi.us.
Click the button below to register!
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Safe at Home, Wisconsin’s address confidentiality program, relies on designated Application Assistants to assist applicants with the safety planning they are required to do before enrolling in Safe at Home. In order to increase victims’ access to the Safe at Home program statewide, we are always looking for more people to complete the training necessary to become a dedicated Application Assistant. Application Assistants can be from state or local agencies that provide counseling, assistance, or support services to victims, or can be employees or volunteers for organizations that provide counseling, assistance, or support services free of charge to victims. Training consists of reviewing three pre-recorded videos that total about an hour in length and completing a registration form. Individuals interested in completing training can send an email to safeathome@doj.state.wi.us or call the Safe at Home program at 608-266-6613.
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