FY 2023 BJA Kick-Off Meeting: John R. Justice (JRJ) Formula Grant Program

Transcript also available as PDF.

DARYL FOX: Good afternoon, everyone, and welcome to today's webinar, “FY 2023 BJA Kickoff Meeting for the John R. Justice Formula Grant Program,” hosted by the Bureau of Justice Assistance. At this time, it's my pleasure to introduce Kate Foreman, Division Chief with BJA, to begin the presentation. Kate?

KATE FOREMAN: Thanks, Daryl. Hello and welcome to all of you. This is, as Daryl said, BJA's FY 2023 grantee orientation kickoff webinar. So this is for your FY 2023 awards that you received in October.

So, thank you for taking the time to join us for this important webinar. We're excited to have you with us today. We know we don't do this every year, but it's really great to connect. As Daryl said, I'm Kate Foreman and I'm the Division Chief that oversees the John R. Justice Grant Program. And listed here are the grant management specialists, or grant managers, who serve as subject matter experts for the program and will be your designated grant managers during the project performance period. In a future slide, we will highlight which grant manager is responsible for your state.

Before we continue though, we would like to know a little bit more about you. In the chat, if you could please share your name, organization, and state, that would be great. I'll give you guys a couple of seconds to do that. All right. Looks like we have lots of Midwest folks. I'm seeing Kansas. I'm seeing New Jersey, Maine, California, Colorado. Loving it. Illinois. Thank you, guys, all for joining. So great to connect with some of you guys who I know I've talked to via email. South Carolina, Oklahoma, Minnesota. Great. Welcome, everyone. Thank you so much.

Okay. So, I'm going to go over the agenda. Here are the topics we will be covering today. We will provide you all with an overview of the program and grants management, as well as resources available to you to successfully administer the program. So, without further ado, let's go ahead and get started. I'm going to pass this on to Danielle, who's going to kick off the welcome and introduction and program overview. Danielle.

DARYL FOX: Your line is muted, Danielle.

DANIELLE WHITESTONE: Okay. Thank you, Kate. I appreciate the introduction. First and foremost, congratulations on receiving the FY '23 JRJ Award. If this is your first time administering the program, you may feel a bit overwhelmed with the process, but please know the JRJ team is here to support and assist you with the project implementation and to be good stewards of federal funds.

To fully understand the program, it may be best to start with understanding who we are in the roles of both OJP and BJA.

“What is the Office of Justice Programs,” you ask? Well, the Office of Justice Programs is one of the three grant-making components of the Department of Justice, along with the Office of Violence Against Women, OVW, and the Office on Community Oriented Policing Services, otherwise known as COPS. OJP provides grant funding, training, research, and statistics to the criminal justice community nationwide. The Bureau of Justice Assistance is one of the six program offices under OJP, which are listed on this slide. All right.

So, the U.S. Department of Justice, the Bureau of Justice Assistance was created in 1984 to reduce violent crime, create safer communities, and reform our nation's criminal justice system. BJA strengthens the nation's criminal justice system and helps America's state, local, and tribal jurisdictions reduce and prevent crime, reduce recidivism, and promote a fair and safe criminal justice system. BJA focuses its programmatic and policy efforts on providing a wide range of resources, including training and technical assistance to law enforcement, courts, corrections, treatment, reentry, justice information sharing, and community-based partners to address chronic and emerging criminal justice challenges nationwide. And Karhlton Moore is our director of BJA. All right.

So, BJA supports the criminal justice field in a variety of ways. Of course, directly through our grants and cooperative agreements, but also by educating and providing training, researching, publishing what works, and consulting with and convening stakeholders across the criminal justice spectrum. Now, the fun stuff. All right.
So, in the next section, we're going to provide a brief overview of the program, the meat and potatoes. All right. So, the program was first launched in fiscal year 2010 through the John R. Justice Prosecutors and Defenders Incentive Act. In pursuant to a $10 million appropriation from Congress, BJA determined that partnering with the governors of each state and their designated state agencies to administer the program would increase efficiency among those most familiar with loan repayment programs and those most familiar with the prosecutor and public defender's offices in their jurisdiction. As the title of the act suggests, the program is designed to encourage qualified attorneys to continue in public service for, at least, three years in exchange for partial loan payments.

Poll question time. All right. We're going to take a moment to do a poll question. It might help in understanding how long our attendees have been working with the program. My colleague, Daryl, will be launching a poll now. You should see it. I see you guys are already in progress here, so I'll give you a couple seconds to respond. “How long have you been doing the program?” All right. I think we got enough here. Looks like we have some new folks coming in. We have some reoccurring folks. So we got a good mix here today. So you guys are all in the right place. In either case, today's webinar can serve as a refresher for those who have knowledge of the program and those coming in fresh. So welcome, everyone. All right.

Love the map here. So this map highlights the grant managers who oversee the program for each state. I'm the yellow section. But the map is color-coded to identify the states and their assigned grant manager. So your assigned grant manager is your first point of contact on all your grant inquiries and they are there to support you through the entire grant life cycle of your project. Take a moment to look at the map to identify which area your state falls under. Contact information for each grant manager will be provided in a later slide.

So, the goal of the program is clear. It's to encourage qualified prosecutors and public defenders to remain in public service in exchange for partial loan payments. And the objectives of the program are to retain qualified prosecutors and public defenders who commit to three years of eligible employment in exchange for partial loan repayment. Selection of these applicants will be made to those with the least ability to repay loans, as well as other factors defined by the state administering agencies. States should ensure fair and equitable distribution of funds among qualifying prosecutors and public defenders. All right.

And I will conclude the program overview section by going over required annual deliverables to showcase project activity. First, we have the signed JRJ, or John R. Justice beneficiary service agreements. The First Time Participant Agreement is used when a JRJ applicant has been selected to participate in the program for the first time, thus starting a 36-month term of their agreement, or three years. Acknowledgement of Benefit forms are signed and collected each year thereafter for the next 24 months to acknowledge eligible employment and continuation in the program. Once a beneficiary completes the 36-month term and collection of the First Time Participant Agreement and subsequent acknowledgement forms, an applicant may enter a second term of service if selected to participate in the program again. The secondary term of service covers an additional 12 months of eligible service.

Next, we have the Verification Form, which verifies all beneficiary information to include name, address, amount awarded, date of agreements, et cetera. We'll go over that later. I said we'll go over that more later in the future slides. So lastly, Justice Enterprise File Sharing, or JEFS, this is for exited/repayment forms, which looks very similar to the Verification Form. This will be submitted annually to include only individuals who have exited the program due to a breach in contract and are thus reported in JEFS as having to repay those funds made to the loan institutions on their behalf. All right.

So, post-award management and federal compliance. Let's go over who your BJA people or your programs teams are. All right. Your assigned BJA grant manager can be found in JustGrants and is your primary point of contact. The grant manager is there to provide assistance and to review and approve grants management actions, such as reports and award conditions, which we will discuss in detail later. They can also connect you to resources you may need to help in the management of your award. The grant manager will ensure your project stays compliant with award conditions and administrative requirements you must follow, but is also tasked with supporting you in successfully achieving your project objectives from start to finish. All right.

OJP's Office of the Chief Financial Officer, otherwise known as the OCFO, provides grants financial management support to all OJP and its grantees. As it relates to your award, the OCFO will be involved with extension requests, financial monitoring, financial management training and technical assistance, and, finally, the financial closeout process. OCFO's customer service contact information is listed here on this slide. Right on the bottom under the envelope.

By now, you’re hopefully familiar with the roles in JustGrants that individuals from your agency will fulfill in acceptance and management of your grant. They’re included on this slide since we will be mentioning them often. The entity administrator, who is usually the same person as the SAM electronic business point of contact, will manage roles in JustGrants, such as inviting new members and assigning them to the award. The authorized representative is the person with authority to sign award agreements on behalf of your agency and must complete the award acceptance in the system. The grant award administrator will be the main point of contact for the award and will submit annual performance reports, budget modifications, award modifications, and the closeout. The financial manager will submit the quarterly financial reports. An individual can serve in multiple roles in JustGrants if it is appropriate based on your agency's needs and requirements, with the understanding that you will maintain proper internal controls on all actions. One thing to know on internal controls as the grantee, you have a responsibility to provide adequate oversight to your grant. Formal grants management roles in JustGrants systems should not be given to individuals outside of your organization. And, lastly, it's important that you keep the roles up to date in the system to minimize lapses in communication or access to funds. So if someone is planning on leaving, hopefully not, you should reassign the effective role or roles in advance. Always reach out to your grant manager too.

And another poll question. All right. Just so we can see who's here today. What your roles are in JustGrants?” If you could take a moment to identify who you are and what your roles are.

Thanks, Daryl, for putting that up there. All right.

We got some grant award administrators. We like our acronyms. So GAA is what we often refer to them as. Some financial managers. All right. This is great. All right. So mostly grant award administrators, which is, perfect, because that's the folks we typically reach out to, if there's any programmatic things to talk about. So we're going to move on. Thank you, everyone, for doing that.

So, please know that the program's office is here to assist you in being successful. We cannot reiterate that enough. We welcome your feedback administering the program, either provide it through your annual performance reports and in a simple email. If you have any issues or concerns with program management, reach out. So the more we know, the more we can assist you. Now, I want to hand it off to my colleague, Robyn, who will go over successful management of your program. Oh, give me one second. Thank you, everyone.

ROBYN HARVEY: Thanks, Danielle. Hello and congratulations once again on your award. My name is Robyn Harvey and I'm one of the three grant managers in the BJA programs office for JRJ. I'll begin the grants management content and then I'll pass it over to my colleague, Ashley. In this presentation, we'll give you an overview of the entire post-award grants management lifecycle, and it'll cover things like your award acceptance, how you go about accessing your funds, your award conditions, and your financial requirements.

So, for your award acceptance, when your agency accepts the grant award agreement, it's entering into a legally binding contract with the federal government. Therefore, it's very important that you all read the terms and conditions thoroughly before accepting your award. Your authorized representative is the person in your organization with authority to sign and enter into the grant agreement. The authorized representative will accept the award electronically in JustGrants, and you may have received communication that the award must be accepted within 45 days. If you have not already accepted your award, please make sure you reach out to your grant manager and request that you need additional time to accept the award, and then please also let us know like an estimation of when you expect this to occur. Hopefully, no one is contemplating declining the award agreement, but if that is the case, please make sure you reach out to your grant manager to discuss.

Next, accessing funds. So your funds are in the U.S. Treasury's Automated Standard Application for Payments, and it's normally what we refer to as the ASAP system. However, there may be additional steps after you accept your award before funds will before you'll be able to draw down your funds. So in addition to the award acceptance, your agency must be registered in ASAP in order for the account to be established. I'll cover that within the next slide as well. We'll talk a little bit more about ASAP. But, additionally, there may be withholding award conditions, which will prevent access to funds until certain actions are completed, and we'll go over that a little bit as well, your withholdings. Okay.

And a little more about the ASAP system. So if your agency was already registered in ASAP, you will not have to complete the step again. If your award status says pending active, and it will be located at the top of your grant in JustGrants, after accepting the award, this means you're registered in ASAP and the specific account for the grant has been established. If your agency was not previously enrolled in ASAP within 24 hours after the award is accepted in JustGrants, your entity administrator will receive emails from ASAP system with links and information that will show you how to enroll. If your award has a status of pending ASAP notification sent and the entity administrator did not receive the invitation emails from ASAP or if your links have expired, please make sure you contact OCFO, which is our financial office. They have a customer service desk and you can request that the ASAP invitation emails be resent to you. Their contact information will be located on slide 17. Okay.

And next, we'll discuss the award conditions. As I previously mentioned, the award agreement is a contract and you are responsible for adhering to the award conditions, so it's very important that you read and understand the applicable conditions. So OJP applies 30 award conditions to all grant agreements. These cover various requirements such as your agency's responsibility to adhere to the DOJ Grants Financial Guide and also the uniform requirements found in 2 CFR Part 200 as an example. The link on this slide has details on the legal requirements contained in these award conditions. The award conditions starting at number 31 in your award documents are conditions applied specifically to the JRJ Grant Program and these conditions particular to your award. So one of these award conditions may withhold funds.

And so next, we'll jump into exactly what your withholdings may be. So withholding award conditions prohibit expenditures or draw down of funds until a specified action or document is approved and a grant manager submits an Award Condition Modification, which we refer to as ACM, to remove the associated hold. Withholding conditions may be applied for various reasons. The most common reasons would be if we could not approve or clear your budget prior to the award as the award amount has not been decided, which is what happens with JRJ. So there will be a condition requiring you to revise your budget to the correct award amount. And we'll cover this more in detail in the next slide as well, but, likewise, if your application had a missing or insufficient mandatory document attachment, there may be a hold of funds placed on to your project as well until this is provided. So, for example, all prior awards made by the state under the program have satisfied JRJ's program's requirements, reporting each individual beneficiary of a JRJ Award in the commutative verification form. The verification form, it's in the Excel sheet that we sent to you, providing the supporting service agreements as well. So there may be a whole place, if you have not in prior years provided that information to us.

So, one of the roles of the BJA grant manager is to communicate with you, for any reason, any withholding conditions may be placed on your grant. And then if you have any questions about it, we are able to assist you in addressing them. So as we discussed with budget approval, this slide explains the budget clearance process. So the grant award administrator will be responsible for initiating a Programmatic Cost GAM that would include you attaching a revised budget. It will then go to the assigned grant manager who will review it and either send it back if there are revisions that needs to be made or just approve it. Once approved, the budget will be sent forward for final approval. After the budget is approved in JustGrants and all budget concerns have been addressed, the grant manager will remove the hold associated with it. Please ensure all withholdings that restrict obligations and expenditures are removed before starting activities. It's very important. Okay.

Grant limitations. So the JRJ Program has certain limitations set forth in statute, and the solicitation outlines other restrictions that apply to this program. So for the purposes of the JRJ Grant Program, the following limitations must be followed. So no more than 10 percent of grant funds may be used for administrative costs within your project and also repayment benefits for each beneficiary cannot exceed $10,000 in a calendar year, per 12 months. The total lifetime benefit to each beneficiary cannot exceed $60,000.

And then we'll get into everyone's favorite next, the Grants Financial Management Training. So one of the administrative requirements of the award is the grant award administrator, and as the financial manager assigned to the award, you must complete the Grants Financial Management Training within 120 of accepting your award. If you've not previously completed the training and at this time, it would have to be on or after February 28th, 2021. So for some recipients, the award condition for this requirement will withhold funds until the training is complete. The training can be completed online. It is a self-paced training and, generally, it can be completed within eight hours total, with the ability for you to save progress and return until completed. So that means if you want to span it across a few days, also to work on it as well, you're more than welcome to do that. It will still save your place. So there is a link on this slide for where you can register and complete the training. Please make sure you email the certificate of completion to your BJA grant manager. So if you have a new grant award administrator or financial manager coming on board to be assigned to the role later on, they will also be required to complete the training within a hundred and twenty days of them oncoming onboard. Please note the condition notes training must be completed once again on/or after February 28th, 2021, in order for us to be able to make the award without having to place a hold on your grant. Annually, the grant managers, we check to ensure that you are up to date on your training. And if you're nearing your three-year mark, please make sure you complete your training as soon as possible. Okay.
Other administrative items. So, this presentation is clearly not long enough nor is it intended to cover every possible administrative requirement that may be applicable to your project, so we list a few other requirements on this slide just to include the requirement to report any ways, fraud, and abuse of grant funds if you become aware of it or if your project is funding a website or publication, make sure there is a requirement to include a disclaimer statement which is included in the award conditions. Also, as a reminder, you should thoroughly read your award agreement and the conditions to understand any administrative requirements that may be applicable. Okay.

And next we'll discuss payments. So, as we discussed earlier, you will be making your payment requests in the U.S. Treasury ASAP system. Under this grant program, you are not allowed to draw down all funds in advance. Instead, you are subject to the rule requiring you to minimize federal cash on hand, and this means you should only draw down what is needed for your immediate needs. Any federal funds drawn down but not dispersed or reimbursed within 10 days must be returned to OJP. If you are drawing down on a reimbursement basis, you can do so on a schedule that works for your agency. Please note that the ASAP system suspends all accounts the last three business days of every month, except for in September when it will be suspended five business days in advance to the transition to the next federal fiscal year. Thank you. And now I'll turn this over to my colleague, Ashley.

ASHLEY GARDNER: Thank you very much, Robyn. Now, we're going to discuss the reporting. All grantees are required to submit a quarterly federal financial report and annual performance reports. The due dates rarely change and will always be on the 30th of the month. The FFR and performance report are to be submitted in JustGrants. Please do not try to submit an FFR in ASAP. You are required to submit a report even if there is no activity and no funds have been obligated, expended, or drawn down. Your first FFR was due January 30th and your first annual report for the FY 2023 award will be due October 30th. The annual report must include attachments of accumulative verification form and applicable service agreements. Additionally, on October 30th each year, you should report in the JEFS system any recipients who have exited from qualifying service before completing the service requirements. For 2023, the performance reporting is annual. All JRJ Grants awarded before are still on a biannual reporting with a quarterly report in PMT. All FFR questions should be directed to the OCFO Customer Service. If you have technical questions regarding the annual report submissions in JustGrants, contact the JustGrants Help Desk. If you have programmatic questions, please contact your grant manager. Contact information for the help desk is provided at the end of the presentation.

When submitting the reports, here's some helpful tips. The FFR obligation should match performance activities reported in your corresponding performance report. The FFR should report on funds obligated and/or expended, not drawn-down amounts. The FFR must be submitted for every quarter regardless of whether there were obligations or not. On the FFR, it is important to note that 10e is for expenditures and 10f is for unliquidated obligations. If you have decided on awards but not made payments to the loan providers, that amount should go into 10f because it is not yet an expenditure. The annual report answers performance measure questions specifically written in the solicitation. It should provide the BJA grant managers with an accurate snapshot of the implementation of your grant. All service agreements and JRJ verification forms for the fiscal year should be attached. A report must be submitted even if there's no activity. There will no longer be a reporting in PMT for the 2023 grant. The performance measure questions found in the solicitation are embedded in your progress report. As previously highlighted for this award, you report once a year in October 30th. You must answer the embedded question set even if there's no activity. Remember to attach the cumulative JRJ verification form regardless of awards under the FY 2023 grant and all service agreements for the fiscal year. Do not submit a blank report. If you have questions, please reach out to your grant manager prior to submitting your report. And, finally, when you're submitting your performance report, make sure to complete the question set and hit the Finish tab. Once the question set shows the status resolved completed and you have ensured that your attachments are included, you need to click the Submit button on the Performance Report screen for it to be routed for review and approval.

We have updates for the JRJ Verification Form that will be coming. We made these changes to ensure we are gathering all the information required. We want to discuss the reasoning for some of these changes. We added a column for Service Agreement Type to provide a place for information around the acknowledgement forms for years two and three. You should make a new line for each service agreement or acknowledgement form, even if no new funding is being made, to ensure the service is being verified. We added a column for Loan Repayment Date because we know that repayment does not always occur at the same time as the agreement and want to capture this information. It is allowable to wait until a year of service has passed to make the payment. Just be aware the payment must occur in the performance period. We added a column for Exited Status Explanation that previously could have been included in General Notes section, but it's important and needs to be provided clearly to us. The JEFS Reporting Date column is to ensure that those who have exited service and are obligated to repay are reported. And the Waiver Guidance Date is because you, as the grantee, has the responsibility to provide guidance around requesting a waiver to anyone in exited/repayment status. We will discuss the requirement in greater detail in a moment.

So among other requirements I just discussed, JRJ administering agencies are required to annually submit a complete list of individuals who have had JRJ benefits paid on their behalf but who have left the program prior to fulfilling their service obligation, including a reference to the grant award number from which the JRJ benefits were paid, and also the applicable service agreement to correspond to the exited/repayment JRJ beneficiary entries in your exited/repayment status JRJ Verification Form. A separate form has been created for solely submitting the recipients and exited/repayment status. Please utilize the following naming convention while substituting both the name of your state and the appropriate year. It would be state_year_JRJ-Repayment. You may not have had any recipients of exited and require repayment, but you should, at minimum, have access to the JEFS reporting system to show how you're able to meet the requirement. Each JRJ SAA has to set up a free box.com account and also email your grant award administrator when the account is created. Your grant manager will then facilitate you gaining access to the account and you will receive an email from a noreply.box.com inviting you to a folder where exited recipients can be reported. Be sure to check your junk folder. Contact your grant manager if you do not receive an invitation when it has been sent. I'm now going to turn this over to Kate for a moment to discuss waivers.

KATE FOREMAN: Thanks, Ashley. I'm going to take the ball from you here. All right. So I'm jumping into request to talk about waivers because we have processed them. So I know that this has been interesting. We've had waivers, and prior to me coming into this role, the waivers haven't been processed. And so I know that many of you are aware of that, those of you who have been with the program longer. So we wanted to provide a little bit of context here about the waiver process now that we have had kind of our first round. So consistent with the terms of the JRJ service agreement, JRJ beneficiaries are required to inform their JRJ state administering agency of their separation from a qualified position of employment and the status of their repayment. So it's actually outlined in the last slide.

As JRJ grantees, you are required to report this annually to us in the JEFS system. So you confirm this through the Acknowledgement of Benefits Form you should be collecting each year after the service agreement is signed—that initial service agreement is signed. So we've updated this requirement to make it a annual requirement at the time you are reporting your performance report rather than quarterly as required in years past. So you're reporting because the beneficiary must make a payment in the total amount of JRJ loan repayment benefits that were made on behalf of them to the loan service provider. They essentially have to repay everything you've given them if they don't meet the three-year service requirement. So it's very important that you are emphasizing the commitment beneficiaries are making at the beginning of their participation in this program to mitigate how many exit and/or repayment status.

In 2014, we provided additional guidance that JRJ beneficiaries who have exited the program prior to fulfilling their service agreement may request a waiver of repayment. We have now processed over a hundred waivers. I wanted to provide the categories these waiver requests must fall into in order to even be considered. So please keep in mind any beneficiary may request a waiver but that it's not guaranteed. And if they don't request a waiver, they will be sent to Treasury for collection. So based on statute, waivers are entertained if they are in the benefit of the public interest or it would be against equity and good conscience to recover funds. So those are kind of our two different categories.

And under the first category, the benefit of public interest, based on our review of the waivers that we've received and trying to be as flexible and understanding as possible because we understand that things happen, we kind of determined two buckets under the public interest category that we would entertain waivers for. The first one is capacity similar to eligible position, meaning a combination of time served in an eligible position and a position of public service that benefits the public interest that would equate to the 36 months could be something that could be considered in terms of entertaining that waiver request. So that's the first one.

The second under the benefit of the public interest is the administrative efficiency and substantial fulfillment kind of category. So if a case can be made that payments have been made for service already provided under the contract, which can include credible absence when applicable, and the remaining amount to be covered would likely be less than the amount expended for collection, we could entertain a waiver. So credible absence can include absences because of uniformed service in a recognized branch of the United States military, authorized maternity or paternity leave, FMLA, or due to compensable injury.

So one thing to note here is that if the beneficiary is paid in arrears of service, this would support this justification when needed. So if you are having them sign a service agreement and then you're paying them when you're getting verification at the end of the year but they're still in that eligible position, you're basically paying them for the amount of service rendered because you should be prioritizing them getting a second and third payment during those 36 months. So for that reason, it makes it very easy, and the reason why we're updating the verification form, is it makes it very easy for us to, say, well, it's kind of compensation for time served versus you've paid them and they didn't have to do the service. So you have that flexibility, and my grant managers are happy to sit there and have brainstorming conversations with you about how you're implementing your program. I know some of you are already doing this. And it does make waivers possible to entertain in that case.

The other categories, equity and good conscience, we've looked at, and there's kind of two buckets there. Multiple eligible positions is one of them. So satisfied service agreements are basically determined after considering documentation that demonstrates that the beneficiary remained employed in an otherwise eligible position, so it's basically for those who left the state and went to another state, and they're still in public service. But you can't continue to support them if they left your state. And so it is a waiver and that is the bucket for those folks who are in that position where there's still in eligible position, they're just in another state. And let's go ahead and say they've met the 36-month requirement, now we have the documentation demonstrating that and we can waive the requirement of repayment.

And then the final bucket is involuntary separation without cause. So the separation from a position as both involuntary and without cause related to performance or misconduct. That requires documentation, significant documentation. So we're working on clarifying the waiver process even more. But we wanted to provide you with these categories that we're trying to bucket these requests into because we thought it would be helpful as you're kind of talking to beneficiaries. If a beneficiary left because they could make more in the private sector, that does not meet the requirements even if they had financial burden and they have significant debt. Unfortunately, that does not meet the requirement.

So once again, we want to emphasize how important it is to communicate the commitment. Beneficiaries are making up the time of them signing their service agreement, making sure it's clear that what you're paying is directly loan service provider, not to them. We have received waivers that said that they thought that they were going to get the money to help them pay bills. And thinking about ways to maximize the benefit to ensure they'll stay within their position for at least 36 months. So those are the things that we really want to emphasize and we are happy to have larger conversations during the Q&A and also setting up meetings after, if you have questions about this.

So, this slide is just a reminder of the waiver requests process. So it's a brief reminder of the information you should be providing beneficiaries who have exited prior to meeting their service agreement requirement. So please note to expiate things on our end and mitigate outreach we need to have with you when we receive waiver requests, providing the beneficiary with the grant number or numbers they receive their benefits under and how much they receive is incredibly helpful. So for instance, if a beneficiary receives 10,000 under your 2021 grant, and then another 10,000 under your 2022 grant but are exiting before their 36-month agreement from the start, you should provide that breakout and they should be providing that within their waiver request. So please emphasize that they should note the state they received benefits from in their request. I can't tell you how many times they don't tell us what they state they're from. The award numbers and award amounts they received, they should provide a copy of their signed service agreement and verification forms. So we have the dates we need to make the determination, and provide a sworn statement and the explanation of their waiver request. They can also provide any other relevant documents that they will help--that will make the case. And we're happy to answer, again, any questions on waivers at the end of this presentation. So I'm going to go ahead and hand it back to Ashley to cover the last few slides before we get into Q&A. Ashley?

ASHLEY GARDNER: Thank you very much, Kate. I feel like we just went over a lot of information so we're going to take a little moment and answer another poll question that might help us in understanding how familiar everyone is with reporting in JEFS. You should see the poll option and let's see. We have some people starting it. So if you have not get gained the access to the JEFS system, please reach out to your Grant Manager at this point. That is the first step of being able to report, in my opinion. Okay. I'm seeing it's a bit of a mix of people have reported in the last year and they have reported in the past with a few that are new. And one that said their state was not aware of this requirement. Well, I hope now you are aware of this requirement, and I know we went over a lot of different information around it, the exit repayment, so please reach out to your grant manager if you have any questions or want to have a discussion.

So, now we will move on to Grant Award Modifications, which we often called GAMs. It is submitted if you're requesting a change to your project or budget. As far as JRJ goes, a typical GAMs that we see include changes to the dispersion of funds among public defenders and prosecutors, adjustments to the administrative or indirect cost, and no cost extensions, which we will go over in a moment. That said, if the changes are in support of a project and otherwise allowable, you can submit a GAM for our approval of the changes. Besides the different types of Programmatic GAMs, the Programmatic Costs GAM is used for revising budgets, a chance from one dollar to the award amount. And the Change Scope GAM is a request to change programmatic activities or changes in key personnel. As always, we recommend connecting with your grant manager before submitting any GAMs in JustGrants. You can also submit a project period extension also known as a no-cost extension because doing so does not grant you additional funds, but additional time. You may request a one-time, up to 12 months, project extension if you need more time to complete the project. You would need to provide justification and a revised timeline. OJP will consider additional extension request or requests for longer than 12 months on a case-by-case basis, but they require an exception to our policy and additional justification. 

As noted on the last slide, you should reach out to your grant manager for any questions about submitting a GAM. BJA managers monitor the progress in applying of each grant through communications with grantees who do a report in GAMs, and by completing any in-depth reviews. However, OJP is required to conduct in-depth monitoring on 10 percent of its total grant award each year and uses respecters and other tools to select which award it will monitor. If your grant is selected for in-depth monitoring, you will receive a formal letter with proposed dates and then a list of documents you must submit for review. The review will be completed by the OJP grant managers either remotely or at your location. After the review, OJP will issue a letter with the results to include any issues that must be resolved. On this slide, we list some of the more common issues that are identified during monitoring. Generally speaking, the issues relate to not following award conditions or obligating and extending funds prior to approval such as before the budget has been approved, or it could relate to inadequate accounting, polices, and procedures.

I know this isn't a lot of information but here we are at the last page of the post-award grant life cycle, which is the closeout. The closeout must be completed with 120 days of the project end date. This allows you the ability to complete the final performance report and financial reports as well as the final drawdowns in ASAP. If you complete all project activity prior to the end date and you are done expending funds, you may mark your next available performance and financial reports as final in JustGrants and initiate early closeout. Please understand that all costs must be properly obligated and expended or spent prior to the grant award performance period end date. This means formally documented in your accounting system that funds have been expended. If there are unliquidated obligations prior to the final financial report, then you do not expend those funds. The grant closeout is processed upon completion of the project submission of the final performance and financial reports in drawing down funds in ASAP as needed, and then submission of the closeout in JustGrants. There's a link on the slide to the JustGrants training resource on closeouts.

Now we will go over a few slides that represent valuable resources available to you as you work through the award cycle. This slide showcases JustGrant's training resources as well as JustGrants reference guides to give you a step-by-step instructions for completing actions in JustGrants. I find these to be particularly useful as there are screenshots of each step you can follow and have often shared them with grantees.

The DOJ financial guide is reference in your award acquisition and serves as the primary reference manual to assist OJP, OVW, and the COPS office award recipients with fulfilling their fiduciary responsibility to safeguard grant funds and ensure funds are used for the purposes which they were awarded. It compiles a variety of laws, rules, and regulations that affect the financial and administrative management of your grant. There may be instances where the requirements may differ among these three grant-making components to extend possible. Those differences are spelled out throughout this guide. However, recipients who refer to their award terms and conditions to determine the specific requirements to apply to their award. We have provided references to the underlying laws and regulations as much as possible. This guide should be a starting point for all recipients of DOJ and cooperative agreements in ensuring day-to-day effective management of awards. Feel free to subscribe to one of the newsletters shown on the screen. The funding news provides weekly notice of funding opportunities. You can also connect with BJA through Facebook, X, or YouTube. And also visit the website for more information on funding opportunities, publications, and initiatives. We are in the midst of creating a resource guide for the program that we made it available to you hopefully when we share the slides and recording. I will now turn this back over to Kate. Thank you for the time you have given me.

KATHRYN FOREMAN: Thanks, Ashley. So as we wrap up this presentation, we want to thank you for your participation, and understand that this has been a lot of information in a short period of time, and we don't expect you to remember everything that was discussed, but we hope this has been helpful. Before we get to the Q&A, a few last-minute tips and reminders, so keep your contact information up to date, it's critically important so that we can reach out. Review your work conditions and take immediate action on any outstanding withholding award conditions. If you take one thing away from today, talk to your grant manager. That specifically goes for grant award modifications, please reach out to them before initiating GAM in the system. And please contact your assigned grant manager if you haven't been in contact yet. They're there to support you and really help you understand this if anything was confusing in this presentation. And if you need assistance on how to take action in JustGrants, as Ashley mentioned, check out the training videos on the justicegrants.usdoj.gov/training-resources website. I'll put that in the chat in a second here. It is a great resource. I need to do it to everyone. It is a great resource and you can access a lot of different guides, provide screenshots, as well as videos that walk you through things.

And finally, please remember it's okay to remind us if we've not gotten back to you within a few days after a request. Your grant manager manages more than their portfolio JRJ grantees, and with large portfolios in multiple programs, a reminder email, and your understanding and patience is always appreciated. So please never hesitate to reach out. So as we transition, I'm going to go ahead and transition to Q&A now. I'm not going to transition into the Q&A slide because I'm going to leave Danielle, Robyn, and Ashley's contact information up on the slide so that you all can easily write it down if you don't have it. But again, that is also in JustGrants under your grant awards. So let's go ahead and pivot to questions that we received. Robyn, have we received any questions?

ROBYN HARVEY: Yes, and we've tried to answer most in the chat box. One of the first questions was, “Employment verification reporting, is it on a six-month basis or a yearly basis?” And then also in the chat box, we stated that employment verification is required annually and please make sure you submit it when you submit your performance report.

KATHRYN FOREMAN: Yeah, and I just wanted to add to that really quick. So, one of the things that we are seeing is that this isn't always happening. And so just keep it as a reminder that if I am a beneficiary that applies to you and I sign a service agreement, and you give me one year of funding. So let's say you do give the max and you give me $10,000. I do have the opportunity to come to you next year to get funding again and I should be prioritized. But for whatever reason, maybe I decide I'm going to be eligible for public service loan forgiveness and I don't want any more funds. I still have that 36-month commitment, and you as the state still have to be tracking that I am continuing to be in an eligible position for the full 36 months, even if I don't get that second and third installment of support. So please keep that in mind and you really only have to collect it once, but we are not putting that out wide because if you and your processes think it's easier to do it every six months, we would 100% support that. So there is nothing that stops you from collecting it more often, but you need to be verifying annually so that you have some type of documentation that says why you're not reporting them in JEFS. Hope that makes sense to everyone.

ROBYN HARVEY: There's an additional question on, what is the deadline on that again? I assumed it was talking about the financial management training. But if not, please let me know. But I did add below here that the training must be completed within 120 days of accepting your award, and the date would have been on or after February 28th, 2021. You should have it completed. If not, you will need to complete it. There was an additional question, “What about the death of a beneficiary? There was one many years ago and she never knew the status.” Just contact your grant manager and we should be able to go in and maybe look at the historical documents and try to figure out the status on that to let you know had it been waived or not.

KATHRYN FOREMAN: So, Robyn, just really quick. I want to back up. It's been 120 days, so if you haven't completed the training, you all should do it. So the team is required to go in and double check that, and if not, they will put a hold on your grant. So please make sure you're doing that training. The date that was provided which is essentially three years back from today is because, again, and that was emphasized on the slide, it's every three years. So if you are one of our seasoned JRJ folks, we appreciate you very much, but if you haven't done the training in a while, maybe double check when your certificate is dated because when we're doing the check a hold can be put on your grant if you have not completed the training. And then with regard to the death of a beneficiary, I think I mentioned in the waiver process that we kind of hadn't figured out a formalized process and we finally did. I believe whoever referenced that that was addressed, a waiver is not needed for that. Obviously we would not collect due to a death of a beneficiary. So I just wanted to flag that. If there are issues now that we have formalized process and we will be rolling out more on waivers, please reach out to your grant managers as well as the Division Chief myself to make sure that we are aware so that we can ensure that they're not going to collections and having that issue with that loss. Go ahead, Robyn.

ROBYN HARVEY: Okay. Next question, "Where can we check if our financial training is still valid or not?" You should be able to check on the financial management website, but if you log on and you don't see the information, you can contact your grant manager and we can look it up for you. If you get with me offline, Matt, I can look it up to see what the date may have been for your last training.

KATHRYN FOREMAN: Great. Any others?

ROBYN HARVEY: Any questions?

KATHRYN FOREMAN: So, while we're waiting for any other questions to come in, I just want to sum up some of the changes that happened. So last year was the first year that you had your question sets in JustGrants instead of PMT. This year for '23, is the first year you only have to report once a year. So we are really trying to reduce the burden on you guys to the extent that we can. And we know that all of you, some of you, it takes you a whole year. And so, the twice-a-year reporting just didn't make sense given the nature of this program and what you guys are doing. So, that is why it is one report due October 30th. The change is your verification form and service agreements are uploaded to that performance report. So I just want to really quick reemphasize that this is because before we were requesting them, it wasn't a formalized process. We understand that those of you who have holds on your '23, because you still have an active '22, you will not be allowed to start activities on your '23 until you're done making awards on your '22. We understand that. You still have to provide performance updates. And just for systematic and streamlined effectiveness, we understand there's a comprehensive JRJ verification form, you're still going to upload it with the supporting documents that you have for that year, even if you're not doing any activity. So I just want to be really clear, it's going to feel duplicative, but you have all the documents.

So you're uploading them to your '22 and you're providing a performance report that does say you did activity in '23, you're saying you haven't started activity, but you're still uploading that report, it just creates kind of streamlined process. It mitigates us having to respond and say, "Hey, where's your '22 funds?" All of those things. It's just streamlined. So that is what we're doing moving forward. You'll always upload whatever—it's a historical document, it reflects everyone. And so you'll upload that every year.

In addition, it's because let's say I was a beneficiary and I received funds back in 2018, but then I had life circumstances and I stopped and I stopped receiving funds, but I met the three-year requirement, but I stopped receiving funds, I have a benefit of up to $60,000 for my life. And there's nothing that says I have to be a new prosecutor. So let's say I go back into eligible role, I could come back and apply to you, you still are required to track what you've paid me before and you can have me sign a secondary service agreement and I can commit to another 12 months and another 12 months. Or you can have me as the state, you can say, “well you have to commit to another 36,” great. But as long as my lifetime benefit of $60,000 hasn't expired, I could come back to you, which is why we have to have the comprehensive JRJ verification form. So hopefully that makes sense.

ROBYN HARVEY: I think, Ashley, I have a question.

KATHRYN FOREMAN: Yeah. It looks, "How often do we need to complete the financial management training?" Every three years. Every three years. Any other questions? Okay. Once again, this is a ton of information. We really appreciate you guys taking the time and listening. We have tried to streamline. You used to have to report more on just, you're only reporting once. So we're really trying to make sure that it's very easy for you to track what is required and when. But if you have any follow-up questions, please reach out to your grant manager. They are here to support you. And hopefully it will reduce burden. Like I said, we are still working on additional updates. We are going to be updating websites, updating contact information. Your grant manager should have been reaching out on kind of generic contact information so that we can have it on the website, so that when folks are reaching out to us saying, "I want JRJ funds. Where should they go without us giving your individual information unless that's what you want?" So we really are trying to overhaul the program and we want to work with you. So if you have ideas, if you have thoughts, if you have concerns, please reach out your grant manager or please reach out to me directly. And my email is [email protected]. So [email protected].

Megan, thank you. I'm so glad. It's great to connect with all of you. We're going to try and do this more on a regular basis and we really appreciate you. I know there's been a lot of change with JRJ lately, so we appreciate all of you very much. And hopefully this will create some streamlined processes for you moving forward. Okay. Megan, I don't understand the consider allowing payments to beneficiaries with payment verification. We might need to talk to you offline on what you mean, but I'm definitely open to ideas and thoughts. Oh, I don't know. Daryl, can we unmute Megan?

DARYL FOX: If you'd like me to.

KATHRYN FOREMAN: Yes. Can you unmute Megan?

DARYL FOX: Megan, you should be unmuted.

MEGAN: Yeah. I was just thinking that we run a number of other loan repayment programs at the state level. And we have a process where we pay the beneficiaries themselves and then there's a payment verification process afterwards. And it's just way more less complicated. And we don't deal with refunds coming back and forth. We paid one of the 8,000 addresses for the U.S. Department of Education and various servicers. And I've tried to pay the same one for the last two years. And it just keeps coming back and it takes them like a year to send it back to us. So we've closed grants and now we've got refunds and we're trying to repay them. And it's on our other programs or state level programs, it's just much more simple and more less complicated for the administration and even for the beneficiaries themselves. And they're just trying to sit there and wait to see if the money shows up and then they—it's really hard for them to track it. So when you're thinking about future changes to administration, that's one suggestion I'd have.

KATHRYN FOREMAN: And I appreciate that. I think one of the barriers that we have is that it has to be to the loan service provider, it's written in statute. And it's also the three-year service commitment. So I know that collection of funds and the waiver process, that's kind of a barrier, but that's just something unfortunately that is statutorily-required, so. But I've been trying to put my thinking cap on on how best to streamline these processes. How can we make the waiver process easier? How can we reduce the burden on you all? I do know a lot state funding as well but different, but some of these requirements are due to the statutory language. But thank you, Megan, for that. I appreciate it. So making payments, the student loan servicers is very difficult. Okay.

The increase. I have no idea if we're going to continue to see an increase. We wonder if we're going to continue to work after March 8th right now, so. I do not know. It has been nice. We have seen increases the past couple of years. We are operating on the assumption that we'll at least get what we got last year for '24, but we do not know at this time. So it's dependent on Congress and what they choose to appropriate for JRJ. So, Dennis, I appreciate you flagging that. So one of the things we are trying to track and we have been following up when states provide the declination letter when we release our opportunity every year is that we do recognize that it's a small pot of money. Most of you forego admin, because it's such a small pot of money and you want to support your prosecutors and defenders in your state. And that the juice isn't worth the squeeze. That's what we're hearing more and more. So we are trying to simplify to the extent that we can on our end. But again, if you have thoughts, ideas, it is great that Congress continues to increase the amount. I have no crystal ball on that, but we are trying to figure out additional flexibilities. So again, my door, my email is always open, so [email protected].

I have asked about this program going to federal student aid. It is definitely appropriate to DOJ. So I understand that it does not completely fit with the rest of the programs we administer, but we love this program and we want to see you guys succeed and be successful. So any help we can provide, and again, I'm happy to jump on the phone with any of you. Okay. I have no idea how I'm going to try and figure this out, but the paying to the servicers, if any of you that are listening and you have figured out streamlined processes, I'm thinking about some of my more seasoned folks maybe in the northeast, please let me know if there are tricks. There's something else we want to do. We want to disseminate best practices. So I think that this is where we all can learn better if we feed off of each other and look at each other's applications. And, it's "rise all ships," so to speak. So if you have thoughts, if you want to share stuff, please tell your grant manager. We definitely want to make that we are helping you disseminate things that you have figured out that work in this program or that mitigate the time and the administration that is required for this grant. There are no tricks. Mark, I appreciate. I've had many conversations with you, I know. All right. Well, I will definitely take…

ASHLEY GARDNER: [INDISTINCT]

KATHRYN FOREMAN: Yup.

ROBYN HARVEY: There was a suggestion. Susan asked, "Could each applicant provide the name and payment address of their lender?"

KATHRYN FOREMAN: That is a good question.

ASHLEY GARDNER: New question, "Couldn't they request additional information if they needed it from any of the recipients, awarding receipt?”

KATHRYN FOREMAN: Yeah. So we don't regulate that. The only thing I would flag and the only thing that pops into my brain is you need to follow your state rules and be careful about PII. And how you collect it. That's why we collect the Social Security number through the just system. So my team actually will never see your beneficiary's Social Security numbers. That being said, you're already collecting that information, so you're already collecting PII. I don't see how that would be a problem. We don't dictate how you do that. So that's a good suggestion, Susan. Oh, there you go. Elizabeth Swann says, "Yeah, they ask for it." So this is what I mean you guys—share your documents. We want you guys to work together. We definitely want that to be possible. Okay.

So, beneficiaries, lenders change constantly as services get out of the student loan business. That has been happening. I do know also that some of the other struggles you guys have had is with the deferment of payment of student loans and then with public service loan forgiveness. So there's definitely a lot of stuff out there. With public service loan forgiveness, that's something else that you guys should probably be inquiring. “How long have they been in their role?” “Are they planning on doing public service loan forgiveness?” Because I know some of you have already dealt with this. The beneficiary gets loan forgiveness and the payment you made gets paid back to the beneficiary. And then you need to recollect it. And if that grant is closed, you need to return it to us. If it's still open, you can repopulate it into your grant to reuse again. But I do know that public service loan forgiveness does create another hiccup for you all as well. So I do know that they've consolidated and a lot of the loans are now through FSA but I know that that's not all loans that are eligible.

So also open to us having more of, a town hall where we are all unmuted and we can have kind of a conversation of ideas and sharing. So that's something the team will think about rolling out if that's something you guys are interested in. Okay.

Well, thank you. Again, if you want to share your information, please tell your grant managers and we'll figure out a way to help do that. And we'll think about ways to connect more in the future. But we are going to probably do this annually at least. So grant managers, do you guys have anything else to add? Robyn, Danielle, Ashley?

ASHLEY GARDNER: No.

ROBYN HARVEY: Thanks for that.

DANIELLE WHITESTONE: No. I appreciate everyone coming out today, especially West Coast. Everybody is on different time zones, so, thank you.

KATHRYN FOREMAN: Yeah. We got rid of the PMTs, but it's little baby steps. Less reporting, we're trying, guys. All right. Well, thank you. Everyone have a lovely day. We appreciate you. And reach out to your grant manager. They're here to help. All right. Thank you.

DARYL FOX: So, on behalf of the Bureau of Justice Assistance and our panelists, thank you for joining. This will end today's presentation.