HomeMy WebLinkAbout10-16-17 City Commission Packet Materials - C2. VETS Court Grant Award83
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U.S. Department of Justice
Office of Justice Programs
Washington, D.C. 20531Office of the Assistant Attorney General
September 23, 2017
Mr. Dennis Taylor
City of Bozeman
P.O. Box 1230
Bozeman, MT 59771-1230
Dear Mr. Taylor:
On behalf of Attorney General Jefferson Sessions III, it is my pleasure to inform you that the Office of Justice Programs has
approved your application for funding under the FY 17 Adult Drug Court Discretionary Grant Program: Implementation in the
amount of $400,000 for City of Bozeman.
Enclosed you will find the Grant Award and Special Conditions documents. This award is subject to all administrative and
financial requirements, including the timely submission of all financial and programmatic reports, resolution of all interim
audit findings, and the maintenance of a minimum level of cash-on-hand. Should you not adhere to these requirements, you
will be in violation of the terms of this agreement and the award will be subject to termination for cause or other administrative
action as appropriate.
If you have questions regarding this award, please contact:
- Program Questions, Kerri Vitalo-Logan, Program Manager at (202) 353-9074; and
- Financial Questions, the Office of the Chief Financial Officer, Customer Service Center (CSC) at
(800) 458-0786, or you may contact the CSC at ask.ocfo@usdoj.gov.
Congratulations, and we look forward to working with you.
Sincerely,
Enclosures
Alan R. Hanson
Acting Assistant Attorney General
106
U.S. Department of Justice
Office of Justice Programs
OFFICE FOR CIVIL RIGHTS
810 7th Street, NW
Washington, DC 20531
Tel: (202) 307-0690
TTY: (202) 307-2027
E-mail: askOCR@usdoj.gov
Website: www.ojp.usdoj.gov/ocr
September 23, 2017
Mr. Dennis Taylor
City of Bozeman
P.O. Box 1230
Bozeman, MT 59771-1230
Congratulations on your recent award. In establishing financial assistance programs, Congress linked the receipt of federal funding to
compliance with federal civil rights laws. The Office for Civil Rights (OCR), Office of Justice Programs (OJP), U.S. Department of Justice
(DOJ) is responsible for ensuring that recipients of financial assistance from the OJP, the Office of Community Oriented Policing Services
(COPS), and the Office on Violence Against Women (OVW) comply with the applicable federal civil rights laws. We at the OCR are
available to help you and your organization meet the civil rights requirements that come with DOJ funding.
Ensuring Access to Federally Assisted Programs
Federal laws that apply to recipients of financial assistance from the DOJ prohibit discrimination on the basis of race, color, national origin,
religion, sex, or disability in funded programs or activities, not only in employment but also in the delivery of services or benefits. A federal
law also prohibits recipients from discriminating on the basis of age in the delivery of services or benefits.
In March of 2013, President Obama signed the Violence Against Women Reauthorization Act of 2013. The statute amends the Violence
Against Women Act of 1994 (VAWA) by including a nondiscrimination grant condition that prohibits discrimination based on actual or
perceived race, color, national origin, religion, sex, disability, sexual orientation, or gender identity. The new nondiscrimination grant
condition applies to certain programs funded after October 1, 2013. The OCR and the OVW have developed answers to some frequently
asked questions about this provision to assist recipients of VAWA funds to understand their obligations. The Frequently Asked Questions
are available at http://ojp.gov/about/ocr/vawafaqs.htm.
Enforcing Civil Rights Laws
All recipients of federal financial assistance, regardless of the particular funding source, the amount of the grant award, or the number of
employees in the workforce, are subject to prohibitions against unlawful discrimination. Accordingly, the OCR investigates recipients that
are the subject of discrimination complaints from both individuals and groups. In addition, based on regulatory criteria, the OCR selects a
number of recipients each year for compliance reviews, audits that require recipients to submit data showing that they are providing services
equitably to all segments of their service population and that their employment practices meet equal opportunity standards.
Dear Mr. Taylor:
107
Providing Services to Limited English Proficiency (LEP) Individuals
In accordance with DOJ guidance pertaining to Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, recipients of federal financial
assistance must take reasonable steps to provide meaningful access to their programs and activities for persons with limited English
proficiency (LEP). See U.S. Department of Justice, Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition
Against National Origin Discrimination Affecting Limited English Proficient Persons, 67 Fed. Reg. 41,455 (2002). For more information
on the civil rights responsibilities that recipients have in providing language services to LEP individuals, please see the website
http://www.lep.gov.
Ensuring Equal Treatment for Faith-Based Organizations
The DOJ regulation, Equal Treatment for Faith-Based Organizations, 28 C.F.R. pt. 38, requires State Administering Agencies (SAAs) to
treat faith-based organizations the same as any other applicant or recipient. The regulation prohibits SAAs from making awards or grant
administration decisions on the basis of an organization's religious character or affiliation, religious name, or the religious composition of its
board of directors.
The regulation also prohibits faith-based organizations from using financial assistance from the DOJ to fund inherently (or explicitly)
religious activities. While faith-based organizations can engage in non-funded inherently religious activities, they must hold them
separately from the program funded by the DOJ, and recipients cannot compel beneficiaries to participate in them. The Equal Treatment
Regulation also makes clear that organizations participating in programs funded by the DOJ are not permitted to discriminate in the
provision of services on the basis of a beneficiary's religion. For more information on the regulation, please see the OCR's website at
http://www.ojp.usdoj.gov/about/ocr/equal_fbo.htm.
SAAs and faith-based organizations should also note that the Omnibus Crime Control and Safe Streets Act (Safe Streets Act) of 1968, as
amended, 42 U.S.C. § 3789d(c); the Victims of Crime Act of 1984, as amended, 42 U.S.C. § 10604(e); the Juvenile Justice and Delinquency
Prevention Act of 1974, as amended, 42 U.S.C. § 5672(b); and VAWA, Pub. L. No. 113-4, sec. 3(b)(4), 127 Stat. 54, 61-62 (to be codified
at 42 U.S.C. § 13925(b)(13)) contain prohibitions against discrimination on the basis of religion in employment. Despite these
nondiscrimination provisions, the DOJ has concluded that it may construe the Religious Freedom Restoration Act (RFRA) on a case-by-
case basis to permit some faith-based organizations to receive DOJ funds while taking into account religion when hiring staff, even if the
statute that authorizes the funding program generally forbids recipients from considering religion in employment decisions.
Please consult with the OCR if you have any questions about the regulation or the application of RFRA to the statutes that prohibit
discrimination in employment.
Using Arrest and Conviction Records in Making Employment Decisions
The OCR issued an advisory document for recipients on the proper use of arrest and conviction records in making hiring decisions. See
Advisory for Recipients of Financial Assistance from the U.S. Department of Justice on the U.S. Equal Employment Opportunity
Commission's Enforcement Guidance: Consideration of Arrest and Conviction Records in Employment Decisions Under Title VII of the
Civil Rights Act of 1964 (June 2013), available at http://www.ojp.usdoj.gov//about/ocr/pdfs/UseofConviction_Advisory.pdf. Recipients
should be mindful that the misuse of arrest or conviction records to screen either applicants for employment or employees for retention or
promotion may have a disparate impact based on race or national origin, resulting in unlawful employment discrimination. In light of the
Advisory, recipients should consult local counsel in reviewing their employment practices. If warranted, recipients should also incorporate
an analysis of the use of arrest and conviction records in their Equal Employment Opportunity Plans (EEOPs) (see below).
Complying with the Safe Streets Act
An organization that is a recipient of financial assistance subject to the nondiscrimination provisions of the Safe Streets Act, must meet two
obligations: (1) complying with the federal regulation pertaining to the development of an EEOP (see 28 C.F.R. pt. 42, subpt. E) and (2)
submitting to the OCR findings of discrimination (see 28 C.F.R. §§ 42.204(c), .205(c)(5)).
108
Sincerely,
Meeting the EEOP Requirement
If your organization has less than fifty employees or receives an award of less than $25,000 or is a nonprofit organization, a medical
institution, an educational institution, or an Indian tribe, then it is exempt from the EEOP requirement. To claim the exemption, your
organization must complete and submit Section A of the Certification Form, which is available online at
http://www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf.
If your organization is a government agency or private business and receives an award of $25,000 or more, but less than $500,000, and has
fifty or more employees (counting both full- and part-time employees but excluding political appointees), then it has to prepare a
Utilization Report (formerly called an EEOP Short Form), but it does not have to submit the report to the OCR for review. Instead, your
organization has to maintain the Utilization Report on file and make it available for review on request. In addition, your organization has to
complete Section B of the Certification Form and return it to the OCR. The Certification Form is available at
http://www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf.
If your organization is a government agency or private business and has received an award for $500,000 or more and has fifty or more
employees (counting both full- and part-time employees but excluding political appointees), then it has to prepare a Utilization Report
(formerly called an EEOP Short Form) and submit it to the OCR for review within sixty days from the date of this letter. For assistance in
developing a Utilization Report, please consult the OCR's website at http://www.ojp.usdoj.gov/about/ocr/eeop.htm. In addition, your
organization has to complete Section C of the Certification Form and return it to the OCR. The Certification Form is available at
http://www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf.
To comply with the EEOP requirements, you may request technical assistance from an EEOP specialist at the OCR by telephone at (202)
307-0690, by TTY at (202) 307-2027, or by e-mail at EEOsubmisson@usdoj.gov.
Meeting the Requirement to Submit Findings of Discrimination
If in the three years prior to the date of the grant award, your organization has received an adverse finding of discrimination based on race,
color, national origin, religion, or sex, after a due-process hearing, from a state or federal court or from a state or federal administrative
agency, your organization must send a copy of the finding to the OCR.
Ensuring the Compliance of Subrecipients
SAAs must have standard assurances to notify subrecipients of their civil rights obligations, written procedures to address discrimination
complaints filed against subrecipients, methods to monitor subrecipients' compliance with civil rights requirements, and a program to train
subrecipients on applicable civil rights laws. In addition, SAAs must submit to the OCR every three years written Methods of
Administration (MOA) that summarize the policies and procedures that they have implemented to ensure the civil rights compliance of
subrecipients. For more information on the MOA requirement, see http://www.ojp.usdoj.gov/funding/other_requirements.htm.
If the OCR can assist you in any way in fulfilling your organization's civil rights responsibilities as a recipient of federal financial
assistance, please contact us.
Michael L. Alston
Director
cc:Grant Manager
Financial Analyst
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Grant
PAGE 1 OF
U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
1. RECIPIENT NAME AND ADDRESS (Including Zip Code)
City of Bozeman
P.O. Box 1230
Bozeman, MT 59771-1230
8. SUPPLEMENT NUMBER
00
9. PREVIOUS AWARD AMOUNT
10. AMOUNT OF THIS AWARD
$ 0
$ 400,000
11. TOTAL AWARD $ 400,000
2a. GRANTEE IRS/VENDOR NO.
816001238
2b. GRANTEE DUNS NO.
083705293
3. PROJECT TITLE
Bozeman Veterans Treatment Court
12. SPECIAL CONDITIONS
THE ABOVE GRANT PROJECT IS APPROVED SUBJECT TO SUCH CONDITIONS OR LIMITATIONS AS ARE SET FORTH
ON THE ATTACHED PAGE(S).
13. STATUTORY AUTHORITY FOR GRANT
This project is supported under FY17(BJA - Veterans Treatment Courts) Pub. L. No. 115-31, 131 Stat 135, 205
14 . CATALOG OF DOMESTIC FEDERAL ASSISTANCE (CFDA Number)
16.585 - Drug Court Discretionary Grant Program
15. METHOD OF PAYMENT
GPRS
AGENCY APPROVAL
16. TYPED NAME AND TITLE OF APPROVING OFFICIAL
GRANTEE ACCEPTANCE
Alan R. Hanson
Acting Assistant Attorney General
AGENCY USE ONLY
20. ACCOUNTING CLASSIFICATION CODES 21.
FISCAL
YEAR
FUND
CODE
BUD.
ACT.OFC.
DIV.
REG.SUB.POMS AMOUNT
VCBX 80 00 00 400000
SVCUGT0183
18. TYPED NAME AND TITLE OF AUTHORIZED GRANTEE OFFICIAL
Dennis Taylor
Interim City Manager
4. AWARD NUMBER:2017-VV-BX-0006
5. PROJECT PERIOD: FROM
BUDGET PERIOD: FROM
6. AWARD DATE 7. ACTION
Initial
09/23/2017
TO
TO
10/01/2017
10/01/2017
09/30/2020
09/30/2020
OJP FORM 4000/2 (REV. 5-87) PREVIOUS EDITIONS ARE OBSOLETE.
OJP FORM 4000/2 (REV. 4-88)
19. SIGNATURE OF AUTHORIZED RECIPIENT OFFICIAL 19A. DATE17. SIGNATURE OF APPROVING OFFICIAL
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U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
Requirements of the award; remedies for non-compliance or for materially false statements
The conditions of this award are material requirements of the award. Compliance with any certifications or assurances
submitted by or on behalf of the recipient that relate to conduct during the period of performance also is a material
requirement of this award.
Failure to comply with any one or more of these award requirements -- whether a condition set out in full below, a
condition incorporated by reference below, or a certification or assurance related to conduct during the award period --
may result in the Office of Justice Programs ("OJP") taking appropriate action with respect to the recipient and the
award. Among other things, the OJP may withhold award funds, disallow costs, or suspend or terminate the award.
The Department of Justice ("DOJ"), including OJP, also may take other legal action as appropriate.
Any materially false, fictitious, or fraudulent statement to the federal government related to this award (or concealment
or omission of a material fact) may be the subject of criminal prosecution (including under 18 U.S.C. 1001 and/or 1621,
and/or 42 U.S.C. 3795a), and also may lead to imposition of civil penalties and administrative remedies for false claims
or otherwise (including under 31 U.S.C. 3729-3730 and 3801-3812).
Should any provision of a requirement of this award be held to be invalid or unenforceable by its terms, that provision
shall first be applied with a limited construction so as to give it the maximum effect permitted by law. Should it be
held, instead, that the provision is utterly invalid or -unenforceable, such provision shall be deemed severable from this
award.
Applicability of Part 200 Uniform Requirements
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements in 2 C.F.R. Part 200, as adopted
and supplemented by DOJ in 2 C.F.R. Part 2800 (together, the "Part 200 Uniform Requirements") apply to this FY
2017 award from OJP.
The Part 200 Uniform Requirements were first adopted by DOJ on December 26, 2014. If this FY 2017 award
supplements funds previously awarded by OJP under the same award number (e.g., funds awarded during or before
December 2014), the Part 200 Uniform Requirements apply with respect to all funds under that award number
(regardless of the award date, and regardless of whether derived from the initial award or a supplemental award) that
are obligated on or after the acceptance date of this FY 2017 award.
For more information and resources on the Part 200 Uniform Requirements as they relate to OJP awards and subawards
("subgrants"), see the OJP website at https://ojp.gov/funding/Part200UniformRequirements.htm.
In the event that an award-related question arises from documents or other materials prepared or distributed by OJP
that may appear to conflict with, or differ in some way from, the provisions of the Part 200 Uniform Requirements, the
recipient is to contact OJP promptly for clarification.
Compliance with DOJ Grants Financial Guide
The recipient agrees to comply with the DOJ Grants Financial Guide as posted on the OJP website (currently, the "2015
DOJ Grants Financial Guide" available at https://ojp.gov/financialguide/DOJ/index.htm), including any updated version
that may be posted during the period of performance.
1.
2.
3.
OJP FORM 4000/2 (REV. 4-88)
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U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
Required training for Point of Contact and all Financial Points of Contact
Both the Point of Contact (POC) and all Financial Points of Contact (FPOCs) for this award must have successfully
completed an "OJP financial management and grant administration training" by 120 days after the date of the
recipient's acceptance of the award. Successful completion of such a training on or after January 1, 2015, will satisfy
this condition.
In the event that either the POC or an FPOC for this award changes during the period of performance, the new POC or
FPOC must have successfully completed an "OJP financial management and grant administration training" by 120
calendar days after-- (1) the date of OJP's approval of the "Change Grantee Contact" GAN (in the case of a new
POC), or (2) the date the POC enters information on the new FPOC in GMS (in the case of a new FPOC). Successful
completion of such a training on or after January 1, 2015, will satisfy this condition.
A list of OJP trainings that OJP will consider "OJP financial management and grant administration training" for
purposes of this condition is available at https://www.ojp.gov/training/fmts.htm. All trainings that satisfy this condition
include a session on grant fraud prevention and detection.
The recipient should anticipate that OJP will immediately withhold ("freeze") award funds if the recipient fails to
comply with this condition. The recipient's failure to comply also may lead OJP to impose additional appropriate
conditions on this award.
Requirements related to "de minimis" indirect cost rate
A recipient that is eligible under the Part 200 Uniform Requirements and other applicable law to use the "de minimis"
indirect cost rate described in 2 C.F.R. 200.414(f), and that elects to use the "de minimis" indirect cost rate, must advise
OJP in writing of both its eligibility and its election, and must comply with all associated requirements in the Part 200
Uniform Requirements. The "de minimis" rate may be applied only to modified total direct costs (MTDC) as defined
by the Part 200 Uniform Requirements.
Requirement to report potentially duplicative funding
If the recipient currently has other active awards of federal funds, or if the recipient receives any other award of federal
funds during the period of performance for this award, the recipient promptly must determine whether funds from any
of those other federal awards have been, are being, or are to be used (in whole or in part) for one or more of the
identical cost items for which funds are provided under this award. If so, the recipient must promptly notify the DOJ
awarding agency (OJP or OVW, as appropriate) in writing of the potential duplication, and, if so requested by the DOJ
awarding agency, must seek a budget-modification or change-of-project-scope grant adjustment notice (GAN) to
eliminate any inappropriate duplication of funding.
4.
5.
6.
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PAGE 4 OF
U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
Requirements related to System for Award Management and Universal Identifier Requirements
The recipient must comply with applicable requirements regarding the System for Award Management (SAM),
currently accessible at https://www.sam.gov/. This includes applicable requirements regarding registration with SAM,
as well as maintaining the currency of information in SAM.
The recipient also must comply with applicable restrictions on subawards ("subgrants") to first-tier subrecipients
(first-tier "subgrantees"), including restrictions on subawards to entities that do not acquire and provide (to the
recipient) the unique entity identifier required for SAM registration.
The details of the recipient's obligations related to SAM and to unique entity identifiers are posted on the OJP web site
at https://ojp.gov/funding/Explore/SAM.htm (Award condition: System for Award Management (SAM) and Universal
Identifier Requirements), and are incorporated by reference here.
This condition does not apply to an award to an individual who received the award as a natural person (i.e., unrelated to
any business or non-profit organization that he or she may own or operate in his or her name).
All subawards ("subgrants") must have specific federal authorization
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements for
authorization of any subaward. This condition applies to agreements that -- for purposes of federal grants
administrative requirements -- OJP considers a "subaward" (and therefore does not consider a procurement
"contract").
The details of the requirement for authorization of any subaward are posted on the OJP web site at
https://ojp.gov/funding/Explore/SubawardAuthorization.htm (Award condition: All subawards ("subgrants") must have
specific federal authorization), and are incorporated by reference here.
Specific post-award approval required to use a noncompetitive approach in any procurement contract that would
exceed $150,000
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements to obtain
specific advance approval to use a noncompetitive approach in any procurement contract that would exceed the
Simplified Acquisition Threshold (currently, $150,000). This condition applies to agreements that -- for purposes of
federal grants administrative requirements -- OJP considers a procurement "contract" (and therefore does not consider
a subaward).
The details of the requirement for advance approval to use a noncompetitive approach in a procurement contract under
an OJP award are posted on the OJP web site at https://ojp.gov/funding/Explore/NoncompetitiveProcurement.htm
(Award condition: Specific post-award approval required to use a noncompetitive approach in a procurement contract
(if contract would exceed $150,000)), and are incorporated by reference here.
7.
8.
9.
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U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
Requirements pertaining to prohibited conduct related to trafficking in persons (including reporting requirements and
OJP authority to terminate award)
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements (including
requirements to report allegations) pertaining to prohibited conduct related to the trafficking of persons, whether on the
part of recipients, subrecipients ("subgrantees"), or individuals defined (for purposes of this condition) as "employees"
of the recipient or of any subrecipient.
The details of the recipient's obligations related to prohibited conduct related to trafficking in persons are posted on the
OJP web site at https://ojp.gov/funding/Explore/ProhibitedConduct-Trafficking.htm (Award condition: Prohibited
conduct by recipients and subrecipients related to trafficking in persons (including reporting requirements and OJP
authority to terminate award)), and are incorporated by reference here.
Compliance with applicable rules regarding approval, planning, and reporting of conferences, meetings, trainings, and
other events
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable laws, regulations,
policies, and official DOJ guidance (including specific cost limits, prior approval and reporting requirements, where
applicable) governing the use of federal funds for expenses related to conferences (as that term is defined by DOJ),
including the provision of food and/or beverages at such conferences, and costs of attendance at such conferences.
Information on the pertinent DOJ definition of conferences and the rules applicable to this award appears in the DOJ
Grants Financial Guide (currently, as section 3.10 of "Postaward Requirements" in the "2015 DOJ Grants Financial
Guide").
Requirement for data on performance and effectiveness under the award
The recipient must collect and maintain data that measure the performance and effectiveness of work under this award.
The data must be provided to OJP in the manner (including within the timeframes) specified by OJP in the program
solicitation or other applicable written guidance. Data collection supports compliance with the Government
Performance and Results Act (GPRA) and the GPRA Modernization Act of 2010, and other applicable laws.
OJP Training Guiding Principles
Any training or training materials that the recipient -- or any subrecipient ("subgrantee") at any tier -- develops or
delivers with OJP award funds must adhere to the OJP Training Guiding Principles for Grantees and Subgrantees,
available at https://ojp.gov/funding/ojptrainingguidingprinciples.htm.
Effect of failure to address audit issues
The recipient understands and agrees that the DOJ awarding agency (OJP or OVW, as appropriate) may withhold
award funds, or may impose other related requirements, if (as determined by the DOJ awarding agency) the recipient
does not satisfactorily and promptly address outstanding issues from audits required by the Part 200 Uniform
Requirements (or by the terms of this award), or other outstanding issues that arise in connection with audits,
investigations, or reviews of DOJ awards.
Potential imposition of additional requirements
The recipient agrees to comply with any additional requirements that may be imposed by the DOJ awarding agency
(OJP or OVW, as appropriate) during the period of performance for this award, if the recipient is designated as "high-
risk" for purposes of the DOJ high-risk grantee list.
10.
11.
12.
13.
14.
15.
OJP FORM 4000/2 (REV. 4-88)
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U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 42
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28
C.F.R. Part 42, specifically including any applicable requirements in Subpart E of 28 C.F.R. Part 42 that relate to an
equal employment opportunity program.
Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 54
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28
C.F.R. Part 54, which relates to nondiscrimination on the basis of sex in certain "education programs."
Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 38
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28
C.F.R. Part 38, specifically including any applicable requirements regarding written notice to program beneficiaries and
prospective program beneficiaries. Part 38 of 28 C.F.R., a DOJ regulation, was amended effective May 4, 2016.
Among other things, 28 C.F.R. Part 38 includes rules that prohibit specific forms of discrimination on the basis of
religion, a religious belief, a refusal to hold a religious belief, or refusal to attend or participate in a religious practice.
Part 38 also sets out rules and requirements that pertain to recipient and subrecipient ("subgrantee") organizations that
engage in or conduct explicitly religious activities, as well as rules and requirements that pertain to recipients and
subrecipients that are faith-based or religious organizations.
The text of the regulation, now entitled "Partnerships with Faith-Based and Other Neighborhood Organizations," is
available via the Electronic Code of Federal Regulations (currently accessible at https://www.ecfr.gov/cgi-
bin/ECFR?page=browse), by browsing to Title 28-Judicial Administration, Chapter 1, Part 38, under e-CFR "current"
data.
Restrictions on "lobbying"
In general, as a matter of federal law, federal funds awarded by OJP may not be used by the recipient, or any
subrecipient ("subgrantee") at any tier, either directly or indirectly, to support or oppose the enactment, repeal,
modification, or adoption of any law, regulation, or policy, at any level of government. See 18 U.S.C. 1913. (There
may be exceptions if an applicable federal statute specifically authorizes certain activities that otherwise would be
barred by law.)
Another federal law generally prohibits federal funds awarded by OJP from being used by the recipient, or any
subrecipient at any tier, to pay any person to influence (or attempt to influence) a federal agency, a Member of
Congress, or Congress (or an official or employee of any of them) with respect to the awarding of a federal grant or
cooperative agreement, subgrant, contract, subcontract, or loan, or with respect to actions such as renewing, extending,
or modifying any such award. See 31 U.S.C. 1352. Certain exceptions to this law apply, including an exception that
applies to Indian tribes and tribal organizations.
Should any question arise as to whether a particular use of federal funds by a recipient (or subrecipient) would or might
fall within the scope of these prohibitions, the recipient is to contact OJP for guidance, and may not proceed without the
express prior written approval of OJP.
16.
17.
18.
19.
OJP FORM 4000/2 (REV. 4-88)
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PAGE 7 OF
U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
Compliance with general appropriations-law restrictions on the use of federal funds (FY 2017)
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable restrictions on the use of
federal funds set out in federal appropriations statutes. Pertinent restrictions, including from various "general
provisions" in the Consolidated Appropriations Act, 2017, are set out at
https://ojp.gov/funding/Explore/FY17AppropriationsRestrictions.htm, and are incorporated by reference here.
Should a question arise as to whether a particular use of federal funds by a recipient (or a subrecipient) would or might
fall within the scope of an appropriations-law restriction, the recipient is to contact OJP for guidance, and may not
proceed without the express prior written approval of OJP.
Reporting potential fraud, waste, and abuse, and similar misconduct
The recipient, and any subrecipients ("subgrantees") at any tier, must promptly refer to the DOJ Office of the Inspector
General (OIG) any credible evidence that a principal, employee, agent, subrecipient, contractor, subcontractor, or other
person has, in connection with funds under this award-- (1) submitted a claim that violates the False Claims Act; or (2)
committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, gratuity, or similar
misconduct.
Potential fraud, waste, abuse, or misconduct involving or relating to funds under this award should be reported to the
OIG by-- (1) mail directed to: Office of the Inspector General, U.S. Department of Justice, Investigations Division,
950 Pennsylvania Avenue, N.W. Room 4706, Washington, DC 20530; (2) e-mail to: oig.hotline@usdoj.gov; and/or (3)
the DOJ OIG hotline: (contact information in English and Spanish) at (800) 869-4499 (phone) or (202) 616-9881
(fax).
Additional information is available from the DOJ OIG website at https://www.usdoj.gov/oig.
20.
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SPECIAL CONDITIONS
Restrictions and certifications regarding non-disclosure agreements and related matters
No recipient or subrecipient ("subgrantee") under this award, or entity that receives a procurement contract or
subcontract with any funds under this award, may require any employee or contractor to sign an internal confidentiality
agreement or statement that prohibits or otherwise restricts, or purports to prohibit or restrict, the reporting (in
accordance with law) of waste, fraud, or abuse to an investigative or law enforcement representative of a federal
department or agency authorized to receive such information.
The foregoing is not intended, and shall not be understood by the agency making this award, to contravene
requirements applicable to Standard Form 312 (which relates to classified information), Form 4414 (which relates to
sensitive compartmented information), or any other form issued by a federal department or agency governing the
nondisclosure of classified information.
1. In accepting this award, the recipient--
a. represents that it neither requires nor has required internal confidentiality agreements or statements from employees
or contractors that currently prohibit or otherwise currently restrict (or purport to prohibit or restrict) employees or
contractors from reporting waste, fraud, or abuse as described above; and
b. certifies that, if it learns or is notified that it is or has been requiring its employees or contractors to execute
agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud,
or abuse as described above, it will immediately stop any further obligations of award funds, will provide prompt
written notification to the federal agency making this award, and will resume (or permit resumption of) such
obligations only if expressly authorized to do so by that agency.
2. If the recipient does or is authorized under this award to make subawards ("subgrants"), procurement contracts, or
both--
a. it represents that--
(1) it has determined that no other entity that the recipient's application proposes may or will receive award funds
(whether through a subaward ("subgrant"), procurement contract, or subcontract under a procurement contract) either
requires or has required internal confidentiality agreements or statements from employees or contractors that currently
prohibit or otherwise currently restrict (or purport to prohibit or restrict) employees or contractors from reporting waste,
fraud, or abuse as described above; and
(2) it has made appropriate inquiry, or otherwise has an adequate factual basis, to support this representation; and
b. it certifies that, if it learns or is notified that any subrecipient, contractor, or subcontractor entity that receives funds
under this award is or has been requiring its employees or contractors to execute agreements or statements that prohibit
or otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud, or abuse as described above, it will
immediately stop any further obligations of award funds to or by that entity, will provide prompt written notification to
the federal agency making this award, and will resume (or permit resumption of) such obligations only if expressly
authorized to do so by that agency.
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AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
Compliance with 41 U.S.C. 4712 (including prohibitions on reprisal; notice to employees)
The recipient (and any subrecipient at any tier) must comply with, and is subject to, all applicable provisions of 41
U.S.C. 4712, including all applicable provisions that prohibit, under specified circumstances, discrimination against an
employee as reprisal for the employee's disclosure of information related to gross mismanagement of a federal grant, a
gross waste of federal funds, an abuse of authority relating to a federal grant, a substantial and specific danger to public
health or safety, or a violation of law, rule, or regulation related to a federal grant.
The recipient also must inform its employees, in writing (and in the predominant native language of the workforce), of
employee rights and remedies under 41 U.S.C. 4712.
Should a question arise as to the applicability of the provisions of 41 U.S.C. 4712 to this award, the recipient is to
contact the DOJ awarding agency (OJP or OVW, as appropriate) for guidance.
Encouragement of policies to ban text messaging while driving
Pursuant to Executive Order 13513, "Federal Leadership on Reducing Text Messaging While Driving," 74 Fed. Reg.
51225 (October 1, 2009), DOJ encourages recipients and subrecipients ("subgrantees") to adopt and enforce policies
banning employees from text messaging while driving any vehicle during the course of performing work funded by this
award, and to establish workplace safety policies and conduct education, awareness, and other outreach to decrease
crashes caused by distracted drivers.
Requirement to disclose whether recipient is designated "high risk" by a federal grant-making agency outside of DOJ
If the recipient is designated "high risk" by a federal grant-making agency outside of DOJ, currently or at any time
during the course of the period of performance under this award, the recipient must disclose that fact and certain related
information to OJP by email at OJP.ComplianceReporting@ojp.usdoj.gov. For purposes of this disclosure, high risk
includes any status under which a federal awarding agency provides additional oversight due to the recipient's past
performance, or other programmatic or financial concerns with the recipient. The recipient's disclosure must include
the following: 1. The federal awarding agency that currently designates the recipient high risk, 2. The date the recipient
was designated high risk, 3. The high-risk point of contact at that federal awarding agency (name, phone number, and
email address), and 4. The reasons for the high-risk status, as set out by the federal awarding agency.
The recipient agrees to submit to BJA for review and approval any curricula, training materials, proposed publications,
reports, or any other written materials that will be published, including web-based materials and web site content,
through funds from this grant at least thirty (30) working days prior to the targeted dissemination date. Any written,
visual, or audio publications, with the exception of press releases, whether published at the grantee's or government's
expense, shall contain the following statements: "This project was supported by Grant No. 2017-VV-BX-0006
awarded by the Bureau of Justice Assistance. The Bureau of Justice Assistance is a component of the Department of
Justice's Office of Justice Programs, which also includes the Bureau of Justice Statistics, the National Institute of
Justice, the Office of Juvenile Justice and Delinquency Prevention, the Office for Victims of Crime, and the SMART
Office. Points of view or opinions in this document are those of the author and do not necessarily represent the official
position or policies of the U.S. Department of Justice." The current edition of the DOJ Grants Financial Guide provides
guidance on allowable printing and publication activities.
23.
24.
25.
26.
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Office of Justice Programs
Bureau of Justice Assistance
AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
The recipient agrees to comply with OJP grant monitoring guidelines, protocols, and procedures, and to cooperate with
OJP (including the grant manager for this award and the Office of Chief Financial Officer (OCFO)) on all grant
monitoring requests, including requests related to desk reviews, enhanced programmatic desk reviews, and/or site visits.
The recipient agrees to provide to OJP all documentation necessary to complete monitoring tasks, including
documentation related to any subawards made under this award. Further, the recipient agrees to abide by reasonable
deadlines set by OJP for providing the requested documents. Failure to cooperate with OJP's grant monitoring
activities may result in sanctions affecting the recipient's DOJ awards, including, but not limited to: withholdings
and/or other restrictions on the recipient's access to grant funds; referral to the Office of the Inspector General for audit
review; designation of the recipient as a DOJ High Risk grantee; or termination of an award(s).
Award recipients must verify Point of Contact(POC), Financial Point of Contact (FPOC), and Authorized
Representative contact information in GMS, including telephone number and e-mail address. If any information is
incorrect or has changed, a Grant Adjustment Notice (GAN) must be submitted via the Grants Management System
(GMS) to document changes.
The recipient agrees to cooperate with any assessments, national evaluation efforts, or information or data collection
requests, including, but not limited to, the provision of any information required for the assessment or evaluation of any
activities within this project.
Approval of this award does not indicate approval of any consultant rate in excess of $650 per day. A detailed
justification must be submitted to and approved by the Office of Justice Programs (OJP) program office prior to
obligation or expenditure of such funds.
Recipient understands and agrees that it must submit quarterly Federal Financial Reports (SF-425) and semi-annual
performance reports through GMS (https://grants.ojp.usdoj.gov), and that it must submit quarterly performance metrics
reports through BJA's Performance Measurement Tool (PMT) website (www.bjaperformancetools.org). For more
detailed information on reporting and other requirements, refer to BJA's website. Failure to submit required reports by
established deadlines may result in the freezing of grant funds and High Risk designation.
Grantee agrees that assistance funds awarded under this grant will not be used to support any inherently religious
activities, such as worship, religious instruction, or proselytization. If the grantee refers participants to, or provides, a
non-Federally funded program or service that incorporates such religious activities, (1) any such activities must be
voluntary for program participants, and (2) program participants may not be excluded from participation in a program
or otherwise penalized or disadvantaged for any failure to accept a referral or services. If participation in a non-
Federally funded program or service that incorporates inherently religious activities is deemed a critical treatment or
support service for program participants, the grantee agrees to identify and refer participants who object to the
inherently religious activities of such program or service to, or provide, a comparable secular alternative program or
service.
The recipient must comply with applicable requirements to report first-tier subawards ("subgrants") of $25,000 or
more and, in certain circumstances, to report the names and total compensation of the five most highly compensated
executives of the recipient and first-tier subrecipients (first-tier "subgrantees") of award funds. The details of recipient
obligations, which derive from the Federal Funding Accountability and Transparency Act of 2006 (FFATA), are posted
on the OJP web site at https://ojp.gov/funding/Explore/FFATA.htm (Award condition: Reporting Subawards and
Executive Compensation), and are incorporated by reference here.
This condition, including its reporting requirement, does not apply to an award made to an individual who received the
award as a natural person (i.e., unrelated to any business or non-profit organization that he or she may own or operate
in his or her name).
27.
28.
29.
30.
31.
32.
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AWARD DATE 09/23/2017PROJECT NUMBER 2017-VV-BX-0006
SPECIAL CONDITIONS
The recipient understands and agrees that no award or matching funds may be used to provide services for violent
offenders as defined in 42 U.S.C. 3797u-2, a “violent offender” means a person who—(1) is charged with or convicted of
an offense that is punishable by a term of imprisonment exceeding one year, during the course of which offense or
conduct— (A) the person carried, possessed, or used a firearm or dangerous weapon; (B) there occurred the death of or
serious bodily injury to any person; or (C) there occurred the use of force against the person of another, without regard
to whether any of the circumstances described in subparagraph (A) or (B) is an element of the offense or conduct of
which or for which the person is charged or convicted; or (2) has 1 or more prior convictions for a felony crime of
violence involving the use or attempted use of force against a person with the intent to cause death or serious bodily
harm.
Recipient understands and agrees that, to the extent that substance abuse treatment and related services are funded by
this award, they will include needed treatment and services to address opioid abuse reduction.
With respect to this award, federal funds may not be used to pay cash compensation (salary plus bonuses) to any
employee of the award recipient at a rate that exceeds 110% of the maximum annual salary payable to a member of the
federal government's Senior Executive Service (SES) at an agency with a Certified SES Performance Appraisal System
for that year. (An award recipient may compensate an employee at a higher rate, provided the amount in excess of this
compensation limitation is paid with non-federal funds.)
This limitation on compensation rates allowable under this award may be waived on an individual basis at the
discretion of the OJP official indicated in the program announcement under which this award is made.
The recipient agrees to submit to BJA, by the termination of the award period, an electronic copy of the final evaluation
report. The final evaluation report must be submitted to BJA as a "Special Report," via the OJP Grants Management
System Progress Reports Module.
The recipient is authorized to incur obligations, expend, and draw down funds for travel, lodging, and per diem costs
only, in an amount not to exceed $15,000, for the sole purpose of attending a required OJP conference associated with
this grant award. The grantee is not authorized to incur any additional obligations, or make any additional expenditures
or draw downs until the awarding agency and the Office of the Chief Financial Officer (OCFO) has reviewed and
approved the recipient's budget and budget narrative, and a Grant Adjustment Notice (GAN) has been issued to remove
this special condition.
Recipient may not obligate, expend or drawdown funds until the Bureau of Justice Assistance, Office of Justice
Programs has reviewed and approved the Program Narrative portion of the application and has issued a Grant
Adjustment Notice (GAN) informing the recipient of the approval.
Recipient may not obligate, expend, or drawdown funds until the Bureau of Justice Assistance, Office of Justice
Programs has reviewed and approved the Budget Narrative portion of the application and has issued a Grant
Adjustment Notice (GAN) informing the recipient of the approval.
34.
35.
36.
37.
38.
39.
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Memorandum To:
From:
Subject:
Washington, D.C. 20531
Orbin Terry, NEPA Coordinator
Categorical Exclusion for City of Bozeman
The Adult Drug Court Discretionary Grant Program is designed to assist states, state courts, local courts, and
counties, other units of local government, or Indian tribal governments to implement comprehensive strategies for
enhancing drug court capacity by bridging access to both criminal justice and substance abuse treatment funds.
None of the following activities will be conducted whether under the Office of Justice Programs federal action or a
related third party action:
(1) New construction.
(2) Any renovation or remodeling of a property located in an environmentally or historically sensitive area,
including property (a) listed on or eligible for listing on the National Register of Historic Places, or (b) located
within a 100-year flood plain, a wetland, or habitat for an endangered species.
(3) A renovation that will change the basic prior use of a facility or significantly change its size.
(4) Research and technology whose anticipated and future application could be expected to have an effect on the
environment.
(5) Implementation of a program involving the use of chemicals.
Additionally, the proposed action is neither a phase nor a segment of a project that when reviewed in its entirety
would not meet the criteria for a categorical exclusion. Consequently, the subject federal action meets the Office of
Justice Programs' criteria for a categorical exclusion as contained in paragraph 4(b) of Appendix D to Part 61 of
Title 28 of the Code of Federal Regulations.
Official Grant File
U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
121
GRANT MANAGER'S MEMORANDUM, PT. I:
PROJECT SUMMARY
1. STAFF CONTACT (Name & telephone number)
PROJECT NUMBER
6. NAME & ADRESS OF SUBGRANTEE
7. PROGRAM PERIOD 8. BUDGET PERIOD
9. AMOUNT OF AWARD 10. DATE OF AWARD
11. SECOND YEAR'S BUDGET
2017-VV-BX-0006
2. PROJECT DIRECTOR (Name, address & telephone number)
4. TITLE OF PROJECT
12. SECOND YEAR'S BUDGET AMOUNT
13. THIRD YEAR'S BUDGET PERIOD 14. THIRD YEAR'S BUDGET AMOUNT
15. SUMMARY DESCRIPTION OF PROJECT (See instruction on reverse)
5. NAME & ADDRESS OF GRANTEE
Grant
This project is supported under FY17(BJA - Veterans Treatment Courts) Pub. L. No. 115-31, 131 Stat 135, 205
Colleen Herrington
Police Lieutenant
P.O. Box 1230
121 N. Rouse Avenue
Bozeman, MT 59771
(406) 599-7063
PAGE 11OF
The purpose of the Adult Drug Court Discretionary Grant Program (42 U.S.C. 3797u et seq.) is to provide financial and technical assistance to states, state courts,
local courts, units of local government, and Indian tribal governments to develop and implement drug courts that effectively integrate evidence-based substance
abuse treatment, mandatory drug testing, sanctions and incentives, and transitional services in a judicially supervised court setting with jurisdiction over substance
abusing offenders. The FY 2017 Adult Drug Court Discretionary Grant Program will provide grant funds to jurisdictions to implement or enhance a local drug
court, or to implement, enhance, or expand drug court services statewide, including services to address opioid abuse reduction.
Under Category 1: Implementation, the grant recipient will use the grant funds to build and maximize the capacity of a single jurisdiction drug court to: ensure that
all offenders are identified and assessed for risk and need; ensure all substance abusing offenders receive targeted research-based and data-driven services; enhance
the provision of ancillary services that prevent recidivism such as individualized treatment, vocational and educational services and community reintegration
Kerri Vitalo-Logan
(202) 353-9074
OJP FORM 4000/2 (REV. 4-88)
Bozeman Veterans Treatment Court
City of Bozeman
P.O. Box 1230
Bozeman, MT 59771-1230
TO:10/01/2017 09/30/2020FROM:TO:10/01/2017 09/30/2020FROM:
09/23/2017 $ 400,000
3b. POMS CODE (SEE INSTRUCTIONS
ON REVERSE)
3a. TITLE OF THE PROGRAM
BJA FY 17 Adult Drug Court Discretionary Grant Program: Implementation
U.S. Department of Justice
Office of Justice Programs
Bureau of Justice Assistance
122
services to achieve long-term recovery; and, overall, meet the key components and the evidence-based program principles in the nationally-recognized drug court
standards. CA/NCF
123