COVID-19 Response Guidance for Subrecipients
The Criminal Justice Coordinating Council (CJCC) would like to thank you for continuing to deliver crucial services within our communities. We understand that this is a time filled with anxiety of the unknown and we thank you for your selfless service and for continuing to respond to those in need.
CJCC leadership is gathering information from the Centers for Disease Control and Prevention (CDC), Administration for Children and Families, Office of Juvenile Justice and Delinquency Prevention, Department of Justice, National Institute of Justice, Bureau of Justice Assistance, Substance Abuse and Mental Health Services Administration, Department of Health and Human Services, Office for Victims of Crime, Office of Violence Against Women, Department of Health and Human Services, Department of Public Health, and others to address questions and concerns. We encourage programs to contact their local health department for the most up to date information and guidance to assist in the decision-making process for their agency. This is the only guidance we have at this time, but we will be updating our guidance as more information becomes available.
Question 1: Will our agency be able to submit reimbursement requests, adjustment requests, etc.?
Answer 1: Yes. In lieu of recent concerns around the spread of COVID-19, we are following the lead of the Governor’s Office and CJCC has implemented a telework schedule for staff. This includes an electronic workflow that accommodates the processing of payments, adjustments, and activations while working remotely.
Please email all grant reimbursement requests, adjustment requests, and award documents/packets to your assigned grants admin email address and copy your assigned grant specialist.
Please email CJCC team members for the most expedient response, they will be as responsive as possible. CJCC team members will be checking their voice mail and email regularly during this time.
Question 2: Will CJCC continue in-person meetings or site visits?
Answer 2: As of March 12, 2020, CJCC has postponed and/or cancelled all scheduled meetings, site visits, and other in-person meetings, with very few exceptions, until further notice. When possible, some meetings and training events may be hosted online. CJCC will inform you if a pre-scheduled meeting or site visit will be hosted online.
Question 3: Will CJCC and other partner agencies extend deadlines for initiatives, solicitation submissions, applications, etc.?
Answer 3: CJCC will extend deadlines when possible. Please check CJCC’s website for updated information on any extensions, and/or check with your Grant Specialist/Planner.
For Federal solicitations awards managed by the Office of Justice Programs (OJP), they have communicated that solicitations with application due dates between March 16th and March 31st will have a two-week extension for submission. OJP program offices are in the process of updating those due dates now. OJP will continue to monitor the situation and determine if additional adjustments to closing dates will be needed. Grants.gov and OJP’s Grants Management System remain open to continue to accept applications.
Question 4: What if we need to temporarily close programs because of the COVID-19 virus?
Answer 4: Programs should prepare to implement prevention efforts to contain the spread of the virus. Details specific to your program can be found on CJCC’s COVID-19 response page.
Should any agency or program need to close its office and provide services remotely, CJCC requests that an emergency action plan explaining the changes to service delivery and how services will be delivered be submitted to their assigned Grants Specialist.
Question 5: What if there are interruptions in the performance of work under the grant?
Answer 5 Subrecipients should review the DOJ Grants Financial Guide and the Part 200 Uniform Requirements (2 C.F.R. Part 200, as adopted by DOJ) (see, for example, 2 CFR 200.430 and 2 C.F.R. 200.431, under Subpart E – Cost Principles), and the subgrantee’s established policies, to help in determining how the subgrantee’s personnel costs may be treated during any period(s) of interruption to the performance of work under the award. You should direct any questions about allowability of costs to your grant specialist or unit supervisors.
Question 6: Should I notify CJCC about any closures?
Answer 6: Yes, please notify CJCC about any impending closure. See FAQ Question/Answer 4.
Question 7: What should be done with participants or clients suspected or confirmed to have COVID-19?
Answer 7: Per the CDC, decisions about whether clients with mild illness due to suspected or confirmed COVID-19 should be made in coordination with local health authorities. Similarly, identifying respite care locations for patients with confirmed COVID-19 who have been discharged from the hospital should be made in coordination with local healthcare facilities and your local health department.
Question 8: Can programs limit participant transportation to essential travel requests while federal guidance is in place to limit movement to support containment and limit spread of the virus?
Answer 8: Yes. Programs may limit access to transportation assistance to essential transportation needs of participants. Essential travel includes access to safe shelter, medical appointments, work or transportation for necessary groceries/supplies. Federal guidance asks the public to do their part to slow the spread of the coronavirus. “Even if you are young, or otherwise healthy, you are at risk and your activities can increase the risk for others. It is critical that you do your part to slow down the spread of coronavirus.” https://www.whitehouse.gov/wp-content/uploads/2020/03/03.16.20_coronavi…
Per the Department of Family and Children’s Services Guidance For Foster Care Parents and Provider’s, please see below for their guidance for court-ordered visitation:
What do we do about court-ordered visitation? It is the Division's recommendation that in-person court-ordered visitation be suspended and replaced with frequent video conferencing and / or phone calls to ensure children stay safe while remaining connected to their parents during this period. In order to remain compliant with judicial court orders, county DFCS offices will need to immediately work to get local juvenile court approval prior to this temporary practice change occurring.
Question 9: Can agencies pay their grant funded staff (even those without leave)?
Answer 9: If programs must reduce services due to a health crisis resulting in quarantines, programs should use their existing leave policies to address employee absences. If you do not currently have policies regarding working remotely and paid administrative leave, please develop those policies. Provided your organization has policies in place and all staff (Federally funded and non-Federally funded) are treated equally, we can continue to reimburse the project even if services are temporarily reduced. Please send any developed policies to your assigned Grant Specialist.
Question 10: As colleges/universities are cancelling classes or going online, agencies who depend on volunteer hours for match may have struggles as their student interns/volunteers get sent home and cannot fulfill their practicum hours. Will CJCC be flexible with the match requirements on federal awards?
Answer 10: If a program is unable to meet match through volunteers, we would work with them to see if they can meet match in other ways. If not, we may consider approving an emergency match waiver if the situation is well-documented.
Question 11: Should we limit non-essential travel?
Answer 11: CJCC strongly encourages subrecipients to limit travel to only essential travel. Also see Question/Answer 9.
Question 12: If our agency needs to cancel upcoming travel, will federal funds cover cancellation fees for reserved travel for canceled conferences and training events?
Answer 12: Grantees should contact their grant specialist to address issues resulting from postponed or canceled meetings, such as using grant funds to cover hotel or travel related cancellation fees and penalties.
Grantees should try to have the airline reimburse the canceled ticket(s) in cash. However, if the airline will only refund the cancellation as a credit:
- The grantee should apply the credit to a future trip for the same grant or project.
- If that is not possible, the grantee should use the credit for another CJCC administered grant program or project and reimburse the original grant or project with the equivalent dollar amount.
- If neither of those options is possible, then the grantee should process the trip as a cancellation, which CJCC approves to be charged to the grant due to this mitigating circumstance.
Question 13: Can programs request reimbursement for specialized cleaning of their facility?
Answer 13: CJCC understands the fluidity of the current emergency and will be as flexible as possible with budget adjustment requests to meet agency and client needs. Please submit adjustment requests to your assigned grants admin email accordingly with any evolving needs. Also see Question/Answer 1.
Question 14: What resources can our agency access for planning and response to COVID-19?
Answer 14: Please find a list of resources available: