Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the Office of Justice 

Programs Victim Assistance Grants

Awarded to the

New Jersey Department of

Law and Public Safety,

Trenton, New Jersey

Audit Division 20-078 July 2020
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Executive Summary 

Audit of the Office of Justice Programs Victim Assistance Grants Awarded to 

the New Jersey Department of Law and Public Safety, Trenton, New Jersey 

Objective 

The objective of the audit was to evaluate how the New 

Jersey Department of Law and Public Safety (NJ DLPS) 

designed and implemented its crime victim assistance 

program. To accomplish this objective, we assessed 

performance in the following areas of grant 

management: (1) grant program planning and 

execution, (2) program requirements and performance 

reporting, (3) grant financial management, and 

(4) monitoring of subrecipients. 

Results in Brief 

As a result of our audit, we concluded that NJ DLPS did 

not meet all of the grant requirements, particularly 

regarding: (1) obligating and expending funds within 

the project period (2) awarding funds to subrecipients in 

a timely manner, (3) monitoring compliance with priority 

area funding requirement, (4) ensuring annual 

performance reports were complete and accurate, 

(5) administering and monitoring subrecipient awards, 

(6) awarding funds to subrecipients in a timely manner. 

We also identified $75,334 in questioned costs. Despite 

these weaknesses we found NJ DLPS conducted 

adequate strategic planning and increased the number 

of projects funded and scope of services provided and 

had an adequate financial management system in place. 

Recommendations 

Our report contains seven recommendations to the 

Office of Justice Programs (OJP) to assist NJ DLPS in 

improving its grant management and administration and 

to remedy questioned costs. We requested a response to 

our draft audit report from NJ DLPS and OJP, which can 

be found in Appendix 3 and 4, respectively. Our 

analysis of those responses is included in Appendix 5. 

Audit Results 

The U.S. Department of Justice (DOJ) Office of the 

Inspector General (OIG) completed an audit of four 

VOCA victim assistance formula grants awarded by OJP’s 

Office for Victims of Crime (OVC) to NJ DLPS in Trenton, 

New Jersey. These formula grants, totaling $177.5 

million from fiscal years 2014 to 2017, were provided 

from the Crime Victims Fund (CVF) to enhance crime 

victim services in New Jersey. As of April 2020, NJ DLPS 

drew down a cumulative amount of $111.2 million for all 

of the grants we audited. 

Program Planning and Execution – While we found 

NJ DLPS conducted adequate strategic planning and 

increased the number and scope of projects funded, we 

identified that NJ DLPS was unable to distribute funds in 

a timely manner to subrecipients because it was 

understaffed and lacked policies and procedures for 

prioritizing funding based on subrecipient financial need. 

Further, NJ DLPS inadequately monitored compliance 

with the priority funding requirement because it did not 

have specific staff assigned to monitor compliance, 

lacked written procedures, and monitored compliance 

based on potential funds awarded to subrecipients 

rather than actual funds awarded. 

Grant Financial Management – We determined NJ 

DLPS’s policies and procedures were ineffective in 

detecting unallowable and unsupported expenditures. 

For example, from our onsite subrecipient testing we 

identified $75,334 in reimbursements for transactions 

that were not appropriately supported. 

Subrecipient Reporting and Monitoring – We found 

that NJ DLPS did not conduct site visits every 2 years for 

each subrecipient, as required by federal criteria and NJ 

DLPS procedures. NJ DLPS did not obtain reasonable 

assurance that its annual progress reports were accurate 

because it did not validate reported subrecipient victim 

statistics during its site visits or other reviews, and 

lacked written policies or procedures to ensure the 

accuracy of data submitted in performance reports. 

i 
 

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

VICTIM ASSISTANCE GRANTS AWARDED TO THE 

NEW JERSEY DEPARTMENT OF LAW AND PUBLIC SAFETY, 

TRENTON, NEW JERSEY 

TABLE OF CONTENTS 

INTRODUCTION .......................................................................................... 1 

The Grantee ...................................................................................... 2 

OIG Audit Approach ............................................................................ 2 

AUDIT RESULTS.......................................................................................... 4 

Grant Program Planning and Execution .................................................. 4 

Subaward Allocation Plan ............................................................ 4 

Subaward Selection Process ........................................................ 6 

Subawarding Process ................................................................. 8 

Subaward Requirements ............................................................. 9 

Program Requirements and Performance Reporting.................................. 9 

Priority Areas Funding Requirement.............................................. 9 

Annual Performance Reports...................................................... 10 

Compliance with Special Conditions ............................................ 12 

Grant Financial Management .............................................................. 12 

Grant Expenditures .................................................................. 13 

Drawdowns............................................................................. 17 

Matching Requirement.............................................................. 18 

Financial Reporting .................................................................. 19 

Monitoring of Subrecipients ................................................................ 19 

Financial Monitoring ................................................................. 20 

Performance Monitoring............................................................ 21 

Subrecipient Risk Assessment.................................................... 22 
 

 

 

 

 

 

Subrecipient Site Visits ............................................................. 23 

CONCLUSION AND RECOMMENDATIONS....................................................... 24 

APPENDIX 1: OBJECTIVE, SCOPE, AND METHODOLOGY.................................. 25 

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS............................... 27 

APPENDIX 3: NEW JERSEY DEPARTMENT OF LAW AND PUBLIC SAFETY 

RESPONSE TO THE DRAFT AUDIT REPORT............................................ 28 

APPENDIX 4: U.S. DEPARTMENT OF JUSTICE OFFICE OF JUSTICE PROGRAMS 

RESPONSE TO THE DRAFT AUDIT REPORT............................................ 32 

APPENDIX 5: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT.................................. 36 
 

 

 

 

 

 

 

 

 

 

 

 

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

VICTIM ASSISTANCE GRANTS AWARDED TO THE 

NEW JERSEY DEPARTMENT OF LAW AND PUBLIC SAFETY, 

TRENTON, NEW JERSEY 

INTRODUCTION 

The U.S. Department of Justice (DOJ) Office of the Inspector General (OIG) 

completed an audit of four victim assistance formula grants awarded by the Office 

of Justice Programs (OJP), Office for Victims of Crime (OVC) to the New Jersey 

Department of Law and Public Safety (NJ DLPS) in Trenton, New Jersey. The OVC 

awards victim assistance grants annually from the Crime Victims Fund (CVF) to 

state administering agencies. As shown in Table 1, from fiscal years (FY) 2014 to 

2017, these OVC grants awarded to NJ DLPS totaled $177,557,262. 

Table 1 

Audited Grants 

Fiscal Years 2014 – 2017 

Award Number Award Date Award Period 

Start Date 

Award Period 

End Date Award Amount 

2014-VA-GX-0032 9/16/2014 10/1/2013 9/30/2017 $12,416,634 

2015-VA-GX-0021 9/15/2015 10/1/2014 9/30/2018 $53,992,667 

2016-VA-GX-0072 9/19/2016 10/1/2015 9/30/2019 $60,868,131 

2017-VA-GX-0058 9/28/2017 10/1/2016 9/30/2020 $50,279,830 

Total: $177,557,262 

Note: Grant funds are available for the fiscal year of the award plus 3 additional fiscal years. 

Source: OJP Grants Management System 

Established by the Victims of Crime Act (VOCA) of 1984, the CVF is used to 

support crime victims through DOJ programs and state and local victim services.1 

The CVF is supported entirely by federal criminal fees, penalties, forfeited bail 

bonds, gifts, donations, and special assessments. The OVC annually distributes 

proceeds from the CVF to states and territories. The total amount of funds that the 

OVC may distribute each year depends upon the amount of CVF deposits made 

during the preceding years and limits set by Congress (the cap). 

In FY 2015, Congress significantly raised the previous year’s cap on CVF 

disbursements, which more than quadrupled the available funding for victim 

assistance grants from $455.8 million to $1.96 billion. In FY 2016, Congress raised 

the cap again, increasing the available funding for victim assistance to $2.22 billion. 

For FY 2017, $1.8 billion was available for victim assistance. The OVC allocates the 

annual victim assistance program awards based on the amount available for victim 

1 The VOCA victim assistance formula program is funded under 34 U.S.C. § 20103. 

1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

assistance each year and a state’s population. As such, the annual VOCA victim 

assistance grant funds available to NJ DLPS increased from $12.41 million in 

FY 2014 to nearly $54 million in FY 2015, $60.86 million in FY 2016, and over 

$50 million in FY 2017. 

VOCA victim assistance grant funds are to support the provision of direct 

services – such as crisis intervention, assistance in filing restraining orders, 

counseling in crises arising from the occurrence of crime, and emergency shelter – 

to victims of crime. The OVC distributes these assistance grants to states and 

territories, which in turn fund subawards to public and private nonprofit 

organizations that directly provide the services to victims. Eligible services are 

efforts that: (1) respond to the emotional and physical needs of crime victims, 

(2) assist primary and secondary victims of crime to stabilize their lives after a 

victimization, (3) assist victims to understand and participate in the criminal justice 

system, and (4) provide victims of crime with a measure of safety and security. 

The Grantee 

As the state administering agency (SAA) for New Jersey, NJ DLPS is 

responsible for administering the VOCA victim assistance program. According to its 

website, the mission of NJ DLPS is to protect the life and property of New Jersey 

residents. NJ DLPS’s 7,700 employees are responsible for protecting citizens' civil 

and consumer rights, promoting highway traffic safety, maintaining public 

confidence in the alcoholic beverage, gaming, and racing industries, and providing 

legal services and counsel to other state agencies. Within NJ DLPS, the Office of 

Attorney General (OAG) is responsible for the fiscal and programmatic oversight of 

the VOCA grants. OAG, with respect to the VOCA grants, conducts strategic 

planning, subaward allocation, submission of Federal Financial Reports (FFRs), and 

the annual certification of VOCA performance statistics. NJ DLPS relies on OAG’s 

Subrecipient Monitoring Unit (SMU) to develop subrecipient monitoring policies and 

procedures, conduct subrecipient site visits and subrecipient desk reviews, and 

provide technical assistance and training to subrecipients. NJ DLPS relies on OAG’s 

Grants Development Section (GDS) for the day-to-day administration of over 500 

VOCA and Non-VOCA subgrants. GDS program analysts assess subrecipient risk, 

score competitive applications, review and approve subrecipient budget proposals, 

approve subrecipient post-award requests, and review and approve State of New 

Jersey quarterly performance reports submitted by subrecipients. GDS staff are 

responsible for the review and approval of subrecipient reimbursement requests. 

At the time of our fieldwork, we observed that NJ DLPS’s VOCA subrecipients 

were comprised of state government components, county governments, and nonprofit organizations. NJ DLPS relied on the subrecipients to deliver a cross-section 

of direct victim services that included services for victims of child abuse, domestic 

violence, sexual assault, as well as crime victims from underserved communities. 

OIG Audit Approach 

The objective of this audit was to evaluate how NJ DLPS designed and 

implemented its crime victim assistance program. To accomplish this objective, we 

2 
 

 

 

assessed performance in the following areas of grant management: (1) grant 

program planning and execution, (2) program requirements and performance 

reporting, (3) grant financial management, and (4) monitoring of subrecipients. 

We tested compliance with what we consider the most important conditions 

of the grants. Unless otherwise stated in our report, we applied the authorizing 

VOCA legislation; the VOCA victim assistance program guidelines (VOCA Guidelines) 

and Final Rule; the OJP Financial Guide and DOJ Grants Financial Guide (Financial 

Guide); and 2 C.F.R. 200, Uniform Administrative Requirements, Cost Principles, 

and Audit Requirements for Federal Awards (Uniform Guidance) as our primary 

criteria.2 We also reviewed relevant NJ DLPS policy and procedures and 

interviewed NJ DLPS personnel to determine how they distributed and administered 

VOCA funds. We conducted site visits of select subrecipients, interviewed 

subrecipient personnel, and obtained and reviewed NJ DLPS and subrecipient 

records reflecting grant activity.3 

2 The OJP Financial Guide governs the FY 2014 grant in our scope, while the revised DOJ 

Grants Financial Guide applies to the FY 2015 to FY 2017 awards. In this report we will refer to the 

applicable requirements for each award under the singular term Financial Guide. 

3 Appendix 1 contains additional information on the audit’s objective, scope, and 

methodology, as well as further detail on the criteria we applied for our audit. Appendix 2 presents a 

schedule of our dollar-related findings. 

3 
 

 

 

 

 

 

 

 

 

 

 

 

AUDIT RESULTS 

Grant Program Planning and Execution 

VOCA victim assistance awards are intended to enhance crime victim 

services, principally through subawards to local community-based organizations. 

The OVC distributes VOCA victim assistance grants to SAAs, which have the 

discretion to select subrecipients from among eligible organizations that provide 

direct services to crime victims and, additionally, must distribute the majority of the 

funding to those organizations. Based on the VOCA Guidelines, NJ DLPS, as the 

SAA, must give priority to victims of sexual assault, domestic abuse, and child 

abuse. Under this program, NJ DLPS must also make funding available for 

previously underserved populations of violent crime victims. We found that NJ 

DLPS distributed the funding to community-based victim coalitions with multiple 

members and to organizations that provide direct services to victims, such as rape 

treatment centers, domestic violence shelters, centers for missing children, and 

other community-based support organizations. 

As part of our audit, we assessed NJ DLPS’s overall plan to allocate and 

award victim assistance funding. We reviewed how NJ DLPS planned to distribute 

its available victim assistance grant funding, made subaward selection decisions, 

and informed its subrecipients of necessary VOCA requirements. Overall, we 

determined that NJ DLPS adequately identified and planned to meet additional 

victim service needs with its increased FY 2015 – 2017 funding, as discussed below. 

We did not identify issues with NJ DLPS’s process to select subrecipients, and we 

found that NJ DLPS adequately communicated applicable award requirements to the 

selected subrecipients. However, although DLPS was able to use its additional 

funding to increase its pool of subrecipients and the overall number of projects 

funded with its FY 2015 and 2016 awards, we are concerned about the challenges 

and risks associated with the significant balances that remain on NJ DLPS’s 2016 

and 2017 awards and the timeliness of the NJ DLPS subaward process. 

Subaward Allocation Plan 

In response to the significant increase in CVF-available funding, the OVC 

required FY 2015 VOCA Victim Assistance Formula applicants to submit subrecipient 

funding plans detailing what efforts would be taken to identify additional victim 

service needs, as well as subaward strategies to allocate the substantial increase in 

available funding. The VOCA Guidelines recommend that SAAs conduct strategic 

planning to maximize the delivery of services to victims and identify unmet victim 

needs as a component of the funding strategy.4 In response, NJ DLPS stated in its 

FY 2015 grant application its intention to allocate the increased funds to: 

4 According to the VOCA Guidelines, SAAs are encouraged to develop a funding strategy that 

should consider the following: the range of direct services throughout the State and within 

communities; the sustainability of such services; the unmet needs of crime victims; the demographic 

profile of crime victims; the coordinated, cooperative response of community organizations in 

organizing direct services; the availability of direct services throughout the criminal justice process, as 

well as to victims who are not participating in criminal justice proceedings; and the extent to which 

other sources of funding are available for direct services. 

4 
 

 

 

 

 

 

 

 

 

 

 

 

(1) enhance the delivery of victim advocate services through the hiring of additional 

victim advocates, including technology upgrades for existing victim advocates, 

(2) enhance the delivery of sexual assault services through increased funding for 

Sexual Assault Response Teams (SART) and Forensic Nurse Examiners (FNE), 

(3) enhance the delivery of services to victims of human trafficking which 

comprised an underserved victim population, and (4) enhance victim services for 

culturally underrepresented victims. To instruct its allocation decisions, NJ DLPS 

relied on a statewide needs assessment. According to the needs assessment, over 

victim service organizations throughout New Jersey were surveyed to identify gaps 

in services and to identify what classes of victims were underserved. Additionally, 

NJ DLPS formed two working groups to solicit the input from major subrecipient 

programs as well as solicit best practices from other SAAs to ensure that NJ DLPS’s 

allocation of funds maximized the delivery of victim services. Because NJ DLPS 

relied on an allocation methodology that was based on a needs assessment and 

was supplemented by additional strategic planning activities, we identified no 

exceptions with NJ DLPS plan to allocate FY 2015 VOCA funds. 

We also reviewed NJ DLPS’s funding plan and found the plan allocated funds 

to not-for-profit and governmental victim assistance programs throughout New 

Jersey to assist a range of victims, including victims of domestic violence, child 

abuse, sexual assault, elder abuse, and human trafficking. We also found that 

between FYs 2014 and 2015, NJ DLPS increased its number of subrecipients from 

86 to 209, while expanding the number of projects funded and the scope of those 

projects. For example, some subrecipients used the additional funding to hire more 

staff and invest in fixed assets such as passenger vehicles that allowed them to 

expand their coverage through offering additional services. 

We also reviewed NJ DLPS’s spending plan and payment history. We found 

NJ DLPS was able to put all of its FY 2015 grant award funds to use; however, NJ 

DLPS did not utilize all of the award funds for the FY 2014 and FY 2016 grants, and 

did not appear it would be able to appropriately utilize all funds from the FY 2017 

grant. The remaining unobligated award funds associated with the FY 2014 grant 

returned to OJP were not considered material and occurred before the significant 

increase in funding that started with the FY 2015 grant. More importantly, we 

asked officials about the $18,269,373 in FY 2016 award funds that were returned to 

OJP. NJ DLPS officials told us that two causes of the unobligated balance were that 

fewer potential subrecipients applied for funding than anticipated and that existing 

subrecipients spent less of their awards than anticipated. We expressed concerns 

to NJ DPLS officials about the FY 2017 grant that, as of January 2020, had less than 

a year remaining in the award period and only 2 percent of the award amount 

drawn down. NJ DPLS officials told us at that time they believed they had a plan in 

place to appropriately utilize all FY 2017 funds. More recently, a NJ DLPS official 

told us that 90 percent of the FY 2017 grant had been obligated with existing 

subrecipients and that the remaining funds may be obligated for possible 

5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

emergency technology upgrades so that subrecipients can better work remotely to 

mitigate lapses in the delivery of victim services during the COVID-19 outbreak.5 

We are aware of the challenges states face when distributing significant 

increases in funding. The OIG’s July 2019 report, titled OJP’s Efforts to Address 

Challenges in Administering Crime Victim Fund Programs Audit Report (“the 

Report”), noted that states would experience challenges in expending the full award 

amounts within award periods.6 First, the Report concluded that because of the 

timing of award distribution, states have closer to 3 years rather than full 4-year 

project periods to spend awards. Second, the Report cited commentary from states 

that expressed hesitation to obligate the full amount of grants on multi-year 

projects because of uncertainty over the amount of funds that will be awarded in 

future years; during our audit, NJ DLPS officials expressed similar concerns. Third, 

NJ DLPS officials echoed the Report’s finding that states had difficulty identifying 

subrecipients that both met VOCA’s eligibility requirements and are able to deliver 

necessary services at volumes needed.7 Lastly, given the multi-year award periods 

for the formula grants, the Report recognized that the sustained increase in award 

amounts and current spending patterns indicated that the challenges states have 

been encountering may be compounded year over year as future fiscal years come 

to a close and each state continues to receive additional funding. 

Because we did not identify any exceptions with NJ DLPS’s strategic planning 

process or funding plan, and we understand the numerous challenges states face in 

distributing VOCA funds, we took no exception with NJ DLPS’s subaward allocation 

plan. However, we are concerned about the challenges and risks associated with 

significant unobligated award balances. In our view, the slow rate in using funds, 

resulting in significant award balances at the end of award periods, increases the 

risk of both wasteful spending and states being required to return unspent funds 

that were not used to serve victims as intended. To address these risks, we 

recommend that OJP provide NJ DLPS with an appropriate level of technical 

assistance to facilitate and enhance the process used by NJ DLPS to effectively and 

efficiently award available funding commensurate with the ongoing needs of victims 

in New Jersey. 

Subaward Selection Process 

The VOCA Guidelines encourage SAAs to rely on open competition to award 

funds to subrecipients when feasible. The VOCA Guidelines require that SAAs 

maintain a documented methodology for selecting all competitive and non5 COVID-19 is a strain of coronavirus that was the cause of a worldwide outbreak of an 

infectious respiratory disease in 2020. 

6 U.S. Department of Justice (DOJ) Office of the Inspector General (OIG), Review of the Office 

of Justice Programs’ Efforts to Address Challenges in Administering the Crime Victims Fund Programs, 

Audit Report 19-34 (July 2019), https://oig.justice.gov/reports/2019/a1934.pdf#page=2, (accessed 

January 27, 2020), 10-17. 

7 The VOCA Guidelines limit eligible subrecipients to those that have demonstrated a record of 

effective direct services and receive at least 25 percent of the program’s funding from sources other 

than the Crime Victims Fund. 

6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

competitive subrecipients. To assess how NJ DLPS selected subrecipients and 

awarded CVF funds, we interviewed NJ DLPS officials and reviewed the state 

funding plan, subrecipient selection procedures, Notice of Available Funds (NOAF), 

public advertisements of NOAFs, and proposal scoring sheets.8 NJ DLPS relied on 

the Internal Policies and Procedures Manual as its documented methodology for 

both selecting subrecipients non-competitively and competitively for each of the 

years included in our audit scope. Overall, we found no exceptions with the process 

NJ DLPS used to select subrecipients. 

We determined that NJ DLPS had a deliberative process for determining 

which subrecipients would receive their awards through open competition. We 

reviewed NJ DLPS’s Internal Policies and Procedures Manual and found that it 

allowed NJ DLPS to award funds either competitively or non-competitively. NJ DLPS 

officials told us it awarded funds to county governments and state government 

components through a non-competitive process, while non-profit subrecipients were 

selected through open competition. NJ DLPS officials told us domestic violence and 

sexual assault victim advocacy services are provided through 21 county prosecutor 

offices and open completion was unfeasible because it could leave the counties that 

lost the competition with service gaps. Moreover, NJ DLPS officials told us that 

some programs, such as the state-wide victim notification hotline and prison-based 

victim services, are administered through the state and therefore open competition 

would also be unfeasible. NJ DLPS officials told us non-competitively selected 

subrecipients still must apply for funding in order to receive awards, and the NOAF 

is held annually with project periods ranging from 12 to 18 months.9 Last, 

according to NJ DLPS officials, non-profits provide victim services that are otherwise 

not provided by the state or county governments, such as legal assistance to 

victims, elder abuse victim services, underserved minority community victim 

services, and human trafficking victim services. According to NJ DLPS officials, 

non-profit subrecipients are awarded competitively because there could be multiple 

providers capable of providing the service. NJ DLPS officials told us a NOAF for 

non-profit subrecipients is held annually where winning subrecipients receive 

awards for 24-month project periods. Additionally, during our site visits, no 

subrecipient took exception with NJ DLPS process for awarding funds competitively or 

non-competitively based on whether the applicant was a unit of government or nonprofit organization. As a result, we take no exception because NJ DLPS relied on a 

deliberative process to determine which subrecipients would receive funds, either 

non-competitively or competitively. 

Based on our discussions with NJ DLPS officials and the review of NJ DLPS 

documentation, we found NJ DLPS’s award process had adequate separation of 

duties and provided adequate public notification of the opportunity to apply for 

VOCA funds. First, the NOAF was drafted by either the GDS manager or section 

chief and reviewed and approved by OAG’s legal affairs department prior to being 

advertised in the New Jersey Bulletin, as well as being posted to OAG’s website. 

8 Notice of Available of Funds (NOAF) is the term for the process that NJ DLPS relies on to 

publicize the availability of funds and select subrecipients from the applicants that respond to the 

NOAF. The NOAF process is otherwise indistinguishable from a Request for Proposal (RFP) process. 

9 The project periods of NJ DLPS’s subawards may overlap each other. 

7 
 

 

 

 

 

 

 

Additionally, we found that for the FY 2016 award, NJ DLPS officials held publicized 

pre-application conferences throughout the state to ensure that victim service 

organizations were provided with additional notification. Second, according to NJ 

DLPS officials, NJ DLPS’s applications were then received, date stamped, and 

tracked by the OAG acting administrator’s secretary. Third, based on NJ DLPS 

procedures, the competitive applications were then reviewed by a committee 

comprising NJ DLPS program component staff, non-program component NJ DLPS 

officials, and other New Jersey state employees familiar with scoring competitive 

grant applications. Fourth, the scored applications were reviewed and approved by 

the Section Chief. Last, the final scoring and selection of the applications was 

reviewed and approved by NJ DLPS’s Consolidated Grants Management Office for 

final approval. Based on our discussions with NJ DLPS officials, review of NJ DLPS 

procedures, and review of NOAF documentation, we found NJ DLPS’s implemented 

award process appeared to be adequately separated as there was no single point of 

control in the selection of subrecipients and available funding was adequately 

publicized. As a result, we took no exception with NJ DLPS subrecipient selection 

process. 

Subawarding Process 

The project period of the subgrant listed on the award document establishes 

the time period where subgrant funds may be expended to achieve the subgrant’s 

objectives. A prudent grantor awards funds to their subrecipients prior to the 

project period start date or shortly thereafter to ensure that the program can be 

fully implemented within the project period. During our site visits, we noted that 

three of the six subrecipients expressed concerns about NJ DLPS’s untimely 

awarding of funds. We found Subrecipient A was awarded funds more than 

6 months into its project period and had to delay purchasing a vehicle and other 

technical equipment necessary to improve the delivery of sexual assault services. 

We found Subrecipient E was awarded funds more than 7 months into its project 

period and had to resort to utilizing non-VOCA sources of funding to fund the VOCA 

program. In addition, Subrecipient F was awarded funds more than 9 months into 

its project period and had to draw upon a line of credit to fund VOCA subgrant 

activities. Because of these observations, we selected a sample of 17 subaward 

documents to evaluate whether NJ DLPS frequently awarded funds more than a 

month after the project period began. We determined that 15 of 17 subawards we 

reviewed were awarded more than 1 month after the subrecipient’s project period 

began. NJ DLPS officials told us it relies on eight program analysts to administer 

over 500 VOCA and non-VOCA subgrants, and NJ DLPS staff recognized that their 

workload was the greatest challenge in the oversight of VOCA subrecipients. 

Additionally, we observed no documented policies and procedures in place to 

prioritize the awarding of funds based on subrecipient financial need. When funds 

are not awarded in a timely manner, subrecipients face the risk of incomplete 

accomplishment of programmatic goals and objectives, and subrecipients are 

unduly burdened with finding alternate sources of funding to fund VOCA goals and 

objectives until funding is awarded. We recommend OJP ensure that NJ DLPS 

develops and implements policies and procedures that facilitate the timely awarding 

of VOCA funds. 

8 
 

 

 

 

 

 

 

 

 

 

 

 

Subaward Requirements 

SAAs are required to communicate VOCA requirements to their subrecipients. 

We reviewed documents provided to subaward recipients by NJ DLPS and found 

that the documents conveyed VOCA-specific award limitations, restrictions on the 

use of VOCA funds, and described the reporting requirements to subrecipients. In 

reviewing these documents, we found that NJ DLPS made its subrecipients aware of 

the requirement to follow the Uniform Guidance and VOCA victim assistance grant 

special conditions NJ DLPS received in its award documentation from OJP. We 

found that NJ DLPS satisfied the requirement to communicate VOCA requirements 

to its subrecipients. 

Program Requirements and Performance Reporting 

We reviewed NJ DLPS’s distribution of VOCA funding through subawards to 

determine whether funds were provided to local community-based organizations 

that serve crime victims or enhance crime victim services. We also reviewed NJ 

DLPS’s performance documents and measures that were used to track goals and 

objectives, as well as the OVC solicitations and award documents that established 

the special conditions governing NJ DLPS award activity. 

Based on our analysis, we believe that NJ DLPS: (1) fulfilled the distribution 

requirements to priority victim groups; however, the SAA is at risk of failing to 

comply with the requirement due to weak internal controls used to track actual 

allocation amounts; (2) did not implement adequate procedures to submit accurate 

annual performance reports; and (3) generally did comply with the remaining 

special conditions we tested. 

Priority Areas Funding Requirement 

VOCA Guidelines required that NJ DLPS award a minimum of 10 percent of 

total grant funds to programs that serve victims in four categories: (1) child 

abuse, (2) domestic abuse, (3) sexual assault, and (4) the previously underserved. 

The VOCA Guidelines give each SAA latitude for determining the method for 

identifying "previously underserved" crime victims.10 NJ DLPS, as part of its 

FY 2015 application for VOCA funds, submitted a Statement Regarding Preliminary 

Plan to Subgrant Funds that showed NJ DLPS identified its previously underserved 

victims as human trafficking victims, child victims, disabled victims, elderly 

victims, and culturally underrepresented victims, such as victims from the Hispanic 

and Southeast Asian communities. NJ DLPS officials, during our fieldwork, 

confirmed that the victims identified in its FY 2015 Statement Regarding 

Preliminary Plan to Subgrant Funds was accurate. We found that NJ DLPS relied 

on a statewide needs assessment to identify the abovementioned classes of 

victims as underserved and therefore we take no exception with the process NJ 

DLPS utilized because it was in accord with the VOCA Guidelines. 

10 Methods for identifying “previously underserved” victims may include public hearings, 

needs assessments, task forces, and meetings with statewide victim services agencies. 

9 
 

 

 

 

 

 

 

 

 

 

Based on our review of the priority funding allocations in the Performance 

Measurement Tool (PMT), we determined that NJ DLPS met the priority funding 

allocations for FYs 2014 and 2015, and was on track to satisfy the requirement for 

FYs 2016 and 2017. However, we found that procedures for tracking compliance 

with the requirement need improvement. Although NJ DLPS was able to 

demonstrate compliance with the requirement, it is at risk of failing to comply with 

requirements due to weak controls currently in place to track allocations. 

To assess whether NJ DLPS was on track to meet VOCA’s distribution 

requirements, we examined how NJ DLPS allocated subawards and tracked 

compliance with the priority area funding requirement. NJ DLPS officials were 

aware of the priority area funding requirement, and these officials confirmed that 

priority area categories were used to inform the allocation of funds. Yet, NJ DLPS 

officials did not know which NJ DLPS personnel were responsible for tracking 

compliance with the priority funding requirement after funds were awarded. 

Further, NJ DLPS officials told us that its accounting system did not assign unique 

codes to track each priority area category. Initially, we were told by NJ DLPS 

officials that, because priority funding areas were a data field within the PMT, the 

Research Manager was responsible for monitoring compliance as the Research 

Manager was the subrecipient point of contact for PMT. However, we interviewed 

the Research Manager and we were told they are not responsible for monitoring 

compliance and they were never asked to produce a report from the PMT system 

by NJ DLPS management. 

Ultimately, we found NJ DLPS compliance tracking was limited to the acting 

administrator’s secretary who recorded the class of victim an applicant intended to 

serve against the priority area category at the time the application was received. 

We found this process to be insufficient because it was based on budgets proposed 

by applicants rather than actual funds allocated and subawarded. We also found 

NJ DLPS lacked policies and procedures that specified the staff responsible for 

monitoring compliance and the frequency of review and what records were to be 

relied upon to monitor compliance. Moreover, we were told that staff turnover 

caused confusion as to the staff responsible for monitoring compliance. 

When SAA’s lack policies and procedures to assign staff responsibility for 

complying with and monitoring priority funding areas, SAAs risk failing to comply 

with the priority areas funding requirement. We recommend OJP ensure NJ DLPS 

develop and implement policies and procedures to monitor compliance with the 

priority area funding requirement. 

Annual Performance Reports 

Each SAA must annually report to the OVC the activities funded by any VOCA 

awards active during the fiscal year. These reports are to include the number of 

(1) agencies funded, (2) VOCA subawards, (3) victims served, and (4) victim services 

funded by VOCA victim assistance grants. OJP’s guidance states that the SAAs and 

subrecipients should prorate performance data if they cannot track grant-funded 

10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

activity separately.11 In FY 2016, the OVC also began requiring SAAs to submit 

quarterly performance data through its web-based PMT. With this system, SAAs 

may provide subrecipients direct access to report quarterly data for SAA review, 

although the OVC still requires that if the subrecipient completes the performance 

measure data entry directly, the SAA must approve the data. 

At the time of our fieldwork, NJ DLPS had submitted annual performance 

reports to OVC for FYs 2015 through 2018. We discussed with NJ DLPS officials 

how they compiled the performance report data from their subrecipients to 

complete the annual reports. According to a NJ DLPS official, subrecipients 

reported performance statistics directly into PMT and are required to submit an 

alternate quarterly state-defined performance report to NJ DLPS that have similar, 

although not identical, data fields to the fields captured in the PMT report. 

According to the NJ DLPS official, the Research Manager printed the statistics each 

subrecipient submits and provides it to the program analyst who adds the printout 

to the subgrant file. A NJ DLPS official told us that while it has this process in 

place, written procedures for the review of the PMT statistics and the staff 

responsible for the certification of the annual report in PMT were not documented. 

Additionally, NJ DLPS staff were unaware which staff member was responsible for 

certifying the annual performance report. Moreover, NJ DLPS, during its routine 

subgrant monitoring, desk reviews, or site visits, did not request supporting 

documentation to validate the completeness and accuracy of subrecipient 

submissions of quarterly reports. As a result, we believe NJ DLPS did not obtain 

reasonable assurance as to the completeness and accuracy of its PMT program 

performance reporting and lacked adequate internal controls to ensure performance 

reports were consistently prepared and reviewed. Therefore, we determined NJ 

DLPS’s annual reports may not be complete and accurate because no steps were 

taken to ensure the validity of the data used to prepare the reports. 

To determine whether the annual performance reports submitted by NJ DLPS 

accurately reflected the activity of the grants, we judgmentally tested performance 

statistics from the Annual Performance Reports by comparing the performance 

statistics to summary spreadsheets that NJ DLPS provided. Our testing covered the 

following reporting periods: October 1, 2014, through September 30, 2015; 

October 1, 2015, through September 30, 2016; October 1, 2016, through 

September 30, 2017; and October 1, 2017, through September 30, 2018. While 

we found the summary spreadsheets NJ DLPS provided reconciled to its FY 2017 

Annual Performance Report, the FY 2015, FY 2016, and FY 2018 Annual Performance 

Reports did not reconcile to the summary spreadsheets. NJ DLPS was unable to explain 

the variance between the spreadsheets provided and the PMT statistics. Further, 

we determined that the data in the summary spreadsheets was not always accurate 

or supportable based on the results of subrecipient testing as discussed below. 

11 Grant management personnel from the OVC’s State Compensation and Assistance Division 

(SCAD) confirmed it is the OVC’s expectation that performance reports capture only VOCA-funded 

activity. This is articulated in OJP’s PMT reference materials, and OJP officials stated that they have 

discussed prorating performance data through discussions with subrecipients, webinar trainings, and 

calls to the PMT Helpdesk. 

11 
 

 

 

 

 

 

 

 

 

 

 

To obtain additional assurance about the completeness and accuracy of NJ 

DLPS’s summary spreadsheets, we performed site visits at six subrecipients. As 

part of our fieldwork, we reconciled subrecipient performance statistics reported to 

OVC to source documents. In so doing, we found three of the six subrecipients we 

visited funded their subgrants with a combination of VOCA and non-VOCA sources 

and failed to prorate victim statistics based on the specific source of funding.12 We 

found at all six sites that supporting documentation provided by the subrecipient 

did not reconcile to the subrecipient’s PMT quarterly reporting. Additionally, we 

identified a subrecipient that reported VOCA-ineligible activity within its PMT 

reports. We also found NJ DLPS did not validate PMT reported subrecipient victim 

statistics during its site visits or other reviews, and that NJ DLPS did not have 

written policies or procedures to ensure the accuracy of data submitted in 

performance reports. Failure to ensure complete and accurate performance 

reporting undermines OVC’s ability to demonstrate the value and specific benefits of 

the program to government agencies, the victim services field, the general public, 

and other stakeholders. We recommend OJP ensure NJ DLPS develops and 

implements policies and procedures that ensure annual performance reports are 

complete and accurate, supported by verifiable data, and periodically validated as 

part of its monitoring process. 

Compliance with Special Conditions 

The special conditions of a federal grant award establish specific grant 

recipient requirements. We reviewed the special conditions for each VOCA victim 

assistance grant we audited and identified three that we deemed significant to 

grant performance that were not tested under any of the other areas we reviewed 

for compliance. We tested compliance with the special conditions imposed on NJ 

DLPS regarding: (1) attending the annual VOCA National Training Conference, 

(2) Federal Funding Accountability and Transparency Act of 2006 reporting of firsttier subawards of $25,000 or more, and (3) OJP financial management and grant 

administration training for Point of Contact and Financial Points of Contact. We 

found that NJ DLPS complied with all three of the special conditions we tested. 

Grant Financial Management 

Award recipients must establish an adequate accounting system and 

maintain financial records that accurately account for awarded funds. To assess the 

adequacy of NJ DLPS’s financial management of the VOCA grants, we reviewed the 

process NJ DLPS used to administer these funds by examining expenditures 

charged to the grants, subsequent drawdown (funding) requests, and resulting 

financial reports. To further evaluate NJ DLPS’s financial management of the VOCA 

grants, we also reviewed the State of New Jersey’s Single Audit Reports for FYs 

2017 and 2018 that specifically related to NJ DLPS. We found the FY 2017 and 

2018 Single Audit Reports identified no exceptions with NJ DLPS’s grant financial 

management. We also interviewed NJ DLPS personnel responsible for financial 

12 Our audit fieldwork at subrecipients is discussed in greater detail later in this report. 

12 
 

 

 

 

aspects of the grants, reviewed NJ DLPS written policies and procedures, inspected 

award documents, and reviewed financial records. 

In our overall assessment of grant financial management, we determined 

that NJ DLPS has an adequate financial management system in place, but NJ DLPS 

did not always use the system as it was designed to facilitate effective grant 

financial management. We found both unsupported and unallowable expenditures 

that were missed by NJ DLPS when it reviewed subrecipient expenses as part of its 

monitoring process. 

Grant Expenditures 

State administering agency victim assistance expenses fall into two 

overarching categories: (1) reimbursements to subrecipients – which constitute the 

vast majority of total expenses, and (2) administrative expenses – which are 

allowed to total up to 5 percent of each award. To determine whether costs 

charged to the awards were allowable, supported, and properly allocated in 

compliance with award requirements, we tested a sample of transactions from each 

of these categories by reviewing accounting records and verifying supporting 

documentation for select transactions. 

Subaward Expenditures 

Subrecipients request reimbursement payments from NJ DLPS via submitting 

a detailed cost statement along with supporting documentation for all expenditures 

on a monthly or quarterly basis. As of June 2019, we found that NJ DLPS paid a 

total of $86,467,357 to its subrecipients with the VOCA victim assistance program 

funds in the scope of our audit. 

To evaluate NJ DLPS’s financial controls over VOCA victim assistance grant 

expenditures, we reviewed a sample of subrecipient reimbursement transactions to 

determine whether the payments were accurate, allowable, and in accordance with 

the VOCA Guidelines. We judgmentally selected transactions submitted by the six 

subrecipients we visited. The transactions we reviewed included costs in the 

following categories: (1) personnel, (2) fringe benefits, (3) travel, 

(4) contracts/consultants, (5) supplies, (6) equipment, (7) training, and 

(8) miscellaneous operating costs. The majority of the costs in our sample 

represented subrecipient personnel and fringe benefits. Specifically, we sampled 

226 transactions totaling $825,442, and we found $75,334 in unsupported costs. 

Table 2 below lists the total reimbursement payments NJ DLPS made to the 

subrecipients, the amount of expenditures we sample tested, and the unsupported 

expenditures we identified for each subrecipient. 

13 
 

 

 

 

 

 

 

 

Table 2 

NJ DLPS Subrecipient Expenditures Tested and 

Unsupported Expenditures as of June 2019 

Subrecipient Organization 

Type 

Victim Service 

Type 

Total 

Payments 

Sample 

Total 

Unsupported 

Expenditures 

A County 

Government Victim Advocacy $ 2,096,006 $ 224,667 $ 0 

B University Sexual Assault 3,025,804 203,779 41,875 

C State 

Government 

Victim 

Notification and 

Forensic Nurse 

Examination 

6,217,016 66,874 0 

D County 

Government Victim Advocacy 1,569,829 206,621 0 

E Non-Profit Violent Crime 156,047 74,253 28,415 

F Non-Profit Human 

Trafficking 2,246,446 49,248 5,044 

Total: $ 15,311,148 $ 825,442 $ 75,334 

Source: NJ DLPS and Subrecipient Records 

We found NJ DLPS ranked subrecipients based on risk (discussed in further 

detail in the Monitoring of Subrecipients section of this report). Yet, regardless of a 

subrecipient’s assigned risk, NJ DLPS policy required that all subrecipients submit 

financial support for expenditures on the Detailed Cost Statement (DCS) as a 

condition of receiving reimbursement.13 However, during our review of six 

subrecipients, we found NJ DLPS often deviated from its established policy of 

reviewing all documentation supporting subrecipient DCS reimbursement requests. 

Throughout our audit, we were told there was lack of staff to review all the DCS 

expenditures claimed by subrecipients and submitted to NJ DLPS for 

reimbursement. 

In one instance, we found that NJ DLPS accepted Subrecipient B’s personnel 

policy and procedures as supporting documentation for reimbursement requests of 

personnel expenditures rather than timesheets or personnel activity records to 

support the actual payroll expenditures eligible for reimbursement. Officials at the 

subrecipient said that documentation to support the personnel costs would be, in its 

view, too voluminous to provide, so it instead only provided copies of its personnel 

policies and procedures which NJ DLPS accepted in lieu of documentation 

supporting the actual expenditures. As discussed earlier, NJ DLPS’s policy was to 

review all financial documentation that supports expenditures reported on a DCS, 

without exception. We found no evidence that NJ DLPS granted any subrecipient a 

waiver from having to provide supporting documentation in compliance with this 

requirement. We also found no evidence showing why NJ DLPS officials believed 

13 Detailed Cost Statements (DCS) are the reports NJ DLPS’s subrecipients submit to receive 

reimbursement. In order to receive reimbursement subrecipients are required to report their subgrant 

expenditures against subgrant approved budget categories and submit detailed financial 

documentation to support each expenditure. 

14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

these policies alone were sufficient to support the costs claimed. At the same 

subrecipient, we also found three unsupported non-personnel expenditure 

transactions totaling $41,875. According to the Financial Guide, subrecipient costs 

must be adequately supported to include verifiable source documentation. 

When performing fieldwork at Subrecipient C, we again found that NJ DLPS 

did not consistently require supporting documentation for much of the consultant 

expenditures that it reimbursed. According to the Financial Guide, consultant 

payments must be supported by time and effort reports. For the consultant 

expenditures that were reviewed, NJ DLPS accepted summary reports that did not 

appropriately detail time spent, and work performed by the consultant. While we 

do not cite any questioned costs for this subrecipient, because we found evidence of 

work being performed by the consultants, we also determined that NJ DLPS failed 

to hold the subrecipient accountable and allowed these instances of noncompliance 

to occur. 

For Subrecipient E, we found consultants were misclassified as employees in 

the budget approved by NJ DLPS. In Subrecipient E’s reimbursement requests, we 

found that supporting documentation did not accurately reflect work being 

performed by consultants, and the documentation did not meet requirements 

established in the Financial Guide. Further, according to NJ DLPS’s Procedure 

Manual, “Divisions shall reconcile all costs with the subrecipient's approved budget 

to ensure expenditures are reasonable, allowable, and accurate prior to authorizing 

reimbursements.” Our testing showed that NJ DLPS reimbursed Subrecipient E 

without reviewing the subrecipient’s approved budget, and Subrecipient E did not 

provide adequate supporting documentation. Additionally, victim assistance 

payments for expenses such as bus passes, identification card renewals, and 

clothes made by Subrecipient E were also not adequately supported. As a result, 

we identified $28,415 in unsupported expenditures. Finally, we found 

Subrecipient E charged training expenditures to the grant that were outside of the 

grant period. According to the Uniform Guidance and Financial Guide, subrecipients 

must spend the grant funds within the project period and the funds must be 

adequately supported. In this instance, because the amount was immaterial, we 

did not question the cost as unallowable but noted this as further evidence of NJ 

DLPS’s noncompliance with grant requirements. 

According to the Financial Guide, “if you are a non-federal entity that has 

never received a negotiated indirect cost rate, you may elect to charge a 

de minimis rate of 10 percent of modified total direct costs which may be used 

indefinitely. When using this method, cost must be consistently charged as either 

indirect or direct costs, but may not be double charged or inconsistently charged as 

both.” Subrecipient F was approved to use the 10 percent de minimis rate applied 

to total direct costs, minus rent. We found Subrecipient F also used an allocation 

rate to charge a number of expenses, including supplies, insurance, rent, utilities, 

information technology, and telephones, as direct costs. Subrecipient F officials 

stated that it applied a percentage amount to its budget as the source of its 

allocation percentage, but was not able to provide a specific method for how it 

allocated costs. Because Subrecipient F was unable to provide an allocation 

method, we are questioning $5,044 of allocated costs charged to the grants as 

15 
 

 

 

 

 

 

 

 

 

 

 

 

unsupported. In addition, as stated in the Financial Guide, if indirect costs are 

charged as indirect, the subrecipient cannot then use an allocation percentage and 

charge costs as direct. Because Subrecipient F also used an allocated rate to 

charge direct costs, we would consider these indirect costs. Therefore, we believe 

Subrecipient F may have charged the costs both as indirect with the de minimis 

indirect cost rate and as direct using an allocated cost rate. 

Overall, we found that it was NJ DLPS’s policy to review all expenditure 

documentation supporting subrecipient reimbursement requests. However, the 

issues we identified demonstrate that NJ DLPS did not always follow its policy. 

Specifically, we identified reimbursement requests that NJ DPLS approved despite 

containing costs that were not fully supported or not approved in the subrecipients 

budget with NJ DPLS. As a result, we recommend NJ DLPS develop and implement 

an effective and efficient method for testing subrecipient DCSs taking into 

consideration a subrecipient’s assigned risk rating and NJ DLPS staffing constraints 

to provide reasonable assurance expenditures are in compliance with laws, 

regulations, and provisions in the award. Additionally, based on the results of our 

subrecipient expenditure testing, we recommend that OJP remedy $75,334 in 

unsupported subrecipient costs. 

Administrative Expenditures 

State administering agencies may retain up to 5 percent of each VOCA grant 

to pay for the administration of its crime victim assistance program and for training. 

For the victim assistance grant program, we tested NJ DLPS’s compliance with the 

5 percent limit on the administrative category of expenses, as shown in Table 3. 

Table 3 

Administrative Expenditures as of June 2019 

Award Number Total Award 

Administrative 

Expenditures 

Charged 

Administrative 

Percentage based 

on Expenditures 

Charged 

2014-VA-GX-0032 $ 12,416,634 $ 620,831 5% 

2015-VA-GX-0021 53,992,667 2,111,799 4% 

2016-VA-GX-0072 60,868,131 472,760 1% 

2017-VA-GX-0058 50,279,830 0 0% 

Source: GMS and NJ Accounting Records 

We found that NJ DLPS did not exceed the 5 percent administrative expense 

limit. We compared the total administrative expenditures charged to the grants 

against the general ledger and determined that NJ DLPS complied with the limit. 

In addition to testing NJ DLPS’s compliance with the 5 percent administrative 

allowance, we also tested a sample of these administrative transactions. At the 

time of our review, NJ DLPS had not spent administrative funds for the 

16 
 

 

 

 

 

 

 

 

 

 

2017-VA-GX-0058 grant. We judgmentally selected one payroll transaction from 

the 2014-VA-GX-0032, 2015-VA-GX-0021, and the 2016-VA-GX-0072 grants. Each 

personnel transaction included 3 months of grant personnel and fringe benefit 

charges and these costs represented the majority of the administrative 

expenditures charged to the awards we reviewed. In reviewing the transactions, 

we found one exception where NJ DLPS overcharged the 2014-VA-GX-0032 grant 

by $4,762 in personnel and fringe benefit costs. NJ DLPS agreed with our 

assessment and reimbursed the CVF fund for the error by issuing a disbursement 

check to the Department. We did not identify any exceptions in the other awards 

we tested and believe this was a one-time administrative error and did not appear 

to be a systemic weakness in NJ DLPS’s program controls. 

In addition, we judgmentally selected 20 non-personnel and fringe benefit 

transactions from the 2014-VA-GX-0032, 2015-VA-GX-0021, and the 

2016-VA-GX-0072 grants. Our testing sample included (1) travel, 

(2) contracts/consultants, (3) supplies, and (4) training. We found no issues with 

the non-personnel administrative expenditures we tested. 

Drawdowns 

Award recipients should request funds based upon immediate disbursement 

or reimbursement needs, and the grantee should time drawdown requests to 

ensure that the federal cash on hand is the minimum needed for disbursements or 

reimbursements made immediately or within 10 days. VOCA grant funds are 

available for the fiscal year of the award plus 3 additional fiscal years. To assess 

whether the NJ DLPS managed grant receipts in accordance with these federal 

requirements, we compared the total amount reimbursed to the total expenditures 

in NJ DLPS’s accounting system and accompanying financial records. 

For the VOCA victim assistance awards, NJ DLPS calculated drawdown 

amounts sufficient to cover subrecipient reimbursement requests and state 

administration based on the general ledger on a quarterly basis. Table 4 shows the 

total amount drawn down for each grant as of April 2020. 

17 
 

 

 

 

 

 

 

 

Table 4 

Amount Drawn Down for Each Award as of April 2020 

Award Number Total Award 

Award 

Period 

End Date 

Amount Drawn 

Down 

Amount 

Remaining Disposition 

2014-VA-GX-0032 $ 12,416,634 9/30/2017 $ 12,083,057 $ 4,762 Returned and 

Deobligated* 

2015-VA-GX-0021 53,992,667 9/30/2018 53,992,667 0 Drawn down by 

12/31/2018 

2016-VA-GX-0072 60,868,131 9/30/2019 42,598,758 0 Deobligated** 

2017-VA-GX-0058 50,279,830 9/30/2020 2,502,373 47,777,457 Open award 

Total: $ 177,557,262 $ 111,176,855 $ 47,782,219 

*$328,814 was deobligated from grant 2014-VA-GX-0032. The difference reflects the $4,762 NJ DLPS 

reimbursed the Department on September 25, 2019 as discussed in the Administrative Expenditures 

section of the report. 

**$18,269,373 was deobligated from grant 2016-VA-GX-0072 in April 2020. 

Source: OJP Payment History Reports 

During this audit, we did not identify significant deficiencies related to the 

recipient’s process for developing drawdown requests. However, we identified 

deficiencies and questioned costs related to compliance of individual expenditures 

with grant rules. We address those deficiencies in the Grant Expenditures section 

in this report. 

Matching Requirement 

VOCA Guidelines require that subrecipients match 20 percent of their project 

costs. The purpose of this requirement is to increase the amount of resources 

available to VOCA projects, prompting subrecipients to obtain independent funding 

sources to help ensure future sustainability. Match contributions must come from 

non-federal sources and can be either cash or an in-kind match.14 The state 

administering agency has primary responsibility for ensuring subrecipient 

compliance with the match requirements. 

In the award documents, NJ DLPS noted to the subrecipients the matching 

funds requirement. In NJ DLPS’s VOCA Guidelines it stated, “VOCA regulations 

require that all applicants provide a 20 percent project match. The match may be 

cash or in-kind services. All matching funds are restricted to the same uses as 

subaward funds, must be expended within the subaward period, and are subject to 

audit. Matching funds must be provided from non-federal funds. The applicant 

must verify the funding source of proposed matching funds. Applicants are 

required to maintain documentation on activities related to the source of matching 

funds as well as subaward-related activities.” To review the provision of matching 

14 In-kind matches may include donations of expendable equipment, office supplies, workshop 

or classroom materials, workspace, or the value of time contributed by those providing integral 

services to the funded project. 

18 
 

 

 

 

 

 

 

 

 

 

 

funds, we reviewed matching fund supporting documentation and financial records 

during subrecipient site visits. We did not identify any issues related to matching 

costs at any of the subrecipients we visited. 

Financial Reporting 

According to the Financial Guide, recipients shall report the actual 

expenditures and unliquidated obligations incurred for the reporting period on each 

financial report as well as cumulative expenditures. To determine whether NJ DLPS 

submitted accurate Federal Financial Reports (FFR), we compared the four most 

recent reports to NJ DLPS’s accounting records the 2014-VA-GX-0032, 

2015-VA-GX-0021, and the 2016-VA-GX-0072 grants. At the time of our review, 

the FFRs for the 2017-VA-GX-0058 grant did not include any expenditures. 

We determined that quarterly and cumulative expenditures for the reports 

reviewed matched the accounting records for the 2014-VA-GX-0032 and the 

2016-VA-GX-0072 grants without exception. However, we were unable to match 

the accounting records for the quarterly and cumulative expenditures associated 

with the 2015-VA-GX-0021 grant. We brought this to the attention of NJ DLPS 

officials and were told the FFR reporting process and staff with assigned 

responsibility has changed from the time the 2015 grant FFRs were prepared. As a 

result of this change, we were assured that the accounting records match and the 

FFRs are now computed correctly. At the conclusion of the grant, the total 

expenditures in the accounting records matched the total FFR amount and we do 

not believe there is an issue with amounts recorded on the FFRs. 

Monitoring of Subrecipients 

According to the Financial Guide, the purpose of subrecipient monitoring is to 

ensure that subrecipients: (1) use grant funds for authorized purposes; (2) comply 

with federal program and grant requirements, laws, and regulations; and 

(3) achieve subaward performance goals. As the primary grant recipient, NJ DLPS 

was required to develop policies and procedures to monitor its subrecipients. To 

assess the adequacy of NJ DLPS’s monitoring of its VOCA subrecipients, we 

interviewed NJ DLPS personnel, reviewed NJ DLPS monitoring procedures, and 

obtained records of interactions between NJ DLPS and its subrecipients. As 

discussed previously, we also conducted site visits at six subrecipients that 

collectively received $21,051,012 of the $177,557,262, or about 12 percent of the 

total award amount of funds we audited. These subrecipients included two county 

governments, a state government component, a university, a non-profit directed 

toward serving victims of violent crime, and a state-wide human trafficking victim 

non-profit agency. Our site visits included interviewing personnel, touring facilities, 

and reviewing accounting and performance records. We spoke with subrecipient 

officials during each visit to determine the level of support they received from NJ 

DLPS. 

NJ DLPS’s subrecipient monitoring program included comprehensive financial 

and programmatic monitoring procedures, desk reviews, subrecipient risk 

assessments, and site visits where detailed testing of expenditures was performed. 

19 
 

 

 

 

 

 

 

 

 

 

 

 

As discussed previously, NJ DLPS’s on-going financial monitoring of its subrecipients 

was supplemented by OAG program analysts’ review of documentation that 

supported each subgrant and matching cost expenditure as a part of their review of 

Detailed Cost Statements and irrespective of the subrecipient’s level of risk. 

Despite the presence of robust monitoring procedures, we found financial 

non-compliance that should have been detected had the abovementioned procedure 

been effectively implemented. Specifically, we identified unsupported expenditures 

at three of the six subrecipients we visited. Additionally, we found subrecipient 

performance statistics were not validated for completeness and accuracy, and 

subrecipient site visits were not performed as frequently as the VOCA Guidelines 

and NJ DLPS’s internal procedure required. 

Financial Monitoring 

We found that NJ DLPS’s financial policies were not applied effectively or 

consistently to its subrecipients. According to the Financial Guide, the purpose of 

subrecipient monitoring is to provide reasonable assurance that subawards are 

being used for the authorized purpose, in compliance with the federal program and 

grant requirements, laws, and regulations, and the subaward performance goals 

are achieved. We found NJ DLPS had robust policies and procedures in place in 

order to ensure subrecipient compliance with award requirements. These policies 

included site visits where documentation that supported subrecipient VOCA 

expenditures was tested, as well as subrecipient desk reviews, and quarterly 

subrecipient reimbursement requests being reviewed for documentation that 

supported each expenditure included in reimbursement requests for all 

subrecipients. 

Despite having these financial monitoring procedures in place, we found that 

they were not always being followed or accomplished as intended. As a result of 

our detailed testing, we found NJ DLPS reimbursed Subrecipients B, E, and F 

$75,334 despite documentation that inadequately supported the costs claimed on 

their reimbursement requests We concluded NJ DLPS’s requirement that 

subrecipients provide detailed documentation that supports each expenditure was 

insufficient, as applied, to ensure compliance with award requirements because the 

policy was inconsistently applied. NJ DLPS officials told us that eight NJ DLPS 

program analysts were responsible for reviewing supporting documentation that 

supported each expenditure in each subrecipient reimbursement request in addition 

to conducting subrecipient site visits, reviewing and approving subrecipient budget 

proposals, reviewing state quarterly performance reports, approving subrecipient 

post-award requests, and making the award document. Moreover, the eight 

program analysts were responsible for performing the abovementioned tasks for 

over 500 VOCA and non-VOCA subgrants. Further, NJ DLPS staff members cited 

their workload as their biggest challenge in the oversight of the VOCA program. 

When personnel responsible for an internal control’s implementation are unable to 

effectively implement policies and procedures, the risk of non-compliance is greatly 

increased. We make a recommendation to address this issue in the Grant Financial 

Management Section of the report. 

20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Performance Monitoring 

During our audit, we found that NJ DLPS had internal control processes to 

measure subrecipient progress toward meeting VOCA-funded goals and objectives, 

but lacked adequate controls for validating subrecipient performance 

accomplishments. NJ DLPS officials told us that they monitor subrecipient 

performance through reviewing state quarterly reporting, PMT quarterly reporting, 

desk reviews, site visits, and on-going communication with the subrecipients. We 

found that NJ DLPS required its subrecipients to directly submit quarterly 

performance reports into the PMT system. We also found that NJ DLPS required 

subrecipients to submit an alternate quarterly performance report where 

subrecipients report progress toward achieving goals and objectives specified in the 

agreement executed between NJ DLPS and the subrecipient in a narrative format. 

An NJ DLPS official told us the review of subrecipient performance reporting 

consisted of reviewing the state performance report and including a printout of the 

PMT quarterly performance report to the audit file. However, NJ DLPS did not 

closely scrutinize the results of PMT reporting or have written procedures requiring 

program analysts to compare the required state reporting to the PMT reporting in 

order to detect significance discrepancies. Additionally, we found that NJ DLPS did 

not periodically request source documentation to validate PMT performance 

statistics during its review of subrecipient performance reports in PMT, or conduct 

validation testing of subrecipient reported PMT statistics during site visits or desk 

reviews, or at any other time. 

We assessed the completeness and accuracy of the performance data 

subrecipients reported in PMT during our site visits. Although subrecipients 

provided evidence that victim services were provided, we found: (1) supporting 

documentation did not reconcile to the statistics reported in PMT for any of the 6 

subrecipients, (2) Subrecipients B, D, and E did not prorate the reported statistics 

based on VOCA and non-VOCA sources of funding; and (3) Subrecipient D reported 

VOCA ineligible activity. 

Subrecipients are required to report accurately and retain documentation 

that supports their programmatic accomplishments. Our detailed testing found that 

none of the six subrecipients were able to provide supporting documentation that 

reconciled to their PMT reporting. The subrecipients were unable to explain the 

cause of the variances, and subrecipient officials confirmed to us that NJ DLPS 

never requested documentation to validate the statistics reported in PMT during site 

visits, desk reviews, or part of their review of quarterly performance reporting. 

While the variances were not significant, slight inaccuracies when aggregated 

among multiple subrecipients contribute to inaccurate annual performance reports 

at the state level. 

OJP guidance states that subrecipients should prorate the number of victims 

served based on the source of funding in order to correctly report the number of 

VOCA-funded victims a grant supports. Subrecipients B, E, and F funded the 

activities each reported to OJP with multiple sources of funding, and their reporting 

did not prorate the victims it served based on the source of funding. As a result of 

our testing, we found Subrecipient B, E, and F over-reported VOCA-funded activity 

21 
 

 

 

 

 

 

 

 

in PMT. Subrecipient officials told us they were unaware of the requirement to 

prorate victim statistics based on funding source. The NJ DLPS official with 

responsibility for PMT oversight was aware that OJP PMT’s guidance mandated 

subrecipients to prorate victims served based on source of funding. The NJ DLPS 

official told us that the PMT system itself informed subrecipients of the abovementioned requirement. The NJ DLPS official told us NJ DLPS did not provide all NJ 

DLPS subrecipients additional notification and guidance about the requirement. 

Subrecipient B, E, and F’s failure to prorate performance statistics potentially 

compromises the accuracy of the data NJ DLPS reports, and as a result, may 

misrepresent information used by Congress, OJP, and the public to assess the 

progress of VOCA-funded activities in New Jersey. 

VOCA Guidelines require that funding be used for direct victim services for 

crime victims. The VOCA Guidelines define a crime victim as “a person who has 

suffered physical, sexual, financial, or emotional harm as a result of the commission 

of a crime”. We found that Subrecipient E’s PMT reported statistics did not separate 

crime victims from individuals that received non-crime services, such as violence 

prevention and other general community services. In response to our testing, 

Subrecipient E provided documentation that demonstrated the number of VOCA 

funded victims it served also included individuals that did not experience 

victimization. A subrecipient official confirmed that Subrecipient E reported the 

total number of individuals it served in PMT regardless if they were victims of crime. 

We otherwise did not find the reporting of VOCA ineligible activity at any other 

subrecipient we visited. 

In sum, we found NJ DLPS’s performance monitoring to be inadequate 

because NJ DLPS did not attempt to validate the completeness and accuracy of 

subrecipient reporting. Our site visits showed that subrecipient statistics did not 

reconcile to source documentation and that Subrecipients B, E, and F did not 

prorate their victim statistics by funding source, and Subrecipient E reported 

ineligible VOCA activity. The above-mentioned examples of non-compliance 

underscore the importance of validating performance statistics, and the risk of 

subrecipient non-compliance is greatly increased. We make a recommendation to 

address this issue in the Program Requirements and Performance Reporting 

Section. 

Subrecipient Risk Assessment 

VOCA Guidelines require that a State Administering Agency’s subrecipient 

monitoring plan includes a risk assessment plan. In order to implement the VOCA 

monitoring requirements, NJ DLPS relied on its Grant Subrecipient Monitoring 

Standard Operating Procedures which require the use of a three-tiered risk 

classification system to determine the level of program monitoring for individual 

subrecipients. According to NJ DLPS’s policy, all subrecipients are assigned a risk 

rating at the time an award is made with the caveat that the risk-level can be 

modified based on the results of NJ DLPS’s review of the subrecipient’s 

programmatic and financial reporting, as well as on-going communication with the 

subrecipient. The risk assessment methodology applied by NJ DLPS factors the 

amount of the award, the number of open subawards with the NJ DLPS, the 

22 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

agency's prior experience, staff turnover, project complexity, timely reporting of 

programmatic activities and expenditures, and previous monitoring results. All of 

these collective factors are assigned a weighted numerical value that enables NJ 

DLPS to rank subrecipients based on the overall level of risk. NJ DLPS relies on the 

annual risk assessments to prioritize which subrecipients will receive site visits first 

within its monitoring plan. We found NJ DLPS was performing pre-award risk 

assessments for its subrecipients and complying with the VOCA Guidelines. While 

we found NJ DLPS ranked subrecipients based on risk, NJ DLPS’ policy required that 

subrecipients submit all financial documentation that supported expenditures on the 

DCS as a condition of receiving reimbursement regardless of a subrecipient’s 

assigned risk. According to the Financial Guide, subrecipients may be evaluated as 

higher risk or lower risk to determine the need for closer monitoring. Generally, 

new subrecipients require closer monitoring. For existing subrecipients, closer 

monitoring may be warranted based on results noted during monitoring and 

subrecipient reviews and audits. The purpose of these monitoring activities is to 

provide reasonable assurance that the subrecipient has administered the passthrough funding in compliance with the laws, regulations, and the provisions of the 

award and that the required performance goals are being achieved. We make a 

recommendation to address this issue in the Grant Financial Management Section of 

the report. 

Subrecipient Site Visits 

VOCA Guidelines advise that SAAs conduct subrecipient site visits once every 

2 years unless a different frequency, based on risk assessment, is set out in the 

monitoring plan. NJ DLPS’s monitoring schedule indicated that NJ DLPS’s goal was 

to perform site visits at least once every 2 years. NJ DLPS officials confirmed that 

the expectation was to conduct a site visit for each subrecipient every 2 years. To 

assess NJ DLPS’s compliance, we reviewed documentation provided that listed the 

monitoring activities performed for each subrecipient. We found that while NJ DLPS 

did conduct site visits, NJ DLPS did not conduct a site visit for each subrecipient 

every 2 years as advised by the VOCA Guidelines and its own procedure. Specifically, 

we found NJ DLPS did not conduct site visits or desk reviews of 58 subrecipients 

within 2 years of the date of the last site visit. Additionally, we found seven 

subrecipients where NJ DLPS documented the purpose of the site visit was to 

monitor a non-VOCA subgrant when the subrecipient received VOCA and non-VOCA 

subgrants from NJ DLPS. NJ DLPS staff told us that they have insufficient personnel 

to conduct site visits for each subrecipient every 2 years and, therefore, place a 

greater priority on reviewing the documentation that supports each DCS as its 

method of gauging subrecipient fiscal compliance. When subrecipients are not 

given timely site visits where detailed testing is performed to assess the validity of 

financial and programmatic documentation, the risk of subrecipient non-compliance 

with VOCA terms and conditions is increased. We recommend OJP ensure that NJ 

DLPS enhances its procedures to ensure that subrecipient site-visits are conducted 

in accordance with VOCA Guidelines and its own procedures. 

23 
 

 

 

 

CONCLUSION AND RECOMMENDATIONS 

Overall, while we found that NJ DLPS used its grant funds to enhance 

services for crime victims. Our audit also identified deficiencies in several key areas 

that represent opportunities for improvement. Specifically, NJ DLPS lacked written 

procedures to monitor compliance with the priority area funding requirement, 

inaccurately reported its performance statistics, did not validate subrecipient 

performance reporting, did not adequately monitor subrecipients in accord with 

VOCA Guidelines and its own policies, and was untimely in awarding of award funds 

to subrecipients. 

With respect to grant financial management, NJ DLPS did not rely on an 

efficient and effective method for testing detailed cost statements which contributed 

to our audit identifying $75,334 in unsupported subrecipient costs. 

We recommend that OJP: 

1. Provide NJ DLPS with an appropriate level of technical assistance to facilitate 

and enhance the process used by NJ DLPS to effectively and efficiently award 

available funding commensurate with the ongoing needs of NJ victims. 

2. Ensure that NJ DLPS develops and implements policies and procedures that 

facilitate the timely awarding of VOCA funds. 

3. Ensure NJ DLPS develops and implements policies and procedures to monitor 

compliance with the priority area funding requirement. 

4. Ensure NJ DLPS develops and implements policies and procedures that 

ensure annual performance reports are complete and accurate, supported by 

verifiable data, and periodically validated as part of its monitoring process. 

5. Ensure NJ DLPS develops an effective and efficient method for testing 

subrecipient detailed cost summaries to provide reasonable assurance the 

funds are in compliance with laws, regulations, and provisions in the award. 

6. Remedy $75,334 in unsupported subrecipient costs. 

7. Ensure that NJ DLPS enhances its policies and procedures to ensure that 

subrecipient site-visits are conducted in accordance with VOCA Guidelines 

and its own procedures. 

24 
 

 

 

 

 

 

 

 

APPENDIX 1 

OBJECTIVE, SCOPE, AND METHODOLOGY 

Objective 

The objective of the audit was to evaluate how NJ DLPS designed and 

implemented its crime victim assistance program. To accomplish this objective, we 

assessed performance in the following areas of grant management: (1) grant 

program planning and execution, (2) program requirements and performance 

reporting, (3) grant financial management, and (4) monitoring of subrecipients. 

Scope and Methodology 

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objective. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objective. 

This was an audit of Victims of Crime Act (VOCA) victim assistance formula 

grants 2014-VA-GX-0032, 2015-VA-GX-0021, 2016-VA-GX-0072, and 2017-VA-GX0058 from the Crime Victims Fund (CVF) awarded to NJ DLPS. The Office of Justice 

Programs (OJP), Office for Victims of Crime (OVC) awarded these grants totaling 

$177,557,262 to NJ DLPS, which serves as the state administering agency. Our 

audit concentrated on, but was not limited to, the period of October 1, 2013, the 

project start date for VOCA assistance grant number 2014-VA-GX-0020, through 

January 2020. As of April 2020, NJ DLPS had drawn down a total of $111,176,855 

from the four audited grants. 

To accomplish our objective, we tested compliance with what we consider the 

most important conditions of NJ DLPS’s activities related to the audited grants. We 

performed sample-based audit testing for administrative and subrecipient 

expenditures, financial reports, and performance reports. In this effort, we 

employed a judgmental sampling design to obtain broad exposure to numerous 

facets of the grants reviewed. This non-statistical sample design did not allow 

projection of the test results to the universe from which the samples were selected. 

The authorizing VOCA legislation, the VOCA victim assistance program guidelines, 

the OJP and DOJ Financial Guides, and the award documents contain the primary 

criteria we applied during the audit. 

During our audit, we obtained information from OJP’s Grants Management 

System and Performance Measurement Tool, as well as NJ DLPS’s accounting 

system specific to the management of DOJ funds during the audit period. We did 

not test the reliability of those systems as a whole; therefore, any findings 

identified involving information from those systems was verified with documents 

from other sources and site visits of six subrecipients. 

25 
 

 

While our audit did not assess NJ DLPS’s overall system of internal controls, 

we did review the internal controls of NJ DLPS’s financial management system 

specific to the management of funds for each VOCA grant within our review. To 

determine whether NJ DLPS adequately managed the VOCA funds we audited, we 

conducted interviews with NJ DLPS’s financial staff, examined policies and 

procedures, and reviewed grant documentation and financial records. We also 

developed an understanding of NJ DLPS’s financial management system and its 

policies and procedures to assess its risk of non-compliance with laws, regulations, 

guidelines, and terms and conditions of the grants. 

26 
 

 

 

 

APPENDIX 2 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

Description Amount Page 

Questioned Costs15 

Unsupported Costs 

Unsupported Subrecipient Costs $75,334 14 

Total Unsupported Costs $75,334 

Total Questioned Costs $75,334 

15 Questioned Costs are expenditures that do not comply with legal, regulatory, or 

contractual requirements; are not supported by adequate documentation at the time of the audit; or 

are unnecessary or unreasonable. Questioned costs may be remedied by offset, waiver, recovery of 

funds, the provision of supporting documentation, or contract ratification, where appropriate. 

27 
APPENDIX 3 

NEW JERSEY DEPARTMENT OF LAW AND PUBLIC SAFETY 

RESPONSE TO THE DRAFT AUDIT REPORT 

State of New Jersey 

DIVISION OF ADMINISTRATION 

D MURPHY DEPARTMENT OF LAW AND PUBLIC SAFETY GURBIR S. GREWAL 

Governor PO BOX OSI Allorney General 

TRENTON, NJ 08625-0081 

SHEILA Y. OLIVER WILLIAM H. CRANFORD 

Lt. Gow1rr1or AclingAdmini.slrator 

June 25, 2020 

TI1omas 0. Puerzer 

Regional Audit Manager 

Philadelphia Regional Audit Office 

Office of the Inspector General 

U.S. Department of Justice 

701 Market Street, Suite 2300 

Philadelphia, PA 19106 

VIA: Electronic Mail at: l11omas.O.Puerzer@usdoj.gov 

Re: Audit of the Office of Justice Programs Victim Assistance Grants Awarded to the New Jersey 

Department of Law and Public Safety, Trenton, New Jersey 

Dear Mr. Puerzer, 

We appreciate the opportm1ity to respond to the Office of the Inspector General (OIG) 2019 audit of the New 

Jersey Department of Law and Public Safety (the Department), Victims of Crime Act (VOCA) Victim 

Assistance Program. 1l1e Depai1ment recognizes and respects the role of the OIG, and has taken this audit as 

an opportunity to improve our grant management and administration as a whole, with emphasis on the areas 

recommended in the report. We appreciate the dedication and insight the OIG staff has shown during this 

review process, and we look forward to continuing the professional relationship we have developed. 

OIG has respectfully requested our comments on each of the recommendations in the report. It has been asked 

that our comments indicate concun-ence or non-concun-ence with each recommendation, completed and/or 

anticipated planned actions to address each recommendation, accompanied by related timeframes, and/or 

supporting documentation, as applicable. 

In the enclosed response, we have included the summary recommendation from the Onsite Review, our plan 

to comply with the recommendation, and our timeline to implement the changes staled. 

New Jersey is <DI Equal Oppcn1unity Employer · Prinled 011 Recycled Paper and Rec,~la.ble 

28 
Provide NJ DLPS with an appropriate lewd of teclmical assistance to fadlitate mul enlumce the 

process used by NJ DLPS to effectil1ely and efjicie11tly award a11ailable fimdi11g commensurate with the 

011goi11g needs of NJ victims. 

We concur with this recommendation. With the significant increases in VOCA funding, New Jersey (the 

State) recognizes the need for a dedicated leadership position to streni:,rthen the handliJ1g of victim services. In 

February 2019, the Department atmounced the hiring of a Special Advisor for Victim Services as part of the 

Department's Executive Staff to, among other things, coordinate the Depa1tment's victim resources, conduct 

a review of the State's victim programs and services, and identify ways to increase and strengthen those 

services. As part of this initiative, the advisor continues to work with the State's VOCA grant stakeholders to 

streamline existing processes in order lo best serve the needs of our crime victims. 1hrough these efforts, the 

advisor has proposed and implemented recommendations within the Department that have improved existing 

services and strengthened the Department's effort to award available funding commensurate with the ongoing 

needs of our victims. To effectuate tl1e advisor's work, the grant staff needs to be increased, as outlined in 

responses below. 

In addition, the Department has recently completed a restructuring within what is now known as the Division 

of Administration, which included the creation of a standalone Grants Unit (previously a component of the 

Budget Unit) and completed a job posting for a Grants Director to lead that unit. 111e Department anticipates 

filling the Grants Director position by the end of 2020. The restructuring also created the position of Chief 

Ethics and Compliance Officer, a standalone section independent of the Grants Unit that allows for a dedicated 

and independent review and monitoring of compliance matters, including those involving grants. 

2. Ensure that NJ DLPS de11elops and implements policies and procedures that facilitate the timely 

awarding of VOCA fimds. 

We partially concur with this recommendation. The Department is dedicated lo following all applicable state 

and VOCA compliance requirements, and it is our policy lo not execute subaward contracts until all applicable 

award package documents are complete, submitted, and reviewed by the Department. While this practice may 

lead to sub-award contracts being executed after the commencement of the grant perfonnance period, this 

practice also mitigates the risk of ineligible agencies receiving VOCA funds and ensures that budgets 

submitted by eligible entities contain allowable costs and are aligned with the purpose of the subgrant 

program. However, the Department does recognize the need for additional grant staff lo ensure efficient grant 

management and the timely awarding ofVOCA funds. We have already begun the process to fill vacant grant 

analyst positions and intend to add staff in the Grants Compliance Unit. Once the additional staff is in place, 

we expect to develop and implement updated procedures in order to expedite our internal grant review process 

and facilitate tl1e timely awarding ofVOCA funds. 

3. Ensure NJ DLPS tlewdops a11tl implements policies a,ul proce1lures to monitor complia11ce wit/, the 

priority areafimding re1111ireme11t. 

We concur with this recommendation. 111e Department is reviewing the grants policies and procedures in 

order to more efficiently monitor compliance with the priority area funding requirement. Once the updated 

policies have been approved, the Department will provide them to the Office of Justice Programs (OJP). 

Within the last several months, the Grants Compliance Unit has been coordinating priority area compliance 

monitoring directly with the Perfonnance Measurement Tool (PMT) Research Manager on a quarterly basis. 

29 
Enmre NJ DLPS tlevelops a11d impleme11ts policies and proce1/ures that ensure anmwl performance 

reports are complete a11d acc11rate, s11pported by 1•erifiable data, and periodically 11alidated as part of 

monitoring process. 

We concur with this recommendation. The Department will draft written policies and procedures as stated in 

the recommendation. After the OIG Site Visit, the Grants Compliance Unit added monitoring of PMT source 

documents to the Depaitment's Monitoring Site Visit Checklist and began to sample and verify subrecipient 

PMT data of VOCA subrecipients. 

5. Enmre NJ DLPS develops a11 effective and efficient method for testu1g subrecipie11t detailed cost 

s11mmaries to provide reaso11able assunmce thefimds are ill compliance with laws, reg11latio11s, a11d 

provisio11s i11 the award. 

We partially concur with this recommendation. TI1e Depa1tment's current policy requiring the review of all 

financial documentation that supports expenditures reported on a detailed cost statement (DCS), has remained 

in place due to limited staff available to conduct monitoring. 11,e Department does agree that our current 

reimbursement policy calls for review and update, as we are aware that the policy is time-consuming at1d may 

lead to delays in payment processing. Since the OIG Site Visit, and as stated above, the State has been 

working to fill grant analyst positions. Once trained, these new analysts are expected take on their share of 

grants in order to ensure proper grants management and a more efficient grant caseload per analyst. In addition 

to the restructuring referenced above, the Department also plans to increase staffing i11 the Grants Compliance 

Unit in order to better navigate the varied State and Federal grant compliance requirements, including the 

required VOCA monitoring. Once fully staffed, the Department plans to revise the ctment reimbursement 

policy to allow for a more risk-based approach as to the amount and frequency of source documentation 

required at the time of grant reimbursement. 

6. Remedy $75,334 in unsupported subrecipient costs. 

We pa1tially concur with this recommendation. In order to accurately determine if the Depa1tment 

inappropriately reimbursed subrecipient costs, the Department is working with OIG to obtain the details of 

the unsupported costs in question. Once the Department can verify our internal documentation of these cosL5, 

the Depru1ment will work with the subrecipients mentioned in the audit report to compile the necessary 

documentation to support the $75,334 in unsupported costs. 17,e Department will repay any amount where 

that infom1ation is not available. 

7. Ensure that NJ DLPS &1/rnnces its polici~· mul procedures to ensure that subrecipient site-1•isits are 

co11d11cted i11 accord with VOCA Guidelines aml its ow11 proced11res. 

We concur with this recommendation. The Department recognizes the need to conduct subrecipient site-visits 

in accordance with VOCA Guidelines and internal procedures. 1l1e Department is planning to increase 

staffmg to ensure that there are sufficient resources in place to successfully perfonn subrecipient monitoring 

policies and procedures. 

Co11clusfo11 

Given the extent of the work required to comply with these recommendations, it may take twelve months or 

more to complete these recommendations. We look forward to updating OIG and OJP on our progress. 

Should you have any questions, or require farther infonnation, please feel free to contact me. 

30 
ly, 

w~ II ~tYJ 

William H. Cranford 

Acting Administrator 

C: Jonathan Garelick, Acting Chief of Staff, Office of the Attorney General 

Elizabeth Ruebman, Special Advisor for Victim Services 

Christina Broderick, Special Assistant to the Attorney General 

Kristen Sleeper, Director, Budget and Grant Operations, Office of the Attorney General 

Julie Malik, Deputy Director, Budget and Grant Operations, Office of the Attorney General 

Kelly Ottobre, Grants Manager, Office of the Attorney General 

Kristen Ramsay, Subrecipient Monitoring/Grant Compliance, Office of the Attorney General 

Kathlyn Bender, Internal Controls, Office of the Attorney General 

Linda J. Taylor, Lead Auditor, Office of Audit, Office of Justice Programs, 

VIA: Electronic Mail at: Linda.Taylor2@mdoj.gov 

31 
APPENDIX 4 

U.S. DEPARTMENT OF JUSTICE OFFICE OF JUSTICE PROGRAMS 

RESPONSE TO THE DRAFT AUDIT REPORT 

U.S. Department of Justice 

Office o.f Justice Programs 

Office of Audit, Assessment, and Management 

Washi11gton. D.C. 20531 

June 26, 2020 

MEMORANDUM TO: ·n1omas 0 . Puerzer 

Regional Audit Manager 

Philadelphia Regional Audit Office 

Office of the Inspector General 

FROM: Ralph E. Mrutin ,l),,,~,,,.J . Director , ------r,-~ 

SUBJECT: Response to the Draft Audit Repo1t, Audit of the Office of Justice 

Programs, Victim Assistance Grants A warded to the New Jersey 

Department of Law and Public Safety, Trenton, New Jersey 

This memorandum is in reference to your coJTespondence, dated May 11, 2020, transmitting the 

above-referenced draft audit report for the New Jersey Department of Law and Public Safety 

(NJ DLPS). We consider the subject repo1t resolved and request written acceptance of this 

action from your office. 

TI1e draft report contains seven recommendations and $75,334 in questioned costs. TI1e 

following is Office of Justice Programs' (OJP) analysis of the draft audit report 

recommendations. For ease of review, the recommendations are restated in bold ru1d are 

followed by our response. 

l. We recommend that OJP provide NJ DLPS with an appropriate level of technical 

assistance to facilitate and enhance the process used by NJ DLPS to effectively and 

efficiently award available funding commensumte with the ongoing needs of NJ 

victims. 

OJP agrees with this recommendation. We will coordinate with NJ DLPS to obtain a 

copy of their written policies and procedures, developed and implemented, to enhance its 

process of effectively and efficiently awarding available Victims of Crime Act (VOCA) 

funding commensurate with the ongoing needs of New Jersey victims; and will provide 

technical assistance, as appropriate. 

32 
We recommend that OJP ensure that NJ DLPS develops and implements policies 

and procedures that. facilitate the timely awal'lling of VOCA fm1ds. 

OJP agrees with this recommendation. We will coordinate with NJ DLPS to obtain a 

copy of its written policies and procedures, developed and implemented, to ensure the 

timely awarding ofVOCA funds. 

3. We recommend that OJP ensure NJ DLPS develops and implements policies and 

procedures to monitor compliance with the p1iority area fwuling requirement. 

OJP agrees with this recommendation. We will coordinate with NJ DLPS to obtain a 

copy of its written policies and procedures, developed and implemented, to ensure proper 

monitoring of compliance with the priority area fonding requirement. 

4. We reconunend tbat OJP ensure NJ DLPS develops and implements policies and 

procedures that ensure annual performance repor1s are complete and accurate, 

supp01ted by verifiable data, and pe1iodically validated as part of its monit01ing 

process. 

OJP a!,>rees with this recommendation. We will coordinate with NJ DLPS to obtain a 

copy of its written policies and procedures, developed and implemented, to ensure that 

annual perfonnance reports are complete and accurate, supported by verifiable data, and 

periodically validated as part of its monitoring process; and the supporting documentation 

is maintained for future auditing purposes. 

5. We reconunend that OJP ensure NJ DLPS develops an effective and efficient 

method for testing sub recipient detailed cost summaries to provide reasonable 

assurance the funds are in compliance with laws, regulations, and provisions in the 

award. 

OJP agrees with this recommendation. We will coordinate with NJ DLPS to obtain a 

copy of its written policies and procedures, developed and implemented, to ensure an 

effective and efficient method for testing subrecipient detailed cost summaries is used, to 

ensure that the funds are expended in compliance with the laws, regulations, and 

provisions of its Federal awards. 

6. We reconunend that O.JP remedy $75,334 in unsupported subrecipient costs. 

OJP agrees with this recommendation. We will review the $75,334 in unsupported 

questioned costs, charged to Grant Numbers 2014-V A-GX-0032, 2015-VA-GX-0021, 

2016-VA-GX-0072, and 2017-VA-GX-0058, and will work with NJ DLPS to remedy, as 

appropriate. 

2 

33 
We recommend that OJP ensure that NJ DLPS enhances its policies and procedures 

to ensure that. subl'Ccipient site-,isits are conduct.ed in accordance with VOCA 

Guidelines and its own procedures. 

OJP agrees with this recommendation. We will coordinate with NJ DLPS to obtain a 

copy of its written policies and procedures, developed and implemented, to ensure that 

subrecipient site-visits are conducted in accordance with YOCA Guidelines and it~ own 

procedures. 

We appreciate the opportunity to review and comment on the draft audit report. lfyou have any 

questions or require additional infomiation, please contact Jeffery A. Haley, Deputy Director, 

Audit and Review Division, on (202) 616-2936. 

cc: Katharine T. Sullivan 

Principal Deputy Assistant Attorney General 

Maureen A. Henneberg 

Deputy Assistant Attorney General 

for Operations and Management 

LeToya A. Johnson 

Senior Advisor 

Office of the Assistant Attorney General 

Jeffery A. Haley 

Deputy Director, Audit and Review Division 

Office of Audit, Assessment, and Management 

Jessica E. Hart 

Director 

Office for Victims of Crime 

Bill Woolf 

Senior Advisor 

Office for Victims of Crime 

Katherine Darke-Schmitt 

Deputy Director 

Office for Victims of Crime 

Kathrina S. Peterson 

Acting Deputy Director 

Office for Victims of Crime 

James Simonson 

Associate Director for Operations 

Office for Victims of Crime 

3 

34 
Ramesa Pitts 

Grants Management Specialist 

Oflice for Victims of Crime 

Charlotte Grzebien 

Deputy General Counsel 

Silas V. Darden 

Director 

Office of Communications 

Leigh A. Benda 

Chief Financial Officer 

Christal McNeil-\:\fright 

Associate Chief Financial Officer 

Grants Financial Management Division 

Office of the Chief Financial Officer 

Joanne M. Suttington 

Associate Chief Financial Officer 

Finance, Accounting, and Analysis Division 

Office of the Chief Financial Officer 

Aida Brumme 

Manager, Evaluation and Oversight Branch 

Grants Financial Management Division 

Office of the Chief Financial Officer 

Louise Duhamel 

Acting Assistant Director, Audit Liaison Group 

Internal Review and Evaluation Office 

Justice Management Division 

OJP Executive Secretariat 

Control Number IT20200512094826 

4 

35 
 

 

 

 

 

 

 

 

 

 

APPENDIX 5 

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT 

The OIG provided a draft of this audit report to the Office of Justice Programs 

(OJP) and the New Jersey Department of Law and Public Service (NJ DLPS). NJ DLPS’s 

response is incorporated in Appendix 3 and OJP’s response in Appendix 4 of this 

final report. NJ DLPS generally concurred with all our recommendations. NJ DLPS 

partially concurred with recommendations 2, 5, and 6, but in its response, NJ DLPS 

agreed to take corrective action consistent with the recommendations in the report. 

In its response, OJP agreed with all our recommendations and discussed the actions 

it plans to complete to address the recommendations. As a result, the status of the 

audit report is resolved. The following provides the OIG analysis of the responses 

and a summary of the actions necessary to close the report. 

Recommendations for OJP: 

1. Provide NJ DLPS with an appropriate level of technical assistance to 

facilitate and enhance the process used by NJ DLPS to effectively and 

efficiently award available funding commensurate with the ongoing 

needs of NJ victims. 

Resolved. OJP agreed with our recommendation. OJP stated in its response 

that it will coordinate with NJ DLPS to obtain a copy of their written policies 

and procedures and will provide technical assistance, as appropriate. 

NJ DLPS concurred with this recommendation. In its response, NJ DLPS said 

that in February 2019 it hired a Special Advisor for Victim Services to 

coordinate the Department’s victim resources, conduct a review of the State’s 

victim programs and services, and identify ways to increase and strengthen 

services as well as streamline existing processes. NJ DLPS acknowledged it 

needed to increase the amount of grant staff to effectuate the Special 

Advisor’s work. Additionally, NJ DLPS maintained that it completed a 

restructuring that has made a stand-alone Grants Unit and is in the process of 

hiring a Grants Director. NJ DLPS also said it created a Chief Ethics and 

Compliance Officer position, independent from the Grants Unit, that is 

responsible for the independent review of grant compliance, among other 

responsibilities. 

This recommendation can be closed when we receive documentation 

demonstrating NJ DLPS has been provided an appropriate level of technical 

assistance to facilitate and enhance the processes used to effectively and 

efficiently award available funding commensurate with the ongoing need of 

victims. 

36 
 

 

 

 

 

 

 

 

 

 

 

 

 

2. Ensure that NJ DLPS develops and implements policies and 

procedures that facilitate the timely awarding of VOCA funds. 

Resolved. OJP agreed with our recommendation. OJP stated in its response 

that it will coordinate with NJ DLPS to obtain a copy of its written policies and 

procedures, developed and implemented, to ensure the timely awarding of 

VOCA funds. 

NJ DLPS partially concurred with our recommendation. In its response, NJ 

DLPS maintained that its policy was not to execute subaward contracts until 

all applicable award package documents were complete, submitted, and 

reviewed. However, NJ DLPS stated it recognizes the need for additional 

grant staff to ensure efficient grant management and the timely awarding of 

VOCA funds. NJ DLPS acknowledged it is in the process of filing vacant grant 

analyst positions and intends to add staff in the Grant Compliance Unit. NJ 

DLPS further stated that once staff are in place, it will develop and 

implement policies and procedures that facilitate the timely awarding of 

VOCA funds. 

This recommendation can be closed when we receive documentation 

demonstrating NJ DLPS has developed and implemented policies and 

procedures that facilitate the timely awarding of VOCA funds. 

3. Ensure NJ DLPS develops and implements policies and procedures to 

monitor compliance with the priority area funding requirement. 

Resolved. OJP agreed with our recommendation. OJP stated in its response 

that it will coordinate with NJ DLPS to obtain a copy of its written policies and 

procedures, developed and implemented, to ensure proper monitoring of 

compliance with the priority area funding requirement. 

NJ DLPS concurred with our recommendation. In its response, NJ DLPS 

stated that it is in the process of reviewing and updating its grant policies 

and procedures to more efficiently monitor compliance with the priority area 

funding requirement. NJ DLPS also said that in the last few months, the 

Grants Compliance Unit has been coordinating priority area compliance 

monitoring directly with the Performance Measurement Tool (PMT) Research 

Manager on a quarterly basis. 

This recommendation can be closed when we receive documentation 

demonstrating NJ DLPS has developed and implemented policies and 

procedures to monitor compliance with the priority area funding requirement. 

4. Ensure NJ DLPS develops and implements policies and procedures 

that ensure annual performance reports are complete and accurate, 

supported by verifiable data, and periodically validated as part of its 

monitoring process. 

Resolved. OJP agreed with our recommendation. OJP stated in its response 

that it will coordinate with NJ DLPS to obtain a copy of its written policies and 

37 
 

 

 

 

 

 

 

 

 

procedures, developed and implemented, to ensure that annual performance 

reports are complete and accurate, supported by verifiable data, and 

periodically validated as part of its monitoring process; and the supporting 

documentation is maintained for future auditing purposes. 

NJ DLPS concurred with our recommendation and said it will draft necessary 

written policies and procedures. In its response, NJ DLPS also said that after 

our audit fieldwork was completed, the Grants Compliance Unit added 

monitoring of PMT source documents to the Department’s Monitoring Site 

Visit Checklist and began to sample and verify PMT data of VOCA 

subrecipients. 

This recommendation can be closed when we receive documentation 

demonstrating NJ DLPS has developed and implemented policies and 

procedures that ensure annual performance reports are complete and 

accurate, supported by verifiable data, and periodically validated as part of 

its monitoring process. 

5. Ensure NJ DLPS develops an effective and efficient method for 

testing subrecipient detailed cost summaries to provide reasonable 

assurance the funds are in compliance with laws, regulations, and 

provisions in the award. 

Resolved. OJP agreed with our recommendation. OJP stated in its response 

that it will coordinate with NJ DLPS to obtain a copy of its written policies and 

procedures, developed and implemented, to ensure an effective and efficient 

method for testing subrecipient detailed cost summaries is used to ensure 

that the funds are expended in compliance with the laws, regulations, and 

provisions of its Federal awards. 

NJ DLPS partially concurred with this recommendation. In its response, 

NJ DLPS stated its current policy requiring the review of all financial 

documentation that supports expenditures reported on a detailed cost 

statement (“DCS”) has remained in place due to limited staff. However, 

NJ DLPS acknowledged that its current reimbursement policy is timeconsuming and may lead to delays in payment processing. NJ DLPS further 

noted that it was working to fill grant analyst positions and increase staffing 

in the Grants Compliance Unit. Further, NJ DLPS acknowledged that once 

fully staffed, it will revise the current reimbursement policy to allow for a 

more risk-based approach as to the amount and frequency of source 

documentation required at the time of grant reimbursement. 

This recommendation can be closed when we receive documentation 

demonstrating NJ DLPS has developed an effective and efficient method for 

testing subrecipient detailed cost summaries to provide reasonable assurance 

funds are in compliance with laws, regulations, and provisions in the award. 

38 
 

 

 

 

 

 

 

6. Remedy $75,334 in unsupported subrecipient costs. 

Resolved. OJP agreed with our recommendation. In its response, OJP stated 

it will review the $75,334 in unsupported questioned costs charged to Grant 

Numbers 2014-VA-GX-0032, 2015-VA-GX-0021, 2016-VA-GX-0072, and 

2017-VA-GX-0058, and will work with NJ DLPS to remedy the costs, as 

appropriate. 

NJ DLPS partially concurred with our recommendation. In its response, NJ DLPS 

stated it was going to obtain the details of the specific unsupported 

subrecipient costs to determine if it inappropriately reimbursed subrecipients. 

We provided NJ DLPS with the breakdown of the subrecipient questioned 

costs at the exit conference and will continue to work with NJ DLPS to provide 

greater detail of the individual transactions that comprise the total amount 

we cited. NJ DLPS further stated that once it can verify the unsupported 

subrecipient costs with its internal documentation, it will work with those 

subrecipients cited in the audit report to compile the necessary documentation 

to support the $75,334 in unsupported costs. Additionally, NJ DLPS said that 

it will repay any amount where that information (supporting documentation) 

is not available. 

This recommendation can be closed when we receive documentation 

demonstrating OJP has remedied $75,334 in unsupported subrecipient costs. 

7. Ensure that NJ DLPS enhances its policies and procedures to ensure 

that subrecipient site-visits are conducted in accordance with VOCA 

Guidelines and its own procedures. 

Resolved. OJP agreed with our recommendation. OJP stated in its response 

that it will coordinate with NJ DLPS to obtain a copy of its written policies and 

procedures, developed and implemented, to ensure that subrecipient site 

visits are conducted in accordance with VOCA Guidelines and its own 

procedures. 

NJ DLPS concurred with our recommendation. In its response, NJ DLPS said 

it recognizes the need to conduct subrecipient site visits in accordance with 

VOCA Guidelines and internal procedures. NJ DLPS further acknowledged 

that it is planning to increase staffing to ensure there are sufficient resources 

in place to successfully perform subrecipient monitoring in accordance with 

existing policies and procedures. 

This recommendation can be closed when we receive documentation 

demonstrating NJ DLPS enhanced its policies and procedures to ensure that 

subrecipient site visits are conducted in accordance with VOCA Guidelines 

and its own procedures. 

39 
 

 

-

The Department of Justice Office of the Inspector General (DOJ OIG) is a 

statutorily created independent entity whose mission is to detect and deter 

waste, fraud, abuse, and misconduct in the Department of Justice, and to

promote economy and efficiency in the Department’s operations.

To report allegations of waste, fraud, abuse, or misconduct regarding DOJ 

programs, employees, contractors, grants, or contracts please visit or call the

DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.

U.S. DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL

950 Pennsylvania Avenue, NW

Washington, DC 20530 0001

Website

oig.justice.gov

Twitter

@JusticeOIG

YouTube

JusticeOIG

Also at Oversight.gov