Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the Office on Violence 

Against Women Justice for Families

Program Grant Awarded to the 

Arlington County Supervised 

Visitation and Safe Exchange 

Program, Arlington, Virginia

Audit Division 20-052 March 2020

 
Executive Summary 

Audit of the Office on Violence Against Women Justice for Families Program Grant 

Awarded to the Arlington County Supervised Visitation and Safe Exchange Program 

Arlington, Virginia 

Objectives 

The Office on Violence Against Women (OVW) awarded a 

grant to the Arlington County Supervised Visitation and 

Safe Exchange Program (Safe Havens) totaling 

$585,060 under its Justice for Families Program. The 

objectives of this audit were to determine whether costs 

claimed under the grant were allowable, supported, and 

in accordance with applicable laws, regulations, 

guidelines, and terms and conditions of the award; and 

to determine whether the grantee demonstrated 

adequate progress towards achieving program goals and 

objectives. 

Results in Brief 

Safe Havens demonstrated adequate progress in 

achieving its grant-related goals and objectives, and we 

did not identify significant issues regarding Safe Havens’ 

compliance with special conditions or its management of 

the grant’s budget. However, we determined that Safe 

Havens should improve its recording and reporting of 

data for grant-related services provided. In addition, we 

found that Safe Havens did not comply with award 

requirements related to grant expenditures and 

subrecipient monitoring. We also found that Safe 

Havens officials need to improve documentation of its 

grant financial management policies and procedures. 

Recommendations 

Our report contains four recommendations to OVW to 

assist Safe Havens in improving its grant management 

and administration. We discussed the results of our 

audit with OVW and Safe Havens officials and have 

included their comments in the report. Their responses 

can be found in Appendices 2 and 3, respectively. Our 

analysis of those responses is included in Appendix 4. 

Audit Results 

The audited grant seeks to support supervised visitation 

and safe exchange services for families experiencing a 

history of domestic violence, dating violence, sexual 

assault, stalking, or alleged child abuse. The project 

period for the grant is October 2017 through September 

2020. As of December 2019, Safe Havens had drawn 

down a cumulative amount of $217,661 of the grant. 

Program Goals and Accomplishments - Safe Havens 

demonstrated adequate progress towards meeting grant 

goals and objectives. Safe Havens collected and 

analyzed performance measures data, including planning 

coordinated community efforts, victim and survivor 

outreach, supervised visitation and safe-exchange 

services, referrals to victim services, and court-based 

activities and services. 

Progress Reports - We tested nine performance 

measures reported on two progress reports. Safe 

Havens lacked documents needed to support measures 

reported on its progress reports. Specifically, two of the 

four performance measures reported from July 2018 

through December 2018, and four of the five 

performance measures reported from January 2019 

through June 2019, either were not supported or the 

grantee was unable to provide source documents. 

Grant Expenditures - We tested a sample of 

transactions charged to the grant. Although Safe 

Havens generally computed and recorded accurate 

salary and associated fringe benefit costs, we found that 

it lacked a documented policy or procedure that 

addressed how employee compensatory time should be 

allocated to federal awards. 

Subrecipient Monitoring – We found that Safe Havens 

officials did not request support for subrecipient invoices 

and generally relied on subrecipients to report their own 

time and performance metrics. This practice increased 

the risk of subrecipients charging unallowable or 

unsupported costs to the grant. 

Drawdowns – We identified concerns with Safe Havens’ 

policy and procedures for preparing and completing 

drawdown requests. These procedures lacked the 

details necessary to ensure that the grantee would 

comply with the DOJ Grants Financial Guide. 

i 
AUDIT OF THE OFFICE ON VIOLENCE AGAINST WOMEN 

JUSTICE FOR FAMILIES PROGRAM GRANT 

AWARDED TO THE ARLINGTON COUNTY SUPERVISED 

VISITATION AND SAFE EXCHANGE PROGRAM 

ARLINGTON, VIRGINIA 

TABLE OF CONTENTS 

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

Arlington County, Virginia ..................................................................... 1 

Arlington County Safe Havens ............................................................... 2 

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

AUDIT RESULTS ........................................................................................... 3 

Program Performance and Accomplishments ............................................ 3 

Program Goals and Objectives ...................................................... 3 

Required Performance Reports ...................................................... 3 

Compliance with Special Conditions ............................................... 6 

Grant Financial Management ................................................................. 7 

Grant Expenditures .............................................................................. 7 

Personnel Costs.......................................................................... 7 

Subrecipient Costs ...................................................................... 8 

Contractor Costs......................................................................... 9 

Monitoring of Subrecipients ................................................................... 9 

Budget Management and Control ......................................................... 10 

Drawdowns ....................................................................................... 10 

Federal Financial Reports .................................................................... 11 

CONCLUSION AND RECOMMENDATIONS ........................................................ 12 

APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY.................................. 13 

APPENDIX 2: ARLINGTON COUNTY SUPERVISED VISITATION AND SAFE 

EXCHANGE PROGRAM RESPONSE TO THE DRAFT REPORT ....................... 14 
APPENDIX 3: OFFICE ON VIOLENCE AGAINST WOMEN RESPONSE TO THE 

DRAFT REPORT.................................................................................. 17 

APPENDIX 4: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT .................................. 20 
AUDIT OF THE OFFICE ON VIOLENCE AGAINST WOMEN 

JUSTICE FOR FAMILIES PROGRAM GRANT 

AWARDED TO THE ARLINGTON COUNTY SUPERVISED 

 VISITATION AND SAFE EXCHANGE PROGRAM 

ARLINGTON, VIRGINIA 

INTRODUCTION 

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

completed an audit of a Justice for Families Program grant awarded by the Office on 

Violence Against Women (OVW) to the Arlington County Supervised Visitation and 

Safe Exchange Program (Safe Havens) in Arlington County, Virginia. Safe Havens 

was awarded one grant totaling $585,060, as shown in Table 1. 

Table 1 

OVW Grant Awarded to Safe Havens 

Project 

Period Start 

Date 

Project 

Period End 

Date 

Award 

Award Number Program Office Award Date Amount 

Office on 

Violence Against 

Women 

2017-FJ-AX-0016 09/14/2017 10/01/2017 09/30/2020 $585,060 

Total: $585,060 

Source: Office of Justice Programs Grants Management System (GMS) 

Funding through the Justice for Families Program was authorized by the 

Violence Against Women Reauthorization Act of 2013 to improve the response of all 

aspects of the civil and criminal justice system to families with a history of domestic 

violence, dating violence, sexual assault, or stalking, or in cases involving 

allegations of child abuse. The Justice for Families Program is intended to improve 

the capacity of courts and communities to help affected families via: (1) courtbased and court-related programs; (2) supervised visitation and safe exchange by 

and between parents; (3) training and technical assistance for people who work 

with families in the court system; (4) civil legal services; (5) the provision of 

resources in juvenile court matters; and (6) developing legislation, model codes, 

policies, and best practices. 

Arlington County, Virginia 

Arlington is an urban county of about 26 square miles located directly across 

the Potomac River from Washington, D.C. As of January 2017, Arlington had an 

estimated population of 222,800, reflecting a 7.3 percent increase since 2010. 

Each Virginia city and county maintains a juvenile and domestic relations 

district court. The Arlington Juvenile & Domestic Relations (JDR) Court hears all 

matters in Arlington County involving juveniles, including matters concerning the 

family, such as custody, support, and visitation. The court also hears family abuse 

cases, cases where adults have been accused of child abuse or neglect, and 

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criminal cases where the defendant and alleged victim are family or household 

members. 

Arlington County Safe Havens 

Although Arlington County courts have issued over 100 protective orders that 

include children each year, Arlington County had lacked a supervised visitation and 

monitored exchange program. Recognizing this need, Safe Havens applied for an 

OVW grant to create a supervised visitation and monitored exchange program to 

promote the safety of victim parents, children, and others during visitations and 

child exchanges in family situations involving domestic violence, dating violence, 

child abuse, sexual assault, or stalking. The program sought to work with the 

Arlington JDR Court to balance the safety interests of the custodial parent and the 

children with the non-custodial parent’s need to bond with their children. 

The program also uses grant funds to perform project work with two 

subrecipient non-profit organizations. Legal Services of Northern Virginia (LSNV) 

provides Safe Havens clients with legal advice on protective orders and direct 

representation on a range of family law proceedings, including child support and 

custody matters. Doorways for Women and Families (Doorways) provides a 

bilingual court advocate to assist Safe Havens clients at meetings with law 

enforcement, prosecutors, and other criminal justice-system related activities. 

Doorways also ensures that clients are aware of the shared visitation services 

offered by Safe Havens. 

OIG Audit Approach 

The objectives of this audit were to determine whether costs claimed under 

the grant were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions of the grant; and to determine 

whether the grantee demonstrated adequate progress towards achieving the 

program goals and objectives. To accomplish these objectives, we assessed 

performance in the following areas of grant management: program performance, 

financial management, expenditures, budget management and control, drawdowns, 

and federal financial reports. 

We tested compliance with what we considered to be the most important 

conditions of the grant. The 2017 DOJ Grants Financial Guide (DOJ Grants Financial 

Guide), and the award documents contain the primary criteria we applied during 

the audit. 

The results of our analysis are discussed in detail later in this report. 

Appendix 1 contains additional information on this audit’s objectives, scope, and 

methodology. 

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AUDIT RESULTS 

Program Performance and Accomplishments 

We reviewed required performance reports, the grant solicitation and 

documentation, and interviewed Safe Havens officials to determine whether the 

grantee demonstrated adequate progress towards achieving program goals and 

objectives. We also reviewed reports submitted by Safe Havens and relevant 

supporting documentation to determine if the required reports were accurate. 

Finally, we reviewed Safe Havens’ compliance with the special conditions identified 

in the award documentation. 

Program Goals and Objectives 

OVW awarded Grant Number 2017-FJ-AX-0016 with four project goals to 

support supervised visitation and safe exchange services: (1) finalize site selection 

and initiate project oversight and coordination, (2) secure needed technical 

assistance training, research best practices and formulate a complete program 

design and operational plan, (3) educate community partners and the general 

community about the visitation and exchange program and the safety it will provide 

for adult and child victims, and (4) be positioned and ready to begin the program at 

the end of the implementation year. Safe Havens estimated that this program 

would serve 200-300 families over the course of the 3-year project period. 

We reviewed documentation, interviewed officials from Safe Havens, and 

observed grant-funded activities in the field. The program coordinator and advisory 

committee researched best practices; consulted with OVW, local stakeholders, and 

other supervised visitation programs; and monitored exchange programs across the 

United States at monthly meetings. These meetings addressed multiple project 

topics, including community coordination techniques, communication needs, the 

referral process, ongoing issues, and how best to establish operational policies and 

program-critical documents such as intake forms and participant booklets. 

We further found that Safe Havens officials attended various events across 

Arlington County, such as fairs and outreach programs, to discuss its services. In 

January 2019, Safe Havens hosted a kick-off event to mark the beginning of its 

operations, thereby achieving the fourth goal. Therefore, we determined that Safe 

Havens demonstrated adequate progress in achieving its grant-related goals and 

objectives. 

Required Performance Reports 

According to the DOJ Grants Financial Guide, the funding recipient should 

have available valid and auditable source documentation to support data collected 

for each performance measure specified in the program solicitation. As part of the 

reporting requirements under the Justice for Families Program, the grantee must 

collect and analyze specific data on a variety of performance measures, including 

planning coordinated community efforts, victim and survivor outreach, supervised 

visitation and safe-exchange services, referrals to victim services, and court-based 

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activities and services. In order to verify the information in OVW’s Semi-Annual 

Progress Reports for Grants to Support Families in the Justice System, we selected 

a sample of nine performance measures from the semiannual periods ending 

December 31, 2018 and June 30, 2019. We then sought to trace the items to 

supporting documentation maintained by Safe Havens officials. 

We assessed progress reports and reviewed services provided, and 

determined that progress reports appeared to align with actual grant activity. 

However, we identified several discrepancies between the data Safe Havens 

reported to OVW and the source documentation. Although Safe Havens 

demonstrated adequate progress in meeting the project goals, we found that the 

grantee lacked proper support to demonstrate that it accurately reported 

performance measures associated with certain grant reporting requirements. Table 

2 shows that two of the four performance measures reported from July 2018 

through December 2018, and four of the five performance measures reported from 

January 2019 through June 2019 lacked adequate support. 

4 
Table 2 

Review of Safe Havens Progress Report Performance Measures 

July 2018 – June 2019 

No. 

Performance Measures 

Tested 

July 2018 – December 2018 

Reported to OVW Safe Havens Data 

1 Effectiveness of planning and/or 

technical assistance activities 

A Grant Adjustment Notice 

(GAN) was submitted and 

approved to change staffing 

Reconciled. However, the grantee 

had to retract the statement that a 

GAN was submitted and approved 

during this reporting period. The 

grantee stated the information was 

entered by error.* 

2 

Agencies/organizations that are 

provided with victim/survivor 

referrals to, received 

victim/survivor referrals from, 

or engaged in other coordination 

activities or meetings. 

Monthly meetings with 

various organizations** Reconciled with meeting agendas. 

3 Number of families served 6 Unreconciled. Grantee did not 

maintain source documentation. 

4 

Number of 

times 

services 

provided with 

Group 

Supervision 3 Unreconciled. Grantee did not maintain source documentation. 

Supervised 

Exchange 5 Unreconciled. Grantee did not maintain source documentation. 

No. 

Performance Measures 

Tested 

January 2019 – June 2019 

Reported to OVW Safe Havens Data 

Update Safe Havens Parent 

Handbook to request parents 

not use the visitation and 

exchange center to service 

civil process documents to 

the other parent. 

Safety and Security Reconciled. 

1 

2 Number of families served 20 Unreconciled. Grantee document 

did not support reported measure. 

3 

Families seeking services who 

were not served 8 Unreconciled. Grantee document 

did not support reported measure. 

4 

Reasons families did not meet 

program criteria 8 Unreconciled. Grantee document did not support reported measure. 

5 

Number of 

times 

services 

provided with 

grant funds: 

Group 

Supervision 87 Unreconciled. Support documents were not provided for verification. 

Supervised 

Exchange 53 Unreconciled. Support documents 

were not provided for verification. 

grant funds: 

* After we brought the lack of a GAN to the attention of Safe Havens officials, Safe Havens submitted and 

OVW approved the GAN. 

** For the semiannual report ending December 2018, Safe Havens officials reported monthly meetings 

occurred with attorneys, a mental health organization, a law enforcement agency, a legal organization, 

and a sexual assault organization. 

Sources: OIG analysis of OVW’s Semi-Annual data and Safe Havens data 

Safe Havens officials told us that they maintain individual files for every 

family they assist. They also stated that they based the numbers reported in the 

progress reports on a hand-count of the files they maintain. However, during the 

review of the progress report ending December 2018, we could not verify certain 

5 
 

 

 

 

reported figures. Safe Havens officials told us that they did not maintain the files in 

the beginning of the program. These officials also told us that they are in the 

process of working with Arlington County to develop a database to capture 

appropriate data on families served by the Safe Havens program. 

During our review of the metrics listed in the progress report ending June 2019, 

we found that the grantee had created spreadsheets that captured the number of 

families served. However, we identified discrepancies within the worksheets and 

requested copies of the supporting documents to assess further. The grantee was 

further unable to provide us with supporting documents to confirm the number of: 

(1) families served, (2) families seeking service and not served, (3) times families 

received group supervision services, and (4) times families received supervised 

exchange services. Without maintaining support for these figures, not only are 

progress reports unverifiable, but Safe Havens cannot demonstrate that it is on 

track to meet performance measures pertaining to services offered or provided to 

families seeking assistance. 

Further, our review of Safe Havens policies revealed no established policies 

or procedures directly related to performance measures reporting or recordkeeping. 

Since we could not verify numbers reported to OVW to support the performance 

measures in the progress reports ending December 2018 and June 2019, we 

recommend that OVW require that Safe Havens officials implement policies and 

procedures to support performance and activities contained in each progress report 

with valid and auditable source documents, as required by the DOJ Grants Financial 

Guide. 

Compliance with Special Conditions 

Special conditions are the terms and conditions that are included with the 

award. We evaluated the special conditions for the grant and selected a 

judgmental sample of the requirements we deemed significant to performance 

under the grant, but not addressed in another section of this report. We evaluated 

six special conditions for the grant. 

First, we tested conditions related to the System for Award Management 

(SAM) and Universal Identifier requirements, including registration with and 

maintaining current information in SAM. Second, we tested requirements 

pertaining to restrictions on lobbying and policy development.1 Third, we assessed 

the Safe Havens Program Center facility to ensure it: (1) provided complete 

separation between relevant parties and adequate safety and security to its users 

and (2) received OVW approval as a supervised visitation center. Fourth, we tested 

whether Safe Havens included the DOJ disclosure statement on all materials and 

publications furnished by the grant. Fifth, we tested for the provision of the OVW 

grantee orientation seminar for first time grant recipients. Finally, we tested for the 

approval of internal and external policies and procedures. Our testing did not 

1 In general, recipients or subrecipients may not use federal funds to support of the 

enactment, repeal, modification or adoption of any law, regulation, or policy. 18 U.S.C. § 1913. 

6 
 

identify any instances of Safe Havens not meeting or otherwise not complying with 

these special conditions. 

Grant Financial Management 

According to the DOJ Grants Financial Guide, all grant recipients and 

subrecipients are required to establish and maintain adequate accounting systems 

and financial records and to account accurately for award funds. To assess Safe 

Havens’ financial management of the grant we interviewed financial staff, examined 

policies and procedures, assessed for suspended or debarred parties, and inspected 

grant documents to determine whether Safe Havens safeguarded grant funds. We 

also reviewed Arlington County’s Single Audit Report for FY 2018 to identify internal 

control weaknesses and significant non-compliance issues related to federal awards. 

Our work identified specific weaknesses in Arlington County’s policies and 

procedures for administrating grants relating to personnel, monitoring 

subrecipients, drawing down federal funds, and filing financial reports. We brought 

these issues to the attention of Safe Havens officials, who told us that they were 

not aware of these discrete requirements. Needed improvements in these areas 

will enhance OVW’s ability to oversee the financial activity of this grant and are 

discussed in more detail in the relevant section of this report. 

Grant Expenditures 

As of November 2019, Safe Havens charged $294,780 in expenditures to the 

grant. The approved budget included allowances for personnel costs, fringe 

benefits, travel, and contractual costs, as detailed in Table 3. 

Table 3 

Expenditures by Cost Elements 

Cost Element Total Budgeted Total Spent 

Personnel $ 348,601 $ 190,638 

Fringe 76,734 68,093 

Travel 20,000 0 

Consultants/Contracts 139,725 36,049 

Total $585,060 $294,780 

Source: OVW and Safe Havens accounting records 

To determine whether costs charged to the award were allowable, supported, 

and properly allocated in compliance with award requirements, we tested a sample 

of transactions representing $59,034 of the total expenditures allocated to the 

grant. These transactions included personnel and fringe, and subrecipient and 

contractor costs. We reviewed supporting documents, analyzed accounting records, 

and performed verification testing related to grant expenditures. 

Personnel Costs 

Under the DOJ Grants Financial Guide, charges must be supported by a 

system of internal controls that provides reasonable assurance that the charges are 

7 
 

 

 

accurate, allowable and properly allocated. As such, salaries, wages, and fringe 

benefits provided by federal awards must be based on records that accurately 

reflect the work performed and comply with the established policies and practices of 

the organization. Based on our review of Arlington County’s September 2019 

Grants Management Policy and Procedure, we found that there is neither a 

documented policy nor procedure that addresses how Safe Havens approves 

employee salaries and fringe benefits associated with federal awards. Therefore, 

we recommend OVW coordinate with Safe Havens officials to implement policies for 

how it allocates employee salaries and fringe benefits to Federal awards. 

As of November 2019, Safe Havens charged $190,638 in personnel costs and 

$68,093 in fringe benefit costs to the grant totaling $258,731, or 44 percent of the 

total award. We reviewed Safe Havens personnel costs and determined Safe 

Havens paid four employees with grant funds, one full-time program coordinator, 

two part-time visitation monitors, and one temporary visitation monitor. Safe 

Havens also paid fringe benefit costs including taxes, health insurance, and county 

retirement benefits for the full-time and part-time grant-funded employees. 

Based on the payroll cost detail information for these employees, we 

judgmentally selected all pay periods for the full-time employee during FY 2018 and 

two non-consecutive pay periods that included part-time employees during FY 

2019. This sample included $34,951 in salary and $13,498 in fringe benefit 

expenditures. Additionally, we interviewed a selected sample of employees paid 

through the grant and determined that these employees’ roles and responsibilities 

had a reasonable relationship to grant activities. Based on testing of the full-time 

program coordinator position, we found that personnel and fringe benefit costs 

were properly computed, authorized, and recorded. 

Under the approved budget, Safe Havens was to allocate the salary of one 

full-time visitation monitor to the grant. However, we found that Safe Havens 

instead charged to the grant the salary of two part-time visitation monitors. 

According to the DOJ Grants Financial Guide, recipients must initiate a GAN for 

changes in scope, duration, activities, or other significant areas, including altering 

programmatic activities that were not identified in the original approved budget. 

We brought this issue to the attention of Safe Havens officials, who subsequently 

requested retroactive approval to split the position into half-time positions that 

equal the same budgeted amount. In November 2019, OVW approved a GAN for 

the proposed personnel changes. Based on this approval, we determined that the 

paid salaries and fringe benefits for the part-time visitation monitors and paid 

salaries for the temporary employee were allowable. In addition, we determined 

that the tested salary expenses and associated fringe benefit costs for the part-time 

and temporary positions were generally computed and recorded accurately. 

Subrecipient Costs 

For our review of the subrecipient costs, we interviewed Safe Havens officials 

and subrecipient staff at both Doorways and LSNV. We reviewed the Memorandum 

of Understanding (MOU) established between each subrecipient and Safe Havens. 

8 
 

We judgmentally selected and sampled two invoices, one from each subrecipient, 

totaling $7,200. 

Based on this testing, we determined that costs were: (1) approved, 

(2) within the scope of the grant program, (3) properly authorized by a grantee 

official, (4) properly classified, (5) accurately recorded in accounting records, and 

(6) properly charged to the grant. However, we found that Doorways invoices 

lacked required information, specifically the dates that it rendered services during 

the invoice-billing period. The MOU between Doorways and Safe Havens requires 

that Doorways include the date of services rendered with their invoices to Safe 

Havens. Without specific dates of service on the invoices, Safe Havens risks 

duplicating or omitting a payment for a date of service. Safe Havens and Doorways 

officials acknowledged the error and stated all invoices going forward would contain 

the required dates of service information. 

Contractor Costs 

Safe Havens uses an Arlington County contract to obtain security guard 

services for the program before, during, and after a visitation. We interviewed 

Arlington County and Safe Havens officials, reviewed the security vendor’s contract 

with Arlington County, reviewed Arlington County’s MOU with Safe Havens, and 

reviewed four invoices the contractor submitted totaling $3,385. From our review, 

we determined all the contractor invoices were allowable and supported by the 

documentation provided. 

Monitoring of Subrecipients 

According to the DOJ Grants Financial Guide, the grantee is responsible for 

monitoring its subrecipients and verifying they fulfill all financial and programmatic 

responsibilities. The DOJ Grants Financial Guide also requires the grantee to have 

written subrecipient monitoring policies and procedures. 

Safe Havens awarded $24,689 to Doorways for court advocacy services for 

2 years and $69,036 to LSNV for legal representation services for 2 years. Safe 

Havens’ respective MOUs with these subrecipients detail the terms of 

reimbursement for services provided such as required information for invoices, 

required invoice submission dates, required reporting of performance measures, 

and required attendance at monthly Safe Havens Advisory Board meetings. 

Our review of Safe Havens’ subrecipient oversight determined that Safe 

Havens did not request support for invoices submitted by either subrecipient and 

instead generally relied on the subrecipients’ own reporting of their time and 

performance metrics. We also found that Safe Havens lacked written policies and 

procedures regarding subrecipient site visits. While our testing found subrecipient 

costs allowable, we believe that by strengthening subrecipient monitoring policies 

and procedures, Safe Havens may decrease the risk of its subrecipients charging 

unallowable or unsupported costs to the grant. Therefore, we recommend OVW 

work with Safe Havens to implement policies and procedures to guide subrecipient 

9 
site visits and verify invoiced time charges, to include the dates of the performance 

of services. 

Budget Management and Control 

According to the DOJ Grants Financial Guide, the grantee is responsible for 

establishing and maintaining an adequate accounting system, which includes the 

ability to compare actual expenditures or outlays with budgeted amounts for each 

award. Additionally, the grant recipient must initiate a GAN for a budget 

modification that reallocates funds among budget categories if the proposed 

cumulative change is greater than 10 percent of the total award amount. 

We compared grant expenditures to the approved budgets to determine 

whether Safe Havens transferred funds among budget categories in excess of 

10 percent. We determined that the cumulative difference between category 

expenditures and approved budget category totals was not greater than 10 percent. 

Drawdowns 

According to the DOJ Grants Financial Guide, grantees should establish an 

adequate accounting system to support all receipts of federal funds. If, at the end 

of the grant award, recipients have drawn down funds in excess of federal 

expenditures, unused funds must be returned to the awarding agency. As of 

December 2019, Safe Havens officials had drawn down a total of $217,661 in grant 

funds. 

To assess whether Safe Havens officials managed grant receipts in 

accordance with federal requirements, we reviewed written policies and procedures 

for preparing drawdown requests and compared the total amount reimbursed to the 

total expenditures in the accounting records. Our testing confirmed that Safe 

Havens total expenditures exceeded its cumulative drawdowns, which indicates 

they drew down award funds on a reimbursement basis, as appropriate, and the 

funds were electronically deposited into a bank account. 

However, our review of Safe Havens policy and procedures for completing 

drawdowns found that the written policy effective April 2019 did not specify 

procedures for drawing down funds or detail the source of information someone 

should use to prepare the drawdown requests. Such details are necessary to 

ensure that the grantee will be in compliance with the DOJ Grants Financial Guide. 

Moreover, we determined that the drawdown policy was not in effect before Safe 

Havens first made a drawdown in August 2018. We brought these issues to a 

grantee official’s attention and in September 2019, this official sent us a revised 

policy that included detailed drawdown procedures to include when a drawdown 

request must be completed by and how drawdown money is received and allocated. 

While the updated policy addressed some of our concerns regarding 

necessary detail to ensure compliance, we determined that the updated policy 

contained contradictory or inconsistent guidance. For instance, the policy states 

that the Arlington County Court Services Unit will complete drawdowns in a timely 

10 
fashion, at the latest by the end of the grant fiscal year on October 30. However, 

the detailed procedure section of the policy states that drawdown requests will be 

performed no later than 30 days after the end of each calendar quarter of the fiscal 

year on January 30, April 30, July 30, and October 30. Therefore, we recommend 

OVW coordinate with Safe Havens officials to implement an effective, consistent 

drawdown policy that complies with the DOJ Grants Financial Guide. 

Federal Financial Reports 

According to the DOJ Grants Financial Guide, grant recipients shall report the 

actual expenditures and unliquidated obligations incurred for the reporting period 

on each Federal Financial Report (FFR) as well as cumulative expenditures. To 

determine whether Safe Havens submitted accurate FFRs, we assessed its written 

policies for preparing FFRs and compared six reports to Safe Havens accounting 

records from April 1, 2018 through September 30, 2019. 

As shown in Table 4, we found inconsistencies between the expenditures 

reported on FFRs and the expenditures per the accounting records. Furthermore, 

we reviewed the grantee's written policy and procedure for completing FFRs and 

found that Safe Havens only created its FFR policy in July 2019, which was after the 

reporting period for five of the six FFRs reviewed. 

Table 4 

Accuracy of Safe Havens Federal Financial Reports 

Award-Related Difference 

Expenditures Expenditures per Between FFRs and 

Report Reported on the Accounting Accounting 

No. Reporting Period FFR ($) Records ($) Records ($)a 

3 04/01/18 - 06/30/18 28,173 35,017 (6,844) 

4 07/01/18 - 09/30/18 34,441 26,220 8,221 

5 10/01/18 - 12/31/18 31,967 35,701 (3,734) 

6 01/01/19 - 03/31/19 47,231 40,598 6,633 

7 04/01/19 - 06/30/19 75,819 80,366 (4,547) 

8 07/01/10 – 09/30/19 41,490 41,490 0 

Total $259,121 $259,392 ($271) 

 

 

Source: OIG analysis of Office of Justice Programs data and Safe Havens accounting records 

The grantee officials advised that the variances between the expenditures 

reported on the FFRs and the accounting records were most likely due to end of 

period expenses and payroll amounts and dates. These officials emphasized that 

the FFR submitted for September 2019 was accurate. In addition, these officials 

stated that once they realized they required written policies and procedures to 

guide FFR development, they took action to implement such policies. 

Our review confirmed that the latest September 2019 FFR reconciled to Safe 

Havens accounting records. Considering that Safe Havens employees prepared this 

FFR under the FFR-development policies and procedures, we provide no 

recommendation. 

11 
 

CONCLUSION AND RECOMMENDATIONS 

Our audit assessed Safe Havens program performance, grant financial 

management, expenditures, budget management and control, subrecipient 

oversight, and drawdowns. We determined that Safe Havens officials demonstrated 

progress towards achieving the grant’s stated goals and objectives, but need to 

comply with certain performance recording and reporting requirements. While we 

did not identify significant issues regarding Safe Havens’ compliance with special 

conditions or its management of the grant budget, we found that Safe Havens 

officials did not comply with DOJ grant financial management policies and 

procedures to maintain documents to support performance metrics and progress 

reports. We provide four recommendations to OVW and Safe Havens officials to 

address these issues. 

We recommend that OVW: 

1. Require that Safe Havens officials implement policies and procedures to 

support performance and activities contained in each progress report with 

valid and auditable source documents, as required by the DOJ Grants 

Financial Guide. 

2. Coordinate with Safe Havens officials to implement policies for how it 

allocates employee salaries and fringe benefits to Federal awards. 

3. Work with Safe Havens to implement policies and procedures to guide 

subrecipient site visits and verify invoiced time charges, to include the dates 

of the performance of services. 

4. Coordinate with Safe Havens officials to implement an effective, consistent 

drawdown policy that complies with the DOJ Grants Financial Guide. 

12 
 

APPENDIX 1 

OBJECTIVES, SCOPE, AND METHODOLOGY 

Objectives 

The objectives of this audit were to determine whether costs claimed under 

the grant were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions of the grant; and to determine 

whether the grantee demonstrated adequate progress towards achieving the 

program goals and objectives. To accomplish these objectives, we assessed 

performance in the following areas of grant management: program performance, 

financial management, expenditures, budget management and control, drawdowns, 

and federal financial reports. 

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 objectives. We believe 

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

conclusions based on our audit objectives. 

This was an audit of the Office on Violence Against Women (OVW) Justice for 

Families Program grant awarded to the Arlington County Supervised Visitation and 

Safe Exchange Program (Safe Havens). Safe Havens was awarded $585,060 under 

Grant Number 2017-FJ-AX-0016, and as of December 2019, had drawn down 

$217,661 of the total grant funds awarded. Our audit concentrated on, but was not 

limited to October 2017, the award start date, through December 2019, the last 

day of our audit work. Grant Number 2017-FJ-AX-0016 is still ongoing. 

To accomplish our objectives, we tested compliance with what we consider to 

be the most important conditions of Safe Havens activities related to the audited 

grant. We performed sample-based audit testing for grant expenditures including 

payroll and fringe benefit charges, subrecipient costs, financial reports, and 

progress reports. In this effort, we employed a judgmental sampling design to 

obtain broad exposure to numerous facets of the grant reviewed. This 

non-statistical sample design did not allow projection of the test results to the 

universe from which the samples were selected. The DOJ Grants Financial Guide 

and the award documents contain the primary criteria we applied during the audit. 

During our audit, we obtained information from the Office of Justice 

Programs’ Grants Management System, as well as Safe Havens’ 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 were verified with documentation from 

other sources. 

13 
APPENDIX 2 

ARLINGTON COUNTY SUPERVISED VISITATION AND SAFE 

EXCHANGE PROGRAM RESPONSE TO THE DRAFT REPORT 

ARLINGTON COUNTY, VIRGINIA 

JUVENILE AND DOMESTIC RELATIONS DISTRICT 

COURT SERVICES UNIT 

1425 N. COURTHOUSE ROAD, SUITE: SJC() 

ARLINGTON, VIP.GIN IA n201 

GCOP.GE C>. VAA.OUTSOS CHlf:F JUDGE 

RODIN L. ROOO 

JUDGE 

EARLJ. CONKLIN 

OIA.l!CTOll OF COURT SUWICE:S 

(70:3) 228•4600 

March 3, 2020 

John Manning 

Regional Audit Manager 

Washington Regional Audit Office 

Office of the Inspector General 

U.S. Department of Justice 

Jefferson Plaza 

Suite 900 

Washington, DC 20530 

RE: OFFICIAL RESPONSE TO DRAFT AUDIT REPORT 

Dear !\fr. Manning: 

TI1is letter constitutes the Arlington Colllt Services Unit's official response to the draft audit 

report from your office dated February 11, 2020. 

We were very pleased that the audit team detennined that Safe Havens demonstrated adequate 

progress in achieving our grant-related goals and objectives. 111e Executive Summary noted that 

the team did not identify significant issues regarding our complim1ce with special conditions or 

mm1agement of our grm1t budget. We would like to note that during the audit, the County's 

Accounting, Reporting and Control Office adopted an official county-wide Grants Management 

Policy and Procedure Guide on September 19, 2019. This policy document covers all areas of the 

grant life-cycle and should be considered a5 part of the Court Services Unit's grant financial 

management policies and procedures. A copy of this document is included as pa1t of this response 

letter. 

14 
Below you will find our plan to follow your recommendations on improved grant management 

and administration. 

1. Program goals and accomplishments; 

2. Progress reports; 

3. Grant expenditures; 

4. Subrecipient monitoring; and 

5. Drawdowns 

1. Program goals and accomplishments 

Disagree: After review of the Draft Audit Report and apart from what is detailed in the 

categories listed below, and we were unable identify how Safe Havens "lacked documentation 

to support certain grant accomplishments". We hope that items 2 through 5 addresses all 

areas of attention. 

2. Progress reports 

Agree: Required perfonnance reports, the audit team found that we did not have sufficiently 

"valid and auditable source documentation to support data collected for each perfonnance 

measure specified in the program solicitation." 

Action Plan: TI1e Arlington Safe Havens management team (grant manger, program 

coordinator, and management specialist) will retain source documentation so that it may be 

easily accessed and audited. Safe Havens will continue to maintain its population data in an 

official spreadsheet that captures infonnation according to the grant's required perfonuance 

measures. The source documentation is located in the program coordinator's office file 

cabinet and/or on the computer in the "Safe Havens Management folder". All members of the 

Safe Havens team wi ll have access to the data on the County's shared "L:\ drive". TI1is 

source doctunentation will back up the measures for: 

• Number of families served 

• Families seeking services who were not served 

• Times families received group supervision services 

• Times families received supervised exchange services 

• Reasons families did not meet program criteria 

We will improve our effo1ts to ensure that the data is accessible and available for future 

auditing purposes. 

3. Grant expenditures 

Agree: TI1e Draft Audit Report indicated that our program "lacked a documented policy or 

procedure that addressed how employee compensatory time should be allocated to federal 

awards". 

Action Plan: TI1e Arlington Safe Havens management team will implement a policy for the 

allocation of salaries, fringe benefits, compensatory time and overtime. We will submit a 

Grant Adjustment Notice (GAN) to follow this recommendation. We will also work with our 

OVW grant manager, Ms. Mitchell, each time a new GAN is required when there is a change 

in scope, duration, program activities, or other significant areas. 

15 
4. Subrecipient monitoring 

Agree: ll1e Draft Audit Reports states "Safe Havens did not request support for invoices 

submitted by either subrecipient, and instead generally relied on the subrecipients' own 

reporting of their time and perfonnance metrics." 

Action Plan: To effectively monito1· subrecipients to ensure that they are fulfilling alt 

financial and programmatic responsibilities, Arlington Safe Havens has already implemented 

reporting procedures that provide objective documentation. Furthennore, subrecipients are 

now providing more complete financial and programmatic infom1ation with their quarterly 

invoices. Specifically, this documentation will include: 

• Dates of service 

• Employee name, job title, and employee hourly rates. 

• Clients served (using unique identifiers) 

• Perfom1ance metrics needed for Section F of the Semi-annual Progress Report. 

Furtliermore, the Arlington Safe Havens grant manager and the management specialist will 

conduct yearly site visits to review records, interview staff, and ensure that services are being 

provided according to the tenns of the MOU. The policy and procedure for monitoring 

subrecipients, including procedures for site visits, invoices, performance metrics, and support 

documentation, will be submitted to OVW as a GAN. 

5. Drawdowns 

Agree: 111e Draft Audit Report indicated that Safe Havens' "written policy effective April 

2019 did not specify procedures for drawing down funds or detail the source of information 

someone should use to prepare the draw down requests." Based on in.fomiation received from 

tile auditors, Safe Havens drafted and revised drawdown policies during period of the audit, 

but the audit team detennined that "the updated policy contained contradictory or inconsistent 

guidance". 

Action Plan: Arlington Safe Havens will coordinate with OVW to meet the recommendation 

for an effective, consistent drawdown policy that complies with the DOJ Financial Guide. A 

revised policy and procedure for drawdowns will be submitted to OVW as a GAN. 

Response from Subrecipients: 

In large part, the responsibility for addressing the Draft Audit Report's recommendations fall 

to the Safe Havens team under the Court Services Unit. The action plans above should 

adequately respond to issues identified by the audit team. 'n1e subrecipients, for their part, 

have affinned their commitment to following all requirements of the grant, to continuing to 

work collaboratively with the Court Services Unit to resolve issues, and to provide any 

infonnation needed for effective oversight. The subrecipients are valued partners in this 

effort. Below are each subrecipient's response. 

l. Doorways 

16 
Doo1ways received the Draft Audit report on the February 11, 2020. Regarding the missing 

dates of service on invoices, Doorways has already begun to include this infonnation on tJ1eir 

invoices. With each invoice, Doorways will provide an anonymized report from their client 

database showing dates of service in which the funded staff person worked with Safe Havenseligible households. TI1e subrecipient will continue to e::dract data from its client database to 

complete Section F. 'n1is data is entered by the Safe Havens-funded Court Advocate working 

with eligible households. l11is data is "valid and auditable". 

To measure families served and families seeking service and not served (group supervision 

and supervised exchange services metrics are not applicable), Doorways counts as families for 

Section Fall clients presenting for Court Advocacy services who have minor children. 

Doorways Court Advocates ensure that eligible households are informed about Safe Havens 

and collaborates with Safe Havens on mutual clients, and only the Courts make fonnal 

referrals to Safe Havens. Regarding site visits, Dootways has received two site visits, and 

have stated tJ1eir belief that site visits should occur with the frequency required by OVW, no 

more than t\vice annually. As stated above, the organization is committed to meeting all 

requirements for the Arlington Court Services to appropriately monitor Doorways a~ a 

subrecipient of the OVW Safe Havens grant. 

2. Legal Service of Northern Virginia (LSNV) 

LSNV received the Draft Audit report on the February 11, 2020. Regarding the missing dates 

of service on invoices, LSNV will begin to include the dates of service in its nell.1 quarterly 

invoice. LSNV was uncertain about what infonnation to include along with their quarterly 

invoices and who should receive their semiarnmal progress repott and metrics. After further 

discussion and clarification with members of the Safe Havens team, the elements of quarterly 

invoice and quruterly performance metrics were reviewed ru1d they will include dates of 

service, employee information, and allocations of salaries and fringe benefits. 

Completing the elements required by Section F of the Semiannual Progress report is 

complicated by the need to parse out client infonnation in such a way that there are no 

unduplicated clients. l11e CSU had initially asked for reporting of this infom1ation on a 

quarterly basis; however, moving forward, LSNV will provide this infonnation at the time of 

the semirumual reports. 

The Cou1t Services Unit will draft and share a memorru1dum to Legal Services of Northern 

Virginia to make plain what reporting elements are required and what the timelines for 

submission are. 

As with Dootways, LSNV is committed to meeting all requirements for the Arlington Court 

Services to appropriately monitor LSNV as a subrecipient oftJ1e OVW Safe Havens grant. 

17 
APPENDIX 3 

OFFICE ON VIOLENCE AGAINST WOMEN 

RESPONSE TO THE DRAFT REPORT 

18 

U.S. Department of Justice 

Office on Violence Against Women 

Washington, DC 20530 

March 25, 2020 

TO: John Manning 

Regional Audit Manager 

THROUGH: Nadine M. Neufville A.,)Jn,,,,,J 

Deputy Director, Grants Development and Management 

Erin Lorah LJi/1. L 

Acting Director, Grants Financial Managen1ent Unit 

FROM: Rodney Sanmels ,(!:5 

Audit Liaison/Staff Accountant 

SUBJECT: Draft Audit Report- Audit of the Office on ViolenceAgainst 

Women (OVW) Grant Awarded to the Arlington County 

Supervised Visitation and Safe Exchange Program 

This memorandum is in response to your correspondence dated Febrnary 11, 2020 transmitting 

the above draft audit report for Arlington County Supen~sed Visitation and Safe Exchange 

Progran1 (Safe Havens). We consider the subject report resolved and request written acceptance 

of this action from your office. 

Toe report contains four recommendations with no questioned costs. OVW is committed to 

addressing and bringing the open reconunendations identified by your office to a close as quickly 

as possible. Toe following is our analysis of each recommendation. 

1. Requil'e that Safe Haveus officials implement policies and procedures to support 

pe1formanc.e and activities contained in each progress report "ith valid and auditable 

source documents, as required by the DOJ Grants Financial Guide. 

Concur: OVW will work with Safe Havens officials to in1plement policies and procedures to 

support performance and activities contained in each progress report ,vith valid and auditable 

source documents, as required by the DOJ Grants Financial Guide. 
SUBJECT: Draft Audit lleport - Audit of the. Office on Violeuce Against 

Women (OVW) Grant Awarded to the. Arlington County Supen,ised Visitation and Safe Exchange 

Program 

2. Cool'dinate with Saft Hanns officials to implement policies for how it allocates employee 

salaries and fringe bendits to Federal awuds. 

Concur: OV\\7 ,,ill coordinate ,,ith Safe Havens officials to implement policies for how it 

allocates employe.e salanes and fringe benefits to Feder al awards. 

3. \Vork with Safe Hanns to implement policies and procedures to guide subretipient site ,isits and nrify iJffoictd time charges~ to include the dates of the- performance ofsenices. 

Concur: OV\\7 ,,ill work with Safe Havens to implement policies and procedures to guide. 

subrecipient site. visits and verify invoiced time charges, to include the dates of the pe.rfonnauce 

of seivices. 

~. Cool'dinate with Saft Hanns officials to implement au effecthe, consistentdr-awdown 

policy that complies uich the DOJ Grants financial Guide. 

Concur: OV\\7 ,,ill coordinate ,,ith Safe Havens officials to implement an e.ffective, consistent 

drawdown policy that <Xllllplies with the DOJ Grants financial Gttide. 

\Ve appreciate the oppornmity to re.view and comment on the. draft report. If you have any 

questions or require additional information, please contact Rodne.y Samuels at 

(202) 514-9820. 

cc Erin Lorah 

Ac.ting Associate Director 

Office on Violence Against Women (OVW) 

1'>,rise.M. Duhamel, Ph.D. 

Acting Direc.tor, Internal Re.view and Evaluation Office. 

Audit Liaison Gro..ip, Justice Management Division 

Ganie Mitchell 

Program Manager 

Office on Violence Against Women 

Thelma Bailey 

Executive Assistant 

Office on Violence Against Women 

Page 2 ofl 

19 
 

 

 

APPENDIX 4 

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 Arlington County 

Supervised Visitation and Safe Exchange Program (Safe Havens) and the Office on 

Violence Against Women (OVW). Safe Havens’ response is incorporated in 

Appendix 2 and OVW’s response is incorporated in Appendix 3 of this final report. 

OVW concurred with and discussed how it will address each recommendation. As a 

result, the report is resolved. 

In its response, Safe Havens agreed with four of the five sections listed in the 

executive summary – Progress Reports, Grant Expenditures, Subrecipient 

Monitoring, and Drawdowns. However, Safe Havens disagreed that it lacked 

documentation to support certain grant accomplishments, a statement that we had 

included under the Program Goals and Accomplishments section of the draft 

report’s executive summary. Recognizing that Safe Havens lacked documentation 

to support certain measurements included in its progress reports, we adjusted the 

executive summary so that this statement is included under the Progress Reports 

heading. 

The following provides the OIG analysis of OVW’s and Safe Haven’s 

responses and a summary of actions necessary to close the report. 

Recommendations for OVW: 

1. Require that Safe Havens officials implement policies and procedures 

to support performance and activities contained in each progress 

report with valid and auditable source documents, as required by the 

DOJ Grants Financial Guide. 

Resolved: OVW concurred with our recommendation. OVW stated in its 

response that it will work with Safe Havens officials to implement policies and 

procedures to support performance and activities contained in each progress 

report with valid and auditable source documents, as required by the DOJ 

Grants Financial Guide. 

Safe Havens stated in its response that its management team will retain 

source documentation so that it may be easily accessed and audited. Safe 

Havens stated it will continue to maintain its population data in an official 

spreadsheet that captures information according to the grant’s required 

performance measures. Safe Havens detailed where it will store the 

documents, who will have access to the documents, and what information 

the documents will support. Safe Havens also stated that it will improve their 

efforts to ensure that the data is accessible and available for future auditing 

purposes. 

20 
 

This recommendation can be closed when OVW provides evidence that Safe 

Havens has implemented policies and procedures to support performance 

and activities contained in each progress report with valid and auditable 

source documents, as required by the DOJ Grants Financial Guide. 

2. Coordinate with Safe Havens officials to implement policies for how it 

allocates employee salaries and fringe benefits to Federal awards. 

Resolved. OVW concurred with our recommendation. OVW stated in its 

response that it will coordinate with Safe Havens officials to implement 

policies for how it allocates employee salaries and fringe benefits to Federal 

awards. 

Safe Havens stated in its response that its management team will implement 

a policy for the allocation of salaries, fringe benefits, compensatory time and 

overtime. Safe Havens stated it will submit a Grant Adjustment Notice 

(GAN) to follow this recommendation and also work with OVW when there is 

a change in scope, duration, program activities, or other significant areas. 

This recommendation can be closed when we receive evidence that Safe 

Havens officials have implemented policies for how it allocates employee 

salaries and fringe benefits to Federal awards. 

3. Work with Safe Havens to implement policies and procedures to 

guide subrecipient site visits and verify invoiced time charges, to 

include the dates of the performance of services. 

Resolved. OVW concurred with our recommendation. OVW stated in its 

response that it will work with Safe Havens to implement policies and 

procedures to guide subrecipient site visits and verify invoiced time charges, 

to include the dates of the performance of services. 

Safe Haven stated in its response that it has implemented reporting 

procedures that provide documentation to ensure subrecipients are fulfilling 

all financial and programmatic responsibilities. Safe Havens stated that its 

subrecipients now provide more complete financial and programmatic 

information with their quarterly invoices, to include the dates of service, 

employee information, rates billed, and clients served. Safe Havens advised 

it will conduct yearly subrecipient site visits to review records, interview staff, 

and ensure that services are being provided according to agreement terms. 

Safe Havens stated it will provide to OVW its policy and procedures for 

monitoring subrecipients, including procedures for site visits, invoices, 

performance metrics, and support documentation. 

This recommendation can be closed when we receive evidence that Safe 

Havens has implemented policies and procedures to guide subrecipient site 

visits and verify invoiced time charges, to include the dates of the 

performance of services. 

21 
4. Coordinate with Safe Havens officials to implement an effective, 

consistent drawdown policy that complies with the DOJ Grants 

Financial Guide. 

Resolved. OVW concurred with our recommendation. OVW stated in its 

response that it will coordinate with Safe Havens officials to implement an 

effective, consistent drawdown policy that complies with the DOJ Grants 

Financial Guide. 

Safe Havens stated in its response that it will coordinate with OVW to provide 

for an effective, consistant drawdown policy that complies with the DOJ 

Financial Guide. A revised policy and procedure for drawdowns will be 

submitted to OVW as a GAN. 

This recommendation can be closed when we receive evidence that Safe 

Havens officials have implemented an effective, consistent drawdown policy 

that complies with the DOJ Grants Financial Guide. 

22 
 

 

 

-

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

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oig.justice.gov @JusticeOIG JusticeOIG

Also at Oversight.gov