Grant Monitoring Standards & Guidelines

for

Hiring and Redeployment

Office of Community Oriented Policing Services 

U.S. Department of Justice 

July 2001 
TABLE OF CONTENTS 

I. PURPOSE OF THE MONITORING STANDARDS GUIDE 1

II. PURPOSE OF THE COPS GRANT PROGRAMS 2

III. TYPES OF GRANTS 3

IV. MONITORING AND AUDITING REQUIREMENTS 5

V. COPS COMPLIANCE DEFINITIONS & CONDITIONS 10

A. Community Policing 10

B. Time Savings for Redeployment 16

C. Retention 20 

D. Allowable Costs 23 

E. Source of Matching Funds 28

F. Supplanting 31 

G. Training: Special Conditioned Grantees 36 

H. Reporting 37 

VI. COPS PERFORMANCE INDICATORS 40

A. Community Policing 41

B. Time Savings for Redeployment 42

C. Retention 44 

D. Allowable Costs 46 

E. Source of Matching Funds 49

F. Supplanting 51 

G. Training: Special Conditioned Grantees 55 

H. Reporting 56 

Appendix A: Glossary of Terms 58

Appendix B: Examples of Compliance/Non-Compliance Cases 64

Appendix C: Grant Threshold Review Dates 68

Appendix D: Examples of Redeployment Tracking 69

Appendix E: Reference Material 85

Grant Monitoring Standards for Hiring and Redeployment 

Revised July 2001 
I. Purpose of the Monitoring Standards Guide 

The purpose of this Monitoring Standards Guide is to provide assistance with the 

monitoring, administration, and auditing of grant performance and compliance 

requirements. These activities help determine whether or not Community Oriented 

Policing Services (COPS) grantees are complying with their Hiring and Making Officer 

Redeployment Effective (MORE) grant terms and conditions. The eight compliance 

categories that interpret the terms and conditions for Hiring and MORE grants are: 

community policing; time savings for redeployment; retention; allowable costs; source of 

matching funds; supplanting; training special condition; and reporting. 

This Monitoring Standards Guide provides two major functions for the Hiring and MORE 

grant programs. First, it provides a definition of each of the eight compliance categories, 

as well as the specific terms and conditions required to comply with the COPS Hiring and 

MORE grant programs. Second, it provides a list of performance standards and indicators, 

for each category, which can be used to help determine whether grantees are meeting the 

intent of the COPS grant programs. Also included in the beginning of this guide are a 

summary of the COPS grants and an explanation of the program's monitoring and auditing 

activities that grantees can expect upon grant award. 

Grant Monitoring Standards for Hiring and Redeployment 1 

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II. Purpose of the COPS Grant Programs 

When the Violent Crime Control and Law Enforcement Act of 1994 was signed into effect, 

it authorized the allocation of over $8.8 billion to rehire or hire and train additional career 

law enforcement officers for deployment in community oriented policing across the 

country. The U.S. Department of Justice (DOJ) Community Oriented Policing Services 

(COPS) Office is responsible for implementing the law, supporting the addition of officers 

and promoting community policing strategies. 

The goals of the COPS Office are to provide community policing officers or sheriff’s 

deputies to America’s neighborhood streets and advance community policing nationwide. 

Community policing can assist in reducing levels of violence, crime, and disorder in 

communities. 

Community policing is an integral part of combating crime and improving the quality of 

life in the nation's cities, towns, and rural areas. This approach requires the police and 

citizenry to join together as partners in the course of both identifying and effectively 

addressing the causes and prevention of crime and disorder. 

The overall intent of the grant program is to help develop an infrastructure that will 

institutionalize and sustain community policing after Federal funding has ended. The 

money awarded to the nation’s law enforcement agencies is “seed” money that provides 

communities with enough resources to begin implementing community policing or to 

further advance existing community policing strategies. 

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III. Types of Grants 

Two of the main categories of grants offered under the COPS Program are Hiring and 

MORE. Of the Hiring grants, five major types were implemented at different stages of the 

COPS Program. (Other UHP and Innovative Grants are not specifically addressed in this 

manual.) Below is a chronology of those COPS grant programs: 

��Phase I

��Funding Accelerated for Smaller Towns (FAST) 

��Accelerated Hiring, Education, and Deployment (AHEAD) 

��Making Officer Redeployment Effective (MORE) 

��Universal Hiring Program (UHP) 

��COPS in Schools Program (CIS) 

Phase I FAST AHEAD MORE UHP CIS 

The first of these Hiring grants, the Phase I grant, superseded the Police Hiring 

Supplement (PHS) grant. The PHS, administered by the Bureau of Justice Assistance, was 

created with the intent to increase police presence in America’s communities. Limited 

funding prohibited the full implementation of PHS, and, consequently, only 9% of the 

overwhelming number of applicants were funded. With the creation of Phase I grants, 

$200 million was distributed in October 1994 to the remaining qualified PHS applicants to 

hire community policing officers. 

FAST and AHEAD were the next two programs created by COPS in March and April 

1995, respectively. The FAST Program provided funds to law enforcement agencies for 

hiring community policing officers in communities whose populations were less than 

50,000. The FAST initial applications to determine eligibility were streamlined to one 

page and the funds awarded were expedited. 

The purpose of the AHEAD Program was to provide funds to law enforcement agencies 

for the purpose of hiring community policing officers. The AHEAD Program provided 

funds to communities whose populations were 50,000 or more. 

The MORE Programs provide funds to acquire civilians and new technologies. The 

purpose of these acquisitions is to save sworn officers’ time spent on administrative and 

support tasks, thereby allowing them more time for community policing. Each item or 

position funded under the MORE Program must free up time for a sworn officer. With the 

extra time, the officer performs community policing activities, and/or the community 

Grant Monitoring Standards for Hiring and Redeployment 3 

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policing of the department is enhanced. It should be noted that overtime is also an 

allowable expense but only for the MORE ’95 grants. It is not allowable under AHEAD, 

FAST, UHP, or other MORE grant programs. 

The UHP superseded FAST and AHEAD as the primary Hiring Program. Funds awarded 

under the program are to assist law enforcement agencies in hiring additional community 

policing officers. The population of the community is not a qualifying factor for 

determining initial eligibility under the UHP. 

The CIS Grant Program provides an incentive for law enforcement agencies to build 

working relationships with schools to use community policing efforts to combat school 

violence. 

Grant Monitoring Standards for Hiring and Redeployment 4 

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IV. Monitoring and Auditing Requirements 

Federal regulations require that any financial assistance from the Federal government be 

monitored to ensure that funds are spent properly. All grantees are subject to participate in 

several grant monitoring and auditing activities by the COPS Office, DOJ Office of the 

Inspector General (OIG), DOJ Office of Justice Programs’ Office of the Comptroller (OC), 

U.S. General Accounting Office (GAO), and other duly authorized representatives. 

The purpose of monitoring is to ensure that grantees meet their programmatic and financial 

requirements. This will result in the achievement of the grantees’ goals, and the successful 

implementation of the COPS Program. In general, the COPS Office monitors program 

activities and financial activities. Monitoring activities include on-site reviews, OfficeBased Grant Reviews, COPS Count telephone-based surveys, and office-based legal, 

financial, and complaint reviews. 

In addition to oversight, guidance and counsel provided by the COPS, grants may be 

subject to an audit by independent examiners. The two primary types of audits are Single 

Audit Act (SAA) audits and DOJ OIG audits. These audits are designed to determine 

whether systems are in place, controls established, and reports provide reasonable 

assurance that the grantee is managing funds in compliance with laws and regulations. 

Failure to comply with audit requirements may result in adverse current and future funding 

determinations. 

COPS MONITORING 

The COPS Office is responsible for monitoring programmatic issues related to grant awards. Five 

activities may be used to monitor grant awards by COPS: 1) on-site program reviews, 2) COPS 

Count, 3) Office-Based Grant Reviews, 4) complaint reviews, and 5) program report reviews. 

COPS On-Site Program Reviews. The objective of the COPS on-site reviews is to assist 

in ensuring that grantees meet their programmatic requirements. Using site visits as a 

primary vehicle, the COPS Office is committed to assuring that COPS grants are properly 

and effectively implemented pursuant to the authorizing statute, grant assurances and 

guidelines, and all applicable federal statutes and regulations. 

A site visit provides the COPS Office with the knowledge and documentation of how 

COPS funds are being used; how compliance issues are being addressed by the grantee; 

and provides firsthand observation of COPS program implementation and progress. If 

problems are cited during a review, then the necessary documentation is gathered and the 

problems are referred to the appropriate COPS division for resolution. 

Grant Monitoring Standards for Hiring and Redeployment 5 

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COPS Count. COPS Count is a telephone survey conducted to provide an accurate 

accounting of hiring and redeployment of law enforcement officers funded by the COPS 

Office. 

During the survey, COPS Hiring and MORE grant recipients are contacted by telephone 

and asked for information regarding the status of their grants as of a selected date. This 

survey information is then summarized and compared with the total number of officers 

funded as of the same selected date. Specific survey information includes whether officers 

have been hired; hire dates of officers, demographic information of the officers, and duties 

and responsibilities of the officers; redeployment dates and related questions for MORE 

grants; and grantee plans concerning future hiring and redeployment. 

Office-Based Grant Reviews (OBGR). The Office-Based Grant Review (OBGR) serves 

as a supplemental activity in support of the overall grant monitoring strategy. It is 

intended to provide detailed grant monitoring oversight for the smaller COPS’ grantees 

that do not meet the on-site monitoring criteria due to their location, status, and/or amount 

of funding. The OBGR specifically targets COPS’ hiring grantees although other types of 

grants may be reviewed for the same grantee. 

Similar to an on-site program review, the OBGR begins with an internal review of grant 

documentation followed by direct contact with the grantee and the collection of additional 

and/or supporting documentation demonstrating compliance with grant requirements. It 

allows the COPS Office to monitor an overall larger number of grantees representing rural 

or small agencies than would otherwise be possible only through conducting site visits. 

Complaint Reviews. The complaint review system provides a centralized process within 

the COPS Office to coordinate the follow-up on external (media, citizens, etc.) and internal 

reports of non-compliance. A determination is made whether the issues can be resolved 

through phone or letter contact, or if a site visit is warranted by COPS or OIG. The 

complaint review process includes a review of grantee Program Progress Reports, COPS 

Count data, COPS Finance/OIG site visit reports, and contact with the grant program 

advisor and Legal Division. Oftentimes, possible non-compliance issues can be resolved 

through phone contacts with grantees and receipt of documentation without on-site visits 

being conducted. 

Program Report Reviews. Grant monitoring is supplemented by reviews of the grant 

Program Progress Reports. The COPS Office reviews progress reports submitted by 

grantees throughout the life of the grant. Grantees awarded Hiring grants must submit a 

Department Initial Report (if the grantees have never previously received a COPS Hiring 

grant) and a Department Annual Report. MORE grantees must submit one MORE 

Progress Report. 

Grant Monitoring Standards for Hiring and Redeployment 6 

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FINANCIAL MONITORING 

The COPS Office or designated representation will be responsible for monitoring financial 

issues related to grant awards. There are two activities that may be used to monitor grant 

awards: 1) on-site financial reviews and 2) office-based financial reviews. 

On-Site Financial Reviews. On-site financial reviews are conducted at the grantee’s 

location to assess overall financial management of a grant with a focus on providing the 

grantee with immediate technical assistance to correct any weaknesses identified. The onsite financial review includes a review of: (1) the grantee’s accounting system and internal 

control over the administration of COPS grants; (2) the grantee’s cash management 

procedures; (3) the timeliness and accuracy of Financial Status Reports submitted, and (4) 

the expenditures charged to the grant to determine if expenditures are allowable and 

supported. If any weaknesses are noted, COPS personnel, or designated representation, 

will provide technical assistance to individual grantees while on site to ensure weaknesses 

identified through financial monitoring are corrected. 

Results of financial monitoring are used to refine policy guidance to grantees. 

Additionally, these results are used in grantee financial management training seminars to 

highlight the types of weaknesses most commonly identified, and to provide grantees with 

training on how to avoid those same common errors in their organizations. For those 

grantees unable to attend financial management training, additional technical assistance on 

financial issues can be obtained by calling the DOJ Response Center at 1-800-421-6770. 

Office-based Financial Reviews. Grantees are required to submit financial status reports 

quarterly to COPS detailing grant obligations and expenditures. The office-based financial 

review includes an analysis of grant activity to date, financial reporting, payments under 

the grant, and audit reports issued on the grant. If financial problems are identified 

through the review process, then grantees are provided immediate technical assistance via 

the telephone and/or identified for a future on-site financial review. 

AUDITING 

OIG Audits. The OIG is an independent agency within DOJ authorized to conduct audits 

related to DOJ program, financial, and administrative operations. OIG audits are designed 

to promote economy, efficiency, and effectiveness in the administration of grants by 

evaluating compliance with laws, regulations, and policies and procedures governing the 

operations encompassed in the scope of the audit. 

Typically, OIG audits encompass all Hiring and MORE grants awarded to the agency, both 

active and expired. OIG conducts testing to determine compliance with program, 

administrative, and financial requirements for each of the grants selected. Compliance 

areas may include, but not be limited to, supplanting, retention, allowable costs, local 

match, redeployment, financial and programmatic reporting, and community policing grant 

provisions. Once testing is completed, OIG issues a report which includes an analysis of 

Grant Monitoring Standards for Hiring and Redeployment 7 

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areas deemed to be in noncompliance and recommendations to correct problem areas. 

OIG’s recommendations may include returning a portion, or all, of the grant funding. As 

such, it is imperative that the grantee remain aware of and comply with grant provisions, 

implement effective accounting systems, and maintain detailed, accurate records 

supporting grant administration. 

Independent Audits. 

The Single Audit Act (SAA) was created in 1984, and established uniform guidelines for 

State and local governments receiving Federal financial assistance. The 1984 Act was 

amended in July 1996 to reflect revised audit criteria and reporting requirements. The 

Office of Management and Budget Circular A-133, Audits of States, Local Governments, 

and Non-Profit Organizations, provides additional guidelines regarding the implementation 

of SAA requirements. 

Each non-Federal entity that expends a total amount of Federal awards equal to, or in 

excess of, $300,000 in a fiscal year, shall have an SAA audit for that fiscal year. 

An SAA audit is an examination of a non-Federal entity’s financial statements and Federal 

awards by public accountants or Federal, State or local government audit organizations. 

The purpose of the SAA audit is to determine: 1) whether financial statements are 

presented fairly, in conformity with generally accepted accounting principles, 2) whether 

the schedule of expenditures of Federal awards is presented fairly in relation to the 

financial statements taken as a whole, 3) if internal controls are sufficient to minimize risk, 

and 4) compliance with laws, regulations, and grant provisions having a material effect on 

major programs. 

Grant Monitoring Standards for Hiring and Redeployment 8 

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TERMINATION OF GRANT FUNDING 

The COPS Office may terminate or suspend funding of a grant in whole or in part if, as a 

result of the reviews, the COPS Office determines that a grant recipient is not: 

�� substantially complying with the requirements of the Act, the guidelines or with other 

provisions of Federal law; 

�� making satisfactory progress toward the goals or strategies in the application and 

information as reflected by performance and status reports; 

�� adhering to grant agreement requirements or conditions; 

�� submitting reports in a timely manner; 

�� filing accurate certification in connection with an application, periodic report, or other 

documents submitted to the COPS Office or the OC; or 

�� submitting for prior approval to the COPS Office any significant changes that grantee 

anticipates being made to the application before implementing those changes. 

In taking an enforcement action, COPS will provide the grantee an opportunity for a 

hearing, appeal, or other administrative proceeding to which the grantee is entitled under 

any statute or regulation applicable to the action involved. 

In the event that sanctions are imposed or a grant is terminated, COPS will notify the 

grantee of the decision, in writing, and the reason for that decision. 

Grant Monitoring Standards for Hiring and Redeployment 9 

Revised July 2001 
V. COPS Compliance Definitions & Conditions 

The eight compliance categories that define the terms and conditions of the COPS Hiring

and MORE grant programs are: 

A) Community Policing

B) Time Savings for Redeployment 

C) Retention 

D) Allowable Costs 

E) Source of Matching Funds 

F) Supplanting

G) Training

H) Reporting

This section defines the eight categories and provides the accompanying conditions that are 

required to be in compliance with the COPS Hiring and MORE grants. Each category also 

includes examples to clarify special conditions or calculations further. 

It is important to note that the Time Savings for Redeployment category pertains to the 

MORE Grant Program only. All other categories pertain to both the Hiring and MORE 

grant programs. 

A. Community Policing 

DEFINITION 

Community Policing is a philosophy that promotes and supports organizational strategies 

to address the causes and reduce the fear of crime and social disorder. This is achieved 

through problem-solving tactics and community-police partnerships. It enhances police 

professionalism by providing officers with the skills, technology, and motivation to act 

innovatively to solve community crime-related problems. 

This community policing approach requires the police and citizenry to join as partners in 

the course of both identifying and effectively addressing the causes of crime and disorder. 

The focus of the police is not only on enforcement, but also on emphasizing the need for 

crime prevention and for proactively addressing the root causes of crime and disorder. The 

community is actively engaged in collaborating on prevention and problem-solving 

activities with a goal of reducing victimization and fear of crime. 

CONDITIONS 

The COPS Office maintains the position that local agencies are best suited to determine 

their community crime-related problems and the policing activities that will solve them. 

Police, community members, and other public and private entities work together to address 

the underlying problems that contribute to crime and disorder by identifying and analyzing 

Grant Monitoring Standards for Hiring and Redeployment 10 

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problems, developing suitable responses, and assessing the effectiveness of these 

responses. Acceptable community policing activities are unique to each local community 

and must be addressed on a case-by-case basis. 

Required Number of Community Policing Officers. Under COPS Hiring grants, 

every grant-funded officer position (or an equal number of veteran officer positions) is 

required to initiate or enhance community policing. For example, a COPS Universal 

Hiring Program grantee with 10 COPS grant-funded officers must deploy 10 officers 

(COPS-funded or additional veteran officers) to initiate or enhance community policing 

through the approved community policing plan. This does not mean that every hour of the 

officers’ time must be spent in a specific community policing “activity,” but it does mean 

that the grantee must show the required number of officers initiating or enhancing 

community policing. 

Community Policing Activity Approval. The COPS Office is responsible for 

determining the applicability of grant awards to the community policing plan that are 

identified in grant applications. Community policing activities that will be executed by 

local law enforcement agencies are identified on grant applications and approved by the 

COPS Office before the grant is awarded. Grantees are not required to implement every 

community policing activity identified on the approved plan to demonstrate compliance. 

Instead, the plan may often identify a broad range of possible community policing 

activities, with the grantee implementing specific community policing strategies from the 

approved plan on an as-needed basis throughout the life of the grant. 

Changes to Community Policing Plans. Any significant changes to the community 

policing plan identified in the grant application must be submitted in writing to the COPS 

Office. Changes are “significant” if they deviate from the range of possible community 

policing activities identified and approved in the grantee’s original community policing 

plan. 

Evidence of Community Policing Philosophy. Integrating community policing into a 

traditional policing environment is an evolutionary process. The COPS grant award is an 

aid to this evolutionary process and, therefore, the evaluation of community policing 

activities is unique to each local agency. 

Evidence that law enforcement agencies are incorporating a community policing policy is 

witnessed through three core elements: 1) police organizational elements, 2) tactical 

elements, and 3) external elements. Agencies may be anywhere on the continuum of 

incorporating community policing into their operations; therefore, the extent to 

which these elements are adopted by agencies varies. 

Grant Monitoring Standards for Hiring and Redeployment 11 

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1. Police organizational elements 

a. Philosophy adopted organization-wide. Department-wide adoption of community 

policing is evidenced by the integration of the philosophy into mission statements, 

policies and procedures, performance evaluations and hiring, promotional 

practices, training programs, and other systems and activities that define 

organizational culture and activities. 

b. Decentralized decision making and accountability. In community policing, 

individual line officers are given the authority to solve problems and make 

operational decisions concerning their roles, both individually and collectively. 

Leadership is required and rewarded at every level, with managers, supervisors 

and officers held accountable for decisions and the effects of their efforts at 

solving problems and reducing crime and disorder within the community. 

c. Fixed geographic accountability and generalist responsibilities. In community 

policing, the majority of staffing, command, deployment and tactical decisionmaking is geographically based. Appropriate personnel are assigned to fixed 

geographic areas for extended periods of time in order to foster communication 

and partnerships between individual officers and their community. These 

personnel are accountable for reducing crime and disorder within their assigned 

area. 

d. Utilization of Volunteer Resources. Community policing encourages the use of 

non-law enforcement resources within a law enforcement agency. The law 

enforcement organization educates the public about ways that they can work in 

partnership with the organization and its members to further community policing, 

and provides an effective means for citizen input. Volunteer efforts can help to free 

up officer time, and allow sworn personnel to be more proactive and prevention 

oriented. 

2. Tactical elements 

a. Enforcement of laws. Community policing complements the use of proven and 

established enforcement strategies, becoming one of many tools available to 

officers that can be collectively employed to prevent and combat crime. Police 

departments should be active partners in identifying laws that need to be amended 

or enacted, and work with lawmakers and organize citizen support efforts to change 

them. 

b. Proactive, crime-prevention oriented. Under community policing, the focus of the 

police is not only on enforcement, but also emphasizes the need for crime 

prevention and for proactively addressing the root causes of crime and disorder. 

The community is actively engaged in collaborating on prevention and problemsolving activities with a goal of reducing victimization and fear of crime. 

Grant Monitoring Standards for Hiring and Redeployment 12 

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c. Problem solving. Police, community members, and other public and private 

entities work together to address the underlying problems that contribute to crime 

and disorder by identifying and analyzing problems, developing suitable responses, 

and assessing the effectiveness of these responses. While enforcement is an 

integral part of policing, problem solving relies more on preventing crime through 

deterring offenders, protecting likely victims, and making crime locations less 

conducive to problems. 

3. External elements 

a. Public involvement and community partnerships. In community policing, citizens 

are viewed by the police as partners who share responsibility for identifying 

priorities, and developing and implementing responses. Accurate surveying of 

customer needs and priorities is one way to determine the problems that drive 

police services, and give the public ownership of the problem-solving process. 

b. Government and other agency partnerships. Under community policing, other 

government agencies are called upon and recognized for their ability to respond to 

and address crime and social disorder issues. The support and leadership of elected 

officials, as well as the coordination of the police department at all levels, are vital 

to the success of these efforts. 

Career Law Enforcement Officer. Hiring grants allow for payment of approved entrylevel salaries and benefits for the hiring or rehiring of additional sworn career law 

enforcement officer positions for deployment in community policing activities. A "sworn 

career law enforcement officer" is a person hired on a permanent basis who is authorized 

by law, by a State or local public agency, to engage in or oversee the prevention, detection, 

or investigation of violations of criminal laws. 

Cops in Schools (CIS) School Resource Officer (SRO). The COPS in Schools Grant 

Program provides an incentive for law enforcement agencies to build working relationships 

with schools to use community policing efforts to combat school violence. Grant funds 

allow for the hiring of new, additional School Resource Officers over and above the 

number of sworn officers that an agency would fund with State or local funds in the 

absence of the grant (including other School Resource Officers). 

The COPS statute defines a “School Resource Officer” as a career law enforcement officer, 

with sworn authority, deployed in community oriented policing, assigned by the employing 

police department or agency to work in collaboration with schools and community-based 

organizations to: 

Grant Monitoring Standards for Hiring and Redeployment 13 

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1. address crime and disorder problems, gangs, and drug activities affecting or occurring 

in or around an elementary or secondary school; 

2. develop or expand crime prevention efforts for students; 

3. educate likely school-age victims in crime prevention and safety; 

4. develop or expand community justice initiatives for students; 

5. train students in conflict resolution, restorative justice, and crime awareness; 

6. assist in the identification of physical changes in the environment that may reduce 

crime in or around the school; and 

7. assist in developing school policy that addresses crime and recommend procedural 

changes. 

MORE Grants Support Community Policing. Community policing activities that are 

supported by MORE grants adhere to the same criteria as the Hiring grants; however, 

funding indirectly relates to community policing activities. Sworn officers are redeployed 

to enhance community policing activities as a result of time savings achieved through the 

use of technology, equipment, overtime, or civilian support services that are funded by 

MORE grants. 

Grant Monitoring Standards for Hiring and Redeployment 14 

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Examples - Can be Funded for Community Policing Activities 

(Note: This list is NOT inclusive of all community policing activities.) 

�� Crime Prevention Efforts 

Examples: Youth programs; anti-drug programs; regular meetings with community 

groups to discuss crime; and anti-violence programs. 

�� Problem-Solving Activities 

Examples: Identifying crime problems with members of the community and other 

government agencies (e.g., probation office, prosecutor and courts); identifying 

crime problems by looking at crime trends; identifying top problems by analyzing 

repeat calls for service; preventing crime by focusing on conditions that lead to 

crime (e.g., abandoned buildings and cars); and building on information systems to 

enhance crime analysis capabilities. 

Examples: Working with citizens to identify and address community crime 

problems; using computer systems to collect and analyze information, particularly 

repeat calls for service; coordinating specific problem-solving projects to address 

problems on their beats; working with other public agencies to solve disorder 

problems (e.g. trash collection, public works agencies to solve lighting problems); 

and mapping crime problems. 

��Community Partnerships 

Examples: Regularly surveying community members to assist in identifying and 

prioritizing crime problems; locating an office or stations within neighborhoods; 

providing community policing training to citizens; meeting with community 

members to learn more about the nature of specific problems; and involving 

community members in selecting responses to problems and determining measures 

of success. 

Examples: Participating in neighborhood watch programs, citizen volunteer 

programs, citizen advisory groups to the law enforcement agency; citizen patrols 

within the community; and anti-drug or anti-violence programs. 

Examples: Participating with community organization working groups and/or 

special programs for schools and other interest groups which enhance crime 

prevention. Program examples are: Drug and Alcohol Resistance Education 

(DARE), Gang Resistance Education and Training (GREAT), Triad, School 

Resource Officer (SRO). 

�� Other Agency Partnerships 

Examples: Juvenile justice services; probative, social services; parole; city and 

county departments; trash removal; school system; elected officials; and other 

public service providers. 

Grant Monitoring Standards for Hiring and Redeployment 15 

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�� Patrol 

Examples: Targeted geographic patrol, foot patrol, bike patrol or mounted patrol; 

making door-to-door contact with citizens and businesses; meeting with community 

leaders and groups to learn more about crime problems and jointly develop crime 

prevention plans; using business cards, cellular phones or beepers to maintain 

contact with citizens regarding public safety concerns; and working in schools or 

other public agencies to teach crime prevention. 

B. Time Savings for Redeployment 

DEFINITION 

Time Savings for Redeployment applies only to the MORE Grant Program. The COPS 

MORE Program goal is to reduce the amount of paperwork and administrative tasks 

performed by veteran sworn trained officers so that they can spend more time on the street 

and in America's neighborhoods. Grants awarded under MORE are restricted to the 

purchase of technology, equipment, overtime for officers (MORE ’95 only), and the hiring 

of civilian support resources that will redeploy officers, or full-time equivalents (FTEs), 

and enhance community policing activities within the agency's jurisdiction. 

The time saved through MORE-funded technology, equipment, overtime, and civilians 

must result in an increase in the number of officer FTEs redeployed. Redeployment of 

officer FTEs applies to sworn officers currently employed by the grantee who will be able 

to enhance community policing activities as a direct result of the purchase of the 

technology, equipment, overtime, or support services. Award of a MORE grant requires 

that the number of officers redeployed will be equal to or greater than the number of 

officers that would result from a COPS grant for hiring officers. Some MORE grantees 

with overtime and civilian hire grants received renewals for an additional 12 or 24 months 

and were required to demonstrate continued, but not additional, time savings or 

redeployment of officers with the new funds. 

CONDITIONS 

To meet the redeployment grant condition, applicants must ensure that the Time Savings 

for Redeployment that results from COPS MORE funding enhances community policing 

activities. Agencies must track time savings and the redeployment of time savings into the 

community policing program after full implementation to assure COPS that, as a result of 

the grant award, community policing is being enhanced; however, there is no requirement 

to track every hour of time saved to an hour of community policing. 

The Time Savings for Redeployment condition results from: 1) technology or equipment; 

2) overtime; and 3) civilians. Technology or equipment time savings is the amount of 

officer's time that the equipment or technology frees up by its use. Overtime time savings 

results from paying currently employed sworn officers additional monies for working 

Grant Monitoring Standards for Hiring and Redeployment 16 

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additional hours beyond the normal workweek to engage in community policing activities. 

Civilian time saving is the amount of time an officer was assigned to a job that is now 

being done by a civilian who replaced the officer. 

The level of Time Savings for Redeployment of FTEs that is indicated in the application is 

a condition of awarding the funds. The FTE requirement is located on the award document 

that was signed by the Director of the COPS Office and accepted by the grantee's law 

enforcement executive. The COPS Office standard for a full-time-equivalent sworn officer 

equals 1,824 hours. The COPS Office recognizes that, due to differences in shift hours, 

there may be slight variances in the number of officers redeployed between a grantee and 

the COPS Office standard formula for calculating redeployment. 

Evidence of Time Savings. Agencies granted an award under the MORE Program are 

required to plan and track Time Savings for Redeployment realized from the equipment, 

technology, overtime (only for MORE ’95 recipients), and civilians awarded 

(MORE 2000-funded civilian support resources only). Once the technology or equipment 

funded by the grant is implemented and fully operational, as determined by the law 

enforcement agency, the grantees must complete a time savings tracking plan. This 

tracking plan describes the grantee’s methodology for measuring the time savings for each 

item, system or group of like items requested as identified by the grantee. 

Actual tracking, pursuant to the plan, will begin after such single stand-alone, independent 

element, function, or operation in a geographic area is fully implemented as contained in 

the plan. Tracking must continue for at least one full year from the date that the 

technology or equipment is implemented and declared fully operational. This time is 

necessary for the agency to achieve the total time savings benefit identified. 

The same tracking plan and actual tracking requirements, discussed above, apply to 

civilian awards under MORE. Tracking should begin for the civilian time savings and 

redeployment when civilian personnel, of each varying title/type, realize maximum time 

savings. Tracking must continue for at least one full year from the date that the civilians 

were declared fully operational by the grantee. 

Information on developing and implementing redeployment tracking plans may be 

obtained from a COPS grant program specialist and can be found on the COPS/MORE 

Home Page at www.COPS.usdoj.gov. 

No one method to track time savings can adequately cover all situations and all 

jurisdictions because each jurisdiction varies in size and each situation varies in 

complexity. Tracking methods can vary from estimating hours saved to directly tracking 

hours. The tracking method for time savings should, at least, demonstrate the time that is 

currently spent on duties without additional equipment or technology and how much time 

is spent on those same duties after the equipment or technology is operational. To assist 

with tracking redeployment, grantees can use baseline time data prior to grant 

implementation. 

Grant Monitoring Standards for Hiring and Redeployment 17 

Revised July 2001 
All grantees must maintain the details of worksheets, studies, or any other written evidence 

that was used to track time savings. The documentation must be kept at the local law 

enforcement agency. Grantees are required to produce time savings tracking plans and 

supporting tracking documentation during any monitoring or audit site visits. 

Sworn officers should be fully aware of the community policing activities that are part of 

the local department's strategy. These are the activities that officers should carry out as a 

result of time saved. Time savings should initiate or enhance community policing 

activities that have been approved through the grant program; however, not every hour of 

time savings needs to be committed to a specific “community policing activity.” 

Elements of a Tracking Plan. Tracking plans must include a statement explaining how 

time is being saved, the method used to track time savings (estimation, direct tracking 

sample, study, etc.), the hours to complete the activity before and after the equipment or 

technology is implemented, and a short description of enhanced community policing 

activities resulting from the time savings. 

Once fully operational, and time savings has been tracked, a determination can be made 

about the actual total hours saved. Examples of time savings calculations are provided at 

the end of this section. 

To demonstrate compliance in reaching required levels of redeployment, grantees must 

demonstrate satisfactory progress in implementing their COPS MORE grants. Delays in 

grant implementation may result in a finding of noncompliance (and possibly termination 

of the grant award) if grantees are unable to document satisfactory progress in 

implementing the grant program (e.g., by documenting the time line of a lengthy 

procurement process). 

Examples - How to Calculate Time Savings 

�� An agency applied for and received four laptop computers to complete paperwork in 

their patrol cars. In the application, the agency estimated that using laptops to 

complete incident reports would reduce the time previously spent by half. After 

becoming fully operational, the agency performed a time study pursuant to their 

tracking plan. 

There are currently 10 officers in the department who realize this time savings. It took 

each officer two hours per officer per shift to complete their paperwork before receiving 

COPS-funded laptops. If the agency's tracking period is quarterly and the Time Savings 

for Redeployment is tracked for the first quarter, the redeployment tracking is computed as 

follows: 

10 officers x 1 hour saved each shift/officer 

x 57 shifts (number of shifts worked by each officer this quarter using the COPS 

standard of 228 shifts per year) 

= 570 hours saved in the first quarter 

Grant Monitoring Standards for Hiring and Redeployment 18 

Revised July 2001 
Although the total number of hours achieved in the first quarter has been calculated, 

one last step remains. To determine the total FTEs redeployed in the first quarter, the 

time saved (570 hours) would be divided by 1,824 hours (number of FTE hours per 

year). In this case, .3 FTEs should have been tracked by the agency in the first quarter 

using the laptops awarded under the COPS MORE grant. 

Some other examples of calculating redeployment, for 1 full year of redeployment, or for 3 

months of redeployment: 

�� One-to-one civilian redeployment equals the amount of time an officer was assigned to 

a job that is now being done by a civilian who replaced the officer. 

1 full year: 1 officer x 8 hours per shift x 228 shifts (COPS standard) = 1,824 hours 

saved 

1,824 hours/1,824 hours (the COPS standard) = 1 FTE 

��Time savings may also be realized by multiple officers from a civilian hire. For 

instance, a department may hire a full-time civilian Community Service Officer to 

handle non-emergency calls. This may result in a time savings of 1.5 hours per shift 

for 7 officers in the department. In this case, redeployment could be calculated in the 

following manner: 

7 officers will save 1.5 hours per officer per shift 

x 57 shifts in a quarter (using the COPS standard 228 shifts per year) 

=599 hours / 1,824 hours (COPS standard) = .33 FTEs 

Summary redeployment tracking worksheet example. The following summary 

redeployment tracking worksheet serves as a guide for reporting on time savings tracked 

by grantees. 

Redeployment Tracking Worksheet Equipment 

Item #1 

Equipment 

Item #2 

Civilian 

#1 

Civilian 

#2 

Overtime 

Number of Items Awarded 

Number of Items Operational and in 

Use During Redeployment Tracking 

Period 

Number of Officers Saving Time Using 

Item Average Time Saved Per Officer 

Each Shift (Hours) 

Number of Shifts Per Officer 

Total Time Savings (Hours) 

/ 1,824 hours 

Total FTE’s Saved to Date 

Grant Monitoring Standards for Hiring and Redeployment 19 

Revised July 2001 
C. Retention 

DEFINITION 

Hiring grantees must plan to retain the additional federally funded positions at the 

conclusion of the Hiring grant funding period.1 MORE grantees must plan to retain the 

federally funded technology/equipment and/or civilians2 and the resulting redeployment 

once the required level of redeployment3 has been met. A distinction is made between 

planning to retain and actual retention. 

Retention planning for Hiring grants must demonstrate that a sincere and legitimate 

attempt was made by the law enforcement agency and by the governing body to secure and 

provide local funding to employ the additional federally funded officer positions at the 

conclusion of the grant funding period. MORE grantees are required to retain the federally 

funded technology/equipment and/or civilians and the resulting redeployment awarded 

under MORE grant awards. 

A retention plan must be submitted with the Hiring grant application, beginning with 

applications submitted after June 16, 1998. MORE 98 and 2000 grantees were required to 

submit a retention statement with their grant award application. For grantees that were not 

previously required to submit a retention plan with the grant application, the COPS Office 

may require evidence of retention planning efforts anytime during the Hiring grant funding 

period for Hiring grants or the redeployment period for MORE grants. 

The COPS Office will measure successful retention as retention for one full local budget 

cycle following the conclusion of the Hiring grant funding period for Hiring grants or 

following the achievement of the required level of redeployment for MORE grants. 

CONDITIONS 

Hiring grantees must plan to retain the additional federally funded positions at the 

conclusion of the Hiring grant funding period with non-COPS grant funding for one full 

local budget cycle. MORE grantees must plan to retain the federally funded 

technology/equipment and/or civilians and the resulting redeployment once the required 

level of redeployment has been met with non-COPS grant funding for one full local budget 

cycle. Evidence that the COPS grant retention planning condition is being met by grantees 

may come in two forms: 1) a written retention plan or, 2) supporting evidence of retention 

planning. 

1

 The Phase I grant conditions did not include a retention requirement. See Appendix A for a definition of

the Hiring grant funding period. 2

 MORE ‘95 overtime grantees are required to plan to continue the proposed overtime activities funded under 

COPS MORE. 3

 In this document the required level of redeployment is used generically, referring to the level of

redeployment grantees must reach to be in compliance with their grant terms and conditions. See Appendix

A for more information about the required level of redeployment for specific MORE grant programs. 

Grant Monitoring Standards for Hiring and Redeployment 20 

Revised July 2001 
MORE retention planning requires that the department must plan to continue funding for 

the civilian positions(s) which will enable the department to redeploy officers. The grantee 

must continue the redeployment of time saved that resulted from the funding for equipment 

or technology. For example, this type of retention planning may be accomplished by 

including technology and equipment upgrades and maintenance funding in future-year 

budget requests. 

Throughout the grant period, all grantees must be able to provide evidence of how they are 

planning to retain the officer positions (under the Hiring grants) and the level of 

redeployment resulting from technology/equipment and/or civilians (under the MORE 

grants). Planning evidence consists of memoranda, minutes of meetings, budget 

documents, and other planning documents produced during the grant period. Grantees 

may be required to produce evidence of their progress in implementing their retention 

plans during any monitoring or audit activities. Additionally, grantees are required to 

answer questions in the Department Annual Reports and MORE Progress Reports 

regarding their plan to retain officer and/or civilian positions. 

The Retention Plan. Retention plans submitted to the COPS Office must include these 

two elements to be acceptable: 

1. Document co-signed by Chief Law Enforcement Official (Chief/Sheriff/Director of 

Public Safety, etc.) and Chief Executive Officer (Mayor/City Manager/Chairman of 

County Commission, etc.) that identifies: 

�� The proposed source of funding for the position(s). 

�� Identification of the grant(s) covered by the retention plan. 

�� The number of positions planned to be retained. 

2. Documentation, including but not limited to: local council minutes; inter-office 

memoranda; local government elected officials' memoranda and future budget 

projections that demonstrate intent to retain the COPS-funded positions at the 

conclusion of the grant period. For example: 

�� documents that demonstrate an intent to add the COPS positions to a request for 

local funding during local budget negotiations; 

�� documents that demonstrate the jurisdiction’s attempts to seek additional law 

enforcement funding from private sources, including corporate, non-profit, and 

foundation donations or grants; 

�� documents that demonstrate that the jurisdiction will try to obtain other non-federal 

funding sources (such as State grants, for example) to support the additional 

positions at the termination of the COPS grant. 

Grant Monitoring Standards for Hiring and Redeployment 21 

Revised July 2001 
Grantees that cannot comply with their retention plan must submit documentation to 

support mitigating circumstances. The COPS Office will review each situation on a caseby-case basis to determine if there is evidence of sufficient mitigating factors to excuse 

retention. Examples of possible acceptable mitigating circumstances are provided at the 

end of this section. Those agencies excused from the retention requirement may be 

required to wait up to one year before applying for additional COPS funding. 

The COPS Office may monitor the grantee’s compliance with the retention requirement for 

one full local budget cycle after the conclusion of the Hiring grant funding period for 

Hiring grants, or after the achievement of the required level of redeployment for MORE 

grants. Grantees must plan to retain officer positions or level of redeployment resulting 

from technology/equipment and/or civilians from the beginning to the end of a local 

budget cycle, regardless of when the grant ends during the previous local budget cycle. 

Grantees that need further assistance may contact their grant program specialist at the 

COPS Office or the DOJ Response Center (800-421-6770). 

Examples - Retention Planning, Retention Plan, and Mitigating Circumstances 

�� Evidence that retention planning efforts occurred throughout the life of the grant may 

include, but are not limited to: 

− 	Memoranda, minutes of elected official meetings or other documentation which 

demonstrate that the jurisdiction attempted to add the COPS positions to a request 

for local funding during local budget negotiations 

− 	Memoranda, minutes of elected official meetings or other documentation which 

demonstrate that the jurisdiction attempted to obtain other non-federal funding 

sources (such as State grants, for example) to support the additional positions at the 

termination of the COPS grant 

− Memoranda, minutes of elected official meetings or other documentation which 

demonstrate that the jurisdiction attempted to seek additional law enforcement funding 

from private sources, including corporate, non-profit, and foundation donations or 

grants 

�� Example of a Retention Plan. This must be written on agency letterhead. 

This letter is to indicate that the ABC Police Department has employed three (3) 

officer positions under the provisions of the UHP grant, as well as employed one (1) 

civilian position under the COPS MORE grant. The City of ABC, along with the 

ABC Police Department, plans to retain these positions and fund them through the 

City of ABC's general fund. We will retain these four positions for at least one full 

local budget cycle, ending 9/30/99. 

Grant Monitoring Standards for Hiring and Redeployment 22 

Revised July 2001 
�� Mitigating circumstances are those which demonstrate severe financial distress, a 

natural disaster, or any other factors that are deemed appropriate by the COPS Office. 

Mitigating circumstances may include, but are not limited to, the following situations 

when documented by the grantee: 

− Jurisdiction has been declared bankrupt by a court of law 

− Jurisdiction has been placed in receivership, or its functional equivalent, by the State or 

federal government 

− Jurisdiction has been declared a financially distressed area by its State or a Federal 

Government agency 

− 	 Budgetary imbalance or expenditure cutbacks resulting in significant reductions in 

other services provided by the law enforcement agency or significant lay-offs of the 

agency's personnel 

− 	 Extraordinary and unanticipated nonrecurring expenses and/or loss of revenue 

(including closure or relocation of major employers) resulting in material effect on a 

jurisdiction's fiscal condition 

− Significant downgrading of a jurisdiction's bond rating for fiscal-related reasons 

− Filing for bankruptcy, receivership or similar measure, with the request for relief 

pending 

− Location within an area in which a declaration of major disaster has been made 

pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act 

Impact of Failure to Retain on Active COPS Grants. An agency which fails to retain 

officer positions and has not been exempted for mitigating circumstances may be in 

violation of the nonsupplanting requirement for an unjustified reduction in baseline 

officers if the grantee also has active COPS Hiring grants. For example, an unapproved 

failure to retain one COPS FAST officer position, which otherwise would have been 

retained with local funding, may result in an unapproved baseline reduction for the active 

UHP grant, since the retained COPS FAST officer position should have increased the UHP 

grant baseline by one position. 

D. Allowable Costs 

DEFINITION 

Allowable costs are those costs that are reimbursable under the COPS Program, as 

specified by the provisions/requirements of the grant. The provisions/requirements 

include: the approved budget, the financial clearance memorandum, and the OJP Financial 

Guide, which are included in the grant award package. The financial clearance 

memorandum limits the amount that may be charged for each category. However, the 

COPS Office reserves the ability to reprogram the grantee budget upon request. The costs 

should be reasonable in nature and permissible under the specific grant conditions. 

Allowable costs are different for Hiring grants and MORE grants. 

Grant Monitoring Standards for Hiring and Redeployment 23 

Revised July 2001 
Hiring Grants 

For Hiring grants, allowable costs encompass the entry-level salaries, (including approved 

benefits and cost-of-living increases as specified on the grant application) for three years 

for sworn entry-level, lateral-transfer, or rehired officers. Allowable salaries and benefits 

must be based on the grantee’s standard entry-level salary/benefit package, regardless of 

the experience of the individual officers hired (although grantees may pay the extra costs 

with local funds), in addition to any required local match. Under Phase I, FAST, AHEAD, 

and UHP, up to 75% of an entry-level salary, with a $75,000 limit over the three-year grant 

period, will be paid by award money, and local funding must pay the remaining portion of 

the salary. The CIS Program does not require a local match, allowing for entry-level salary 

and benefits with a $125,000 limit over the three-year grant period. Any costs above this 

amount will be paid by local funding. 

MORE Grants 

For MORE grants, allowable costs encompass the salaries, including approved benefits, for 

civilian hires during the life of the grant, including renewal periods if applicable. In 

addition, the MORE ’95 Grant Program allowed for certain overtime costs of officers. Up 

to 75% of the salary will be reimbursed by award money, and the remaining portion of the 

salary must be paid by local funding. (MORE 2000 pays for 75% or a maximum of 

$25,000 for 1:1 redeployment). The 75% reimbursement is not based on entry-level salary 

and benefits, but may reflect the actual (approved) salary and benefit costs for the funded 

civilian positions. The COPS Office approval for funding civilian hires is based upon the 

cost effectiveness of replacing an officer with a support-service position. The salary of the 

civilian hire is factored into the cost-effective equation and approved with the application. 

Further, up to 75% of the costs for approved equipment and technology purchases is 

reimbursable under the conditions of the grant. 

CONDITIONS 

Costs that are deemed allowable are different for Hiring and MORE grant awards. 

Hiring Grants 

If the award is for a Hiring grant, funding allows for hiring new, additional full-time, 

entry-level sworn officers or promoting a current part-time sworn officer into a newly 

created full-time COPS-funded position. If the grantee has received approval from the 

COPS Office to promote a part-time officer to the full-time COPS grant-funded position, 

then the grantee must replace the part-time vacant position using local funding before 

expending COPS grant funds on the new full time position. The newly hired, additional 

full-time, entry-level sworn officers do not have to be placed into community policing. 

They may work wherever the department deems acceptable, but one veteran for each new 

hire must be redeployed to community policing activities. Alternatively, of course, the 

newly hired COPS-funded officers may be deployed to fulfill the community policing 

functions of the grant. 

Grant Monitoring Standards for Hiring and Redeployment 24 

Revised July 2001 
If the award is for a part-time Hiring grant, the salary costs, including approved benefits, 

are only allowable if grant funds are being used to pay for a new part-time officer, not to 

increase the hours of the currently employed part-time officer. Part-time hours are defined 

by the grantee in the application and approved by the COPS budget memorandum. 

For both full-time and part-time grant awards, it is acceptable for grantees to recruit and 

hire non-sworn officers with COPS grant monies as long as the individual will become a 

sworn officer through the standard training and swearing-in procedures required by the 

grantee’s State or local law. 

The determination of allowable costs for Hiring grants includes considering the local 

budget, which confirms the approved salary and benefits for the entry-level position. If the 

filled position is not entry level, the grant funding cannot pay for more than 75% of the 

portion of the salary and benefits of a position that is entry level. The approved COPS 

grant application will specify the recipient share of outlays for the local match. 

MORE Grants 

If the award is for a MORE grant, funding allows for the payment of support resources, 

including the salaries and approved benefits of civilian personnel (MORE 2000-funded 

civilian support resources only), and overtime (MORE ’95), and technology and equipment 

that have been approved by the COPS Office. The allowable costs must directly contribute 

to time savings and thereby enhance the community policing presence through redeployment. 

The different types of costs that are considered reasonable and, therefore, allowable, 

include the salary and approved benefits for civilian personnel who are employed for 

support services. MORE grants are awarded for one year only, with renewal available at 

the discretion of the COPS Office, subject to funding availability, for civilian hires and 

overtime for up to two years after the initial grant period. Depending on the COPS Office 

approval of renewal requests, the costs of salary and benefits for civilian support services 

may or may not be allowable. 

For technology and equipment purchases, the term of the grant funding is one year. The 

grant application reflects whether the costs are timely and allowable. For COPS compliance 

purposes, “timely” is defined as consistent with the local government’s procurement 

practices, and “allowable” is defined as approved costs specified on the grantee’s application. 

It should be noted that it may be permissible to obtain additional items in support of the 

MORE grant as a result of cost savings. For example, a department requests and receives 

funding to obtain eight (8) computers and is able to obtain 10 computers at the same price 

due to discounts. All use of saved funds must be consistent with the program outlined in 

the approved application. Beginning March 8, 1999, the COPS Office required prior 

written approval only if the utilized saved funds were to be in excess of $1,000. However, 

the agency will not be required to demonstrate additional redeployment based on the use of 

this money since the required redeployment is linked to the dollars spent rather than the 

number of items purchased. 

Grant Monitoring Standards for Hiring and Redeployment 25 

Revised July 2001 
EXAMPLES 

Allowable/Unallowable Costs by Program

Hiring Grant Allowable Costs 

Allowable costs include the salaries and approved fringe benefits for three years for sworn 

entry-level, lateral-transfer, or rehired officers. Up to 75% of the entry-level salary 

actually incurred, with a $75,000 limit over the three-year grant period, will be paid by 

award money with the remaining portion of the salary paid by local funding. 

�� Approved fringe benefits include, but are not limited to, department costs for 

FICA/Social Security, health insurance, life insurance, vacation and sick leave not 

included in base salary, retirement benefit contribution, worker's compensation, and 

unemployment insurance. Fringe benefits that are absolutely NOT approved are costs 

of equipment, training, uniforms, vehicles, and overtime. For assistance in determining 

other allowable costs under Hiring grants, please refer to the COPS budget 

memorandum, which all grantees receive as part of their award package. 

�� Salary and benefits may be paid during training if this is the grantee’s standard practice 

for all officers. Examples of training include, but are not limited to, academy training, 

field training, and probationary training. 

�� If the grantee chooses to transfer veteran officers into community policing activities, 

the veteran officers do not have to begin those activities until the new hires finish the 

required training program for that particular grantee. (Training programs include 

academy, field, and probationary training.) The reason for this policy is twofold. First, 

if veterans were deployed to community policing while the new hires are in training or 

are not fully prepared to fill the vacant position, there would be a deficiency in another 

area of the police department. Second, the policy encourages consistency for COPS 

grantees by allowing departments to transfer veterans to community policing and not 

use new hires for the community policing program. 

Grant Monitoring Standards for Hiring and Redeployment 26 

Revised July 2001 
MORE Grant Allowable Costs 

�� MORE ’95, ’96, ’98 

a. mobile data computers/laptops 

b. crime analysis hardware/software 

c. mapping software 

d. personal computers 

e. automated aided dispatch systems 

f. automated booking system 

g. dictation systems 

h. salary and benefits to civilians that result in the redeployment of sworn officers 

i. administrative assistants 

j. record clerks 

k. booking clerks 

l. dispatchers 

m. certain overtime costs for officers (MORE ’95)

n. certain training costs 

�� MORE 2000 Grant: 

a. salary and benefits to civilians that result in the redeployment of sworn officers 

b. administrative assistants 

c. record clerks 

d. booking clerks 

e. dispatchers 

The Memorandum of Estimated Funding will assist in determining the specific item that 

can be funded under the MORE grant award. The COPS budget memorandum will also 

assist grantees in determining allowable costs. 

Hiring Grant Unallowable Costs 

a. overtime

b. training (other than salary or benefits paid during training) 

c. weapons 

d. communication equipment 

e. uniforms 

f. vehicles 

g. indirect costs 

Grant Monitoring Standards for Hiring and Redeployment 27 

Revised July 2001 
MORE Grant Unallowable Costs 

a. direct salaries and benefits of sworn officers 

b. police vehicles 

c. siren vehicle equipment 

d. office equipment/furniture 

e. weapons and ammunition 

f. cellular telephones 

g. radios 

h. pagers 

i. uniforms 

j. narcotics dogs/horses 

k. bullet proof vests 

l. breathalyzers 

m. radar guns 

n. video cameras 

o. phone lines and voice mail systems 

p. educational material 

q. televisions/VCRs 

r. all equipment and technology (MORE 2000 only) 

E. Source of Matching Funds 

DEFINITION 

The grantee is obligated to match a portion of the costs of the program, project, or activity 

as funded by the COPS Program. With the exception of the CIS Program (see below), 

grant awards may cover up to 75% of the costs over the grant period as outlined in the 

application submission; therefore, the grantee must contribute at least 25% unless a waiver 

is obtained from the COPS Office. For the CIS Program, however, a local match is not 

required. The CIS Program funds school resource officer salary and benefits over the 

three-year grant period, not to exceed $125,000 per officer. Any additional salary or 

benefits must be paid by State or local funds. 

Any match, if necessary, must be fully paid before the end of the grant period. This 

criterion follows the logic that the COPS Program supplies “seed” money to various law 

enforcement agencies for community policing. 

CONDITIONS 

The Hiring and MORE grant awards have different compliance conditions for the local match 

requirement. For Hiring grant awards (AHEAD, FAST, UHP), the COPS grant will provide 

for up to 75% over three years with a maximum of $75,000 per officer for an entry-level 

salary and fringe benefits package. Grantees are responsible for at least 25% of the salary and 

fringe benefit package. If the position is not entry level, any portion of the salaries or fringe 

Grant Monitoring Standards for Hiring and Redeployment 28 

Revised July 2001 
benefits that are above an entry-level position must be provided by the grantee. CIS grantees 

are responsible for any additional costs for salaries and benefits over the maximum of 

$125,000 per officer. 

For MORE ’95, ’96, and ’98 grant awards, the COPS grant will provide up to 75% of the 

allowable costs for equipment and technology and civilian support services under the grant 

guidelines. Under MORE 2000, the COPS grant will provide 75% of civilian support 

services salaries up to $25,000 for 1:1 redeployment. Grantees are responsible for 

contributing at least 25% of the remaining costs. For civilian hires, the COPS grant will 

provide up to 75% of the salaries and approved benefits packages. The 75% reimbursement 

is not based upon entry-level salary and benefits, but is based, instead, on the cost 

effectiveness of replacing or redeploying an officer for a support-service position. The salary 

of the civilian hire is factored into the cost-effective equation, which is approved with the 

application. 

MORE grants are typically awarded for one-year periods unless grantees choose to apply for 

a renewal of grant funding for the civilian hires and overtime only. Approval of MORE 

grant renewals is at the discretion of the COPS Office and is subject to the availability of 

funds. Subject to the availability of funding and progress in implementing the original 

award, the cost of a civilian hire’s salary and benefits package or overtime costs may be 

renewed for up to two years after the original grant period ends, for a total of three years. 

These renewals of funds continue the same level of redeployment for additional years. 

There are several guidelines that must be observed by grantees when meeting the source of 

matching funds requirement, regardless of the type of grant awarded. One of these 

guidelines concerns the local contribution level of matching throughout the life of the grant. 

For MORE grants, the grantee is responsible for at least 25% of the total cost of allowable 

items. For Hiring grants (with the exception of CIS), the local share must be at least 25% of 

the total cost of salaries and fringe benefits over the three-year period. (CIS does not require 

a local match, paying $125,000 over three years for school resource officer entry-level 

salaries and benefits. Grantees whose costs exceed the $125,000 offered under CIS to pay 

the excess costs with local funds). For Hiring grants (excluding CIS) the percentage of total 

officers’ salaries and benefits paid with Federal funds must be less in year two than in year 

one and less in year three than in year two. For example, if the award amount were $75,000, 

the grantee could spend $50,000 in Federal money the first year. The following year the 

grantee could spend $15,000; the third year only $10,000 of the Federal funds could be spent. 

While the Federal share decreases each year, all that is spent over the three-year period is a 

maximum of $75,000. 

An additional guideline to follow concerns the type and source of the match. The type of 

match must be a cash match and the source of funds may not be Federal unless a Federal 

agency has specifically approved the use of its funds as a cash match to another federal 

grant program. The local match funds must be in addition to funds previously budgeted 

for law enforcement purposes and may not have come from other COPS grants or 

supplements. 

Grant Monitoring Standards for Hiring and Redeployment 29 

Revised July 2001 
Further, grantees may not count equipment costs outside of the programmatically approved 

project towards the local match. For example, if a MORE project costs $100,000 total for 

computer, software, and installation, the applicant must pay $25,000 towards the total 

project for the local match. The local jurisdiction may not substitute non-project 

expenditures, such as training officers on the use of equipment, toward the match. 

If grantees include the source of the local match in the current year’s operating budget, it 

must be intentionally budgeted in anticipation of the grant award or previously budgeted as 

reserve or discretionary monies, in addition to funds previously budgeted for law 

enforcement purposes. If the supporting documentation clearly indicates either of these 

conditions exists, the grantee may use those funds as an acceptable source for the local 

cash match. If the documentation cannot support a causal link between the budgeted funds 

and the anticipation of the grant award, or if the funds are not in addition to funds 

previously budgeted for law enforcement purposes, there is a violation of the matching 

funds requirement. 

To demonstrate compliance with the local match requirement, grantees must be able to 

document the source of local match (cash match from a source of funding not previously 

budgeted for law enforcement); the timing of the local match (when paid); and the amount 

of the local match. 

It should also be noted that grantees are excused from either the whole or a portion of the 

local cash match if the law enforcement agency has obtained a waiver. Only a small 

portion of waiver requests are granted and they are considered at the time of application or 

post-award if the community can prove severe financial distress or other severe mitigating 

factors. Grantees who are excused should have a copy of the COPS notification of the 

approved waiver on site. 

Examples - Acceptable Sources of Matching Funds: 

�� New Local Appropriations 

�� State Funds: it is permissible to use State funds only if allowable by State law. 

�� Other Federal Funds: it is permissible to use Federal funds only if allowable by the 

other particular Federal funding agency (e.g., Bureau of Indian Affairs). 

�� Other Grant Funds: it is permissible to use other grant funds if the grant is a nonCOPS-related grant and only if allowable by the particular grant. 

�� Asset Forfeiture Fund Equitable Sharing Program 

�� Reserved, Discretionary, and Other Undesignated Law Enforcement Fund 

Grant Monitoring Standards for Hiring and Redeployment 30 

Revised July 2001 
F. Supplanting 

DEFINITION 

For the purpose of COPS grants, supplanting means using COPS grant funds to replace 

State or local funds which otherwise would have been spent on the specific law 

enforcement purpose of the COPS grant awards. To be in compliance with the nonsupplanting requirement, COPS grant funds are to be used to supplement the budget of the 

law enforcement agency, not replace any currently, historically, or future appropriated 

funds for the grant purposes. For example, COPS Hiring grant funds may not replace State 

or local funding for hiring sworn officers and COPS MORE funds may not replace State or 

local funding for purchasing equipment or technology or for hiring civilians that would 

have been budgeted in the absence of receiving COPS grant funding. 

The non-supplanting requirement of the COPS statute reads as follows: 

Funds made available under [the COPS statute] to States or units of local 

government shall not be used to supplant State or local funds, or, in the case of 

Indian tribal governments, funds supplied by the Bureau of Indian Affairs, but 

shall be used to increase the amount of funds that would, in the absence of federal 

funds received under [the COPS statute], be made available from State or local 

sources, or in the case of Indian tribal governments, from funds supplied by the 

Bureau of Indian Affairs. 

CONDITIONS 

Regardless of the type of grant, complying with the non-supplanting requirement entails 

using COPS grant funds to increase the baseline level of funding by augmenting the level 

of State, local, or Bureau of Indian Affairs funds that would be made available for the grant 

purposes in the absence of the grant. When specifically referring to Hiring grants, the 

increased level of funding pertains to hiring new officers. For MORE grants, the level of 

funding that should increase with the award of the grant applies to purchasing equipment 

and technology, hiring civilians, or, under the MORE ’95 program, funding overtime. 

An analysis of supplanting is a two-step process. The first step is to examine the facts that 

occurred during the life of the grant in order to determine if a supplanting violation might 

have transpired because a reduction in local or State funding for the grant-funded purpose 

occurred after the grantee received funding. The second step is to review pertinent data 

relative to the reduction to ascertain why the action or decisions that impacted the reduction 

occurred. Examples of relevant information include both historic and current copies of the 

grantee’s budget, local government policies, and other documentation reflecting the 

reasons for the reduction in the department’s budget. 

Grant Monitoring Standards for Hiring and Redeployment 31 

Revised July 2001 
The key to determining whether a supplanting violation has occurred is to decide if the 

reduction of local or State funding, a fact that might “look like” supplanting, would have 

occurred regardless of the receipt of award money for reasons unrelated to the COPS 

grants. Reductions in local or State funding which might indicate possible supplanting 

violations occur in four primary areas: 

�� Hiring sworn officers or civilians or purchasing equipment/technology, depending on 

the type of grant, before the award date of the grant. 

�� Delays in filling vacant locally funded sworn officer positions or civilian positions, 

depending on the type of grant. 

�� Decreases in the baseline level of funding for sworn officers, civilians and 

equipment/technology during the grant period. 

�� Decreases in the baseline level of sworn officer and civilian positions during the grant 

period. 

Hiring Sworn Officers or Civilians or Purchasing Approved Technology and 

Equipment before the Award Date of the Grant 

Except for FAST and AHEAD recipients, grantees are prohibited from using COPS grant 

funds to pay for officers or civilians who are hired prior to the award start date of the grant. 

FAST and AHEAD grant recipients may not use grant funds to pay for officers hired 

before the approved hiring start date (FAST 2/8/95; AHEAD 10/1/94), which may differ 

from the date of award. Grantees are required to obtain written approval from the COPS 

Office to use COPS grant funding for personnel hired pre-award. To obtain such approval, 

the grantee must provide documentation, from the time of the pre-award hiring, that proves 

that the additional officers or civilians were hired in specific anticipation of receiving 

COPS grant funds and were not otherwise funded with State or local funds. 

Acceptable forms of documentation may include (and must be dated on or about the time 

of the pre-award hiring): 

��Internal departmental memoranda clearly linking the hiring to the anticipated COPS 

grant funding 

��Governmental memoranda clearly linking the hiring to the anticipated COPS grant 

funding 

��Documentation provided to the officers or civilians in question explaining that 

continued employment is contingent upon receiving grant funds 

��Budget documentation demonstrating that the positions in question were not funded 

with State or local funds (or were funded with anticipated incoming COPS grant funds) 

The same provisions for hiring also apply to the purchase of approved technology and 

equipment before the award date of the grant. If grantees acquired the technology and 

equipment that was requested on the grant application before the award date, 

documentation from the time of the pre-award purchase is required to prove the purchase 

was in anticipation of the grant funding. The examples of acceptable documentation for 

Hiring grants can also be used to support the relationship between the purchased items and 

the expected grant award for MORE grants. 

Grant Monitoring Standards for Hiring and Redeployment 32 

Revised July 2001 
Exception to Pre-Award Hiring Prohibition: Part-time to Full-time Promotions 

A unique exception to the pre-award or pre-approval hiring date requirement is the 

promotion of a previously locally funded (and, therefore, usually hired pre-award) parttime officer or civilian to full-time status under the COPS grant. The grantee must also 

hire a new officer or new civilian with local funds to backfill the vacant part-time position. 

COPS Hiring grant funds may not be expended on the new full-time position until it has 

backfilled the part-time vacancy with a new hire using local funding. 

If the supporting documentation, or lack thereof, reveals that the pre-award hiring or the 

purchase of technology and equipment was not a direct result of anticipated grant funds, 

but would have occurred regardless of the grant availability, or if a grantee promoted a 

locally funded officer or civilian from part-time to a full-time COPS grant position, but did 

not “backfill” the resulting part-time vacancy with local funds, a supplanting violation has 

occurred. 

Requirements for Written Approval 

Under any “early hire” or “early purchase” situation, or transfers from a locally funded 

part-time to full-time COPS-funded position, COPS grantees are required by their Grant 

Conditions to seek written approval from the COPS Office for the requested use of funds. 

Grantees who failed to obtain prior written approval from the COPS Office before using 

COPS grant funding for pre-award hires or purchase must seek a retroactive review of their 

use of funding to determine compliance. 

Delays in Filling Vacant Locally Funded Sworn Officer Positions or Civilian Positions 

The COPS guidelines state that the standard procedures used by the grantee to fill locally 

funded vacancies must be followed by grantees in a timely and active manner during the 

life of the grant. Any delay in filling locally funded vacancies must not be a direct result 

of receiving grant funds. 

In order to determine grantees’ standard procedures for filling locally funded vacancies, 

grantees should follow their written procedures for recruiting and hiring locally funded 

positions. 

If grantees do not have formal documented procedures for hiring and recruiting, historical 

practices may be used as evidence of standard procedures. In the situation where grantees 

have continued to follow those historical practices for filling vacancies in locally funded 

positions during the period of the grant, the non-supplanting requirement is met. 

A situation independent of the grant may prevent the grantee from adhering to historical 

practices, such as a local hiring freeze or pending litigation, and result in a delay in filling 

locally funded vacancies. If grantees deviate from their standard hiring procedures, 

documentation should demonstrate the reasons for the deviation. If, after reviewing all 

pertinent documentation, there is no causal link between the delays in filling locally funded 

vacancies and the receipt of grant funding, then a supplanting violation has not occurred. 

Grant Monitoring Standards for Hiring and Redeployment 33 

Revised July 2001 
For grantees without formal written guidelines, the following items are examples of areas 

that could be considered active recruiting and timely filling of vacant locally funded vacant 

positions: 

��If the grantee typically hires replacement law enforcement officers from a civil service 

list of certified candidates, confirmation is necessary from the grantee or a civil service 

official showing that the grantee followed historical practices during the grant period. 

��If the grantee hires replacements to coincide with State, local, or law enforcement 

agency training academies, verification is necessary from the grantee or an academy 

official showing that the grantee followed similar practices after the grant award date. 

��If the grantee experiences high turnover rates, confirmation is necessary showing that 

the grantee is following historical hiring procedures during the grant period. 

��If the grantee is filling both COPS positions as well as locally funded positions, both 

should be filled at approximately the same rate. If a grantee fills COPS vacancies at an 

unreasonably faster rate, it must justify that its reasons for doing so are unrelated to the 

receipt of COPS grant funding. 

��To meet the timing of school years, grantees may hire new, additional officers to fill 

CIS-funded vacancies prior to filling locally funded, non-school resource sworn officer 

vacancies, as long as the grantee is continuing to take active and timely steps to fill 

local sworn officer vacancies. 

Decrease in the Baseline Level of Funding 

The goal of both the Hiring and MORE grants is to increase the “baseline” level of State, 

local, or Bureau of Indian Affair funds which would otherwise be budgeted for sworn 

officers (Hiring grants) and civilians or equipment (MORE grants), with COPS grants 

funds. For the purposes of the COPS Program, the determinant for a possible supplanting 

violation includes both the level of funding and the level of sworn officer positions (Hiring 

grants) and civilian positions (MORE grants). 

To determine the baseline level, the State or local funding and number of sworn officer and 

civilian positions must be measured as of each grant’s threshold review date. (See 

Appendix C for the applicable review date for each type of COPS grant.) This level should 

be reviewed for each fiscal year during the grant period in case any additional State or 

local funding had been budgeted for extra positions after the original threshold date. If the 

State or local baseline funding increased during the grant period, the highest documented 

level of State or local funding or positions for sworn officers or civilians should be used as 

the new baseline level. 

If, during the grant period, the State or local baseline level of funding or number of 

positions for sworn officer and civilian positions has decreased, it must be determined if 

there is a causal link between the decrease and the award of grant funding. Supporting 

documentation is needed to justify that a decrease in baseline funding or baseline positions 

occurred for reasons that are unrelated to the COPS grant for adequate proof of nonsupplanting compliance. Acceptable forms of supporting documentation may include, but 

are not limited to: 

Grant Monitoring Standards for Hiring and Redeployment 34 

Revised July 2001 
�� City or county council meeting minutes 

�� Internal departmental budget directives 

�� Internal law enforcement agency documents

�� Independent management studies recommending reductions 

�� Documentation for other local agencies outlining budget reductions 

Impact of Failure to Retain on Supplanting Analysis 

An agency which fails to retain officer positions and has not been exempted for mitigating 

circumstances may be in violation of the nonsupplanting requirement for an unjustified 

reduction in baseline officers if the grantee also has active COPS Hiring grants. For 

example, an unapproved failure to retain one (1) COPS FAST officer position, which 

otherwise would have been retained with local funding, may result in an unapproved 

baseline reduction for the active UHP grant, since the retained COPS FAST officer 

position should have increased the UHP grant baseline by one position. 

If the grant award is for part-time officers or civilian support services, the baseline funding 

level analysis is still applicable. 

To verify compliance, grantees are required to demonstrate that any reduction in local 

funding for sworn officers and civilians or a reduction in the number of sworn officer and 

civilian positions is unrelated to the receipt of COPS funds. 

Examples - Supplanting Situations 

�� When COPS-funded hires are excluded, a causal link has been determined to exist 

between the delay of filling vacant locally funded positions and the receipt of grant 

funding. 

�� Evidence shows that the amount of non-federal funding resources devoted to the hiring 

or rehiring of law enforcement officers has decreased in expectation of, or as the result 

of, receipt of a COPS grant. 

Grant Monitoring Standards for Hiring and Redeployment 35 

Revised July 2001 
G. Training: Special Conditioned Grantees 

DEFINITION 

Training is the act, process, or method by which sworn officers and civilians learn about 

community policing practices and other law enforcement techniques. 

CONDITIONS 

Hiring and MORE Grantees 

A community policing “special condition” status was bestowed on certain Hiring and 

MORE grantees as determined by the COPS Office, typically law enforcement 

departments that were new or did not have a community policing strategy. Notification of 

this added grant condition was sent to the grantee with the grant award. The special 

condition was satisfied through sworn officer representative(s) from the police department 

attending two on-site community policing training seminars held by the Community 

Policing Consortium (a COPS-funded training organization), or participating in distance 

learning courses (such as video tapes, workbooks, compact discs or Internet courses) 

provided by the Community Policing Consortium. Travel costs for the community policing 

training seminars through the Community Policing Consortium were paid for by the 

grantee. In February 2001, the Community Policing Consortium no longer offered the 

courses in order to satisfy this training special condition. Accordingly, the COPS Office no 

longer requires that the community policing special condition be satisfied by completing 

training through the Community Policing Consortium. However, training is still available 

through the Regional Community Policing Institutes. 

COPS in Schools (CIS) Grantees 

All COPS in Schools awards contain an additional grant condition that requires the officers 

deployed into the schools as a result of the CIS grant and one designated school administrator 

per grant to attend COPS-sponsored School Resource Officer (SRO) Training. Notification of 

this added grant condition is sent to the grantee with the grant award. Departments are 

encouraged to attend the training in the early stages of the grant, but, in all cases, departments 

must complete their training during the life of the grant. Under the actual grant condition, the 

SRO(s) deployed to work in the schools as a result of the grant and one school administrator, 

representing the lead partnering agency, are required to attend this team-based training. Since 

this is a team-based training, it is encouraged that both the school administrator and the SRO(s) 

attend the training together; however, COPS recognizes the difficulty in scheduling such an 

event. Therefore, as long as both the SRO(s) deployed into the school and the representing 

school administrator attend a training session sponsored by COPS during the life of the grant, 

the grant recipient is in compliance with this training condition. Only the training sponsored 

by the COPS Office will satisfy this additional grant condition. The COPS Office Grants 

Administration Division reserves the right to approve all participants to ensure proper 

representatives attend the training, thereby satisfying the grant condition. Costs, including 

training, per diem, travel and lodging, up to a maximum of $1,100 will be reimbursed to the 

grantee by the COPS Office. 

Grant Monitoring Standards for Hiring and Redeployment 36 

Revised July 2001 
H. Reporting 

DEFINITION 

Two types of reports are required from grantees: 1) Program Progress Reports, and 2) 

Financial Status Reports. Reports are survey instruments that the COPS Office uses to 

monitor grants. These Progress Reports request information about the status of the grant in 

terms of selection, hiring and training; characteristics of the officers hired; descriptions of 

officer activities; and general information about the department. The MORE Program 

requires submission of one MORE Progress Report detailing background information on 

the department, equipment and technology purchasing and any information on civilian 

hiring. The financial reports request information on monies spent including amounts for 

Federal expenditures, local matching contributions, and the unobligated balance of the 

award. Financial status reports are reviewed by the COPS Office. 

The type of program progress reports required depends on the type of grant award. As of 

December 1999, the Hiring grants require two reports: 1) Department Initial Report and 2) 

Department Annual Report. The MORE grants require only one MORE Progress Report. 

CONDITIONS 

The type of progress reports required depend on whether the grant is COPS Hiring or 

MORE. Financial status reports require the same format for all grants. Grantees are 

required to complete the financial status reports even if the grant has been in effect for only 

a portion of the reporting period and no money has been drawn down. 

Department Initial Report: Hiring. The Department Initial Report is required only if the 

department has never previously received a COPS Hiring grant. Only one report is 

required per agency for the life of the grant. The exception to this is for agencies that have 

received both a Phase I and a (other) Hiring grant(s). If this is the case, the department is 

required to submit one Department Initial Report for the Phase I grant and one for the other 

Hiring grant(s). This report solicits information regarding pre-grant data, which serves as a 

baseline for measuring the grantee's future progress in community policing. Information 

gathered includes training curriculum, demographics of police force, and community 

policing activities. The Department Initial Report also collects information about a 

department’s actual and budgeted number of locally funded officers. 

A hard copy of the Department Initial Report is sent to all Hiring grantees within 30 days 

of receiving an award packet if a grant is awarded for the first time. The report is due back 

to the COPS Office within 45 days of receipt of the award packet by the grantee. 

Department Annual Report: Hiring. The Department Annual Report solicits 

information very similar to the Department Initial Report. Questions on these reports 

include demographics of police force, retention plans, and community policing programs 

and activities. In addition, the Department Annual Report collects information about a 

Grant Monitoring Standards for Hiring and Redeployment 37 

Revised July 2001 
department’s actual and budgeted number of locally funded officers. This information can 

be compared to the information provided in a grantee’s Department Initial Report to 

determine if the baseline level of locally funded officers has decreased over the life of the 

grant.

A hard copy of the Department Annual Report is mailed to all grantees awarded a Hiring

grant. Department Annual Reports are mailed in December of each year, for the reporting

period covering January 1 - December 31, throughout the lifetime of the grant. These 

reports are due in February of each year. 

COPS Count. During the survey, COPS Hiring and a sample of MORE grant recipients 

are contacted by telephone and asked for information regarding the status of their grants as 

of a selected date. This survey information is then summarized and compared with the 

total number of officers funded as of the same selected date. Specific survey information 

includes whether officers have been hired; hire dates of officers, demographic information 

of the officers, and duties and responsibilities of the officers; redeployment dates and 

related questions for MORE grants; and grantee plans concerning future hiring and 

redeployment. 

Progress Report: MORE. The MORE Progress Report requires the grantee to provide 

information about the enhanced levels of community policing that have resulted from the 

purchase of equipment and/or the hiring of civilian personnel funded under the COPS 

MORE Grant Program. The information requested will include documentation that

demonstrates that the required level of redeployment is being maintained and monitored. 

As of January 1, 1999, grantees have been required to submit a redeployment tracking plan 

with the MORE Progress Report. The information from this report will be used to monitor

each grantee’s progress and to provide summary data on the characteristics and activities 

of the project supported with COPS MORE funding. 

The report must be completed by the grantee even if they have not hired the civilian 

personnel or purchased the equipment awarded under the COPS MORE Program. The 

reports are mailed approximately 12-18 months after the original award start date. These 

reports are to be returned within 45 days of their receipt. 

Financial Status Reports. The Financial Status Report, (SF-269A), is a required report for 

both Hiring and MORE grantees that is completed and sent to the COPS Office on a 

quarterly basis. This report requests information on total monies spent, the breakdown by

Federal expenditure and local match, and unobligated amounts. The COPS Office 

monitors the financial aspects of grants and will assist in completing much of the standard

information; however, the grantee must provide specific financial information. 

Payments to grantees are delayed if the most current financial status report has not been 

submitted at the time of the payment request. 

For information on how to complete an SF-269A, refer to the Helpful Hints Guide at the 

COPS Website, www.usdoj.gov/cops/toolbox/general_info/financial. For technical 

Grant Monitoring Standards for Hiring and Redeployment 38 

Revised July 2001 
assistance in financially managing and administering a grant, refer to the U.S. Department 

of Justice Office of Justice programs, Office of the Comptroller Financial Guide, which 

can be found at www.ojp.gov/FinGuide. Grantees may also contact the DOJ Response 

Center at 1-800-421-6770 for additional technical assistance. 

Grant Monitoring Standards for Hiring and Redeployment 39 

Revised July 2001 
VI. COPS Performance Indicators 

This section presents a checklist of performance indicators that can be used as a guide in

determining whether or not COPS grantees are in compliance with the terms and 

conditions of the Hiring and MORE grant awards within each of the eight compliance 

categories. Performance indicators present characteristics that are used to measure the 

results of the COPS Program activity compared to its intended purpose and compliance

requirements. 

In general, written evidence that grantees are complying with grant laws and regulations is 

always required. Consequently, copies of all documentation should be kept at local law 

enforcement agency offices. Significant changes to grant applications must be submitted 

in writing to the COPS Office for prior approval. Significant changes include: 

��Changes in number of officers that will be hired 

��Extensions 

��Salary and benefit changes 

��Changes in required redeployment levels 

��Changes in the type of equipment purchased 

��Purchase of additional items for a MORE redeployment grant that was the result of 

cost savings in excess of $1,000 

��Changes in community policing plans not within the scope of the original approved 

plan 

��Use of grant funding for officers or civilians hired pre-award 

��Use of grant funding for equipment or technology purchased pre-award 

��The transfer of a locally funded part-time position to a full-time COPS-funded position 

While interpreting the goal of any of the eight compliance categories and whether the 

terms and conditions of the COPS grant awards have been met, the intent of the program 

should be kept in mind. The overall intent of the COPS grant program is to help develop 

an infrastructure that will institutionalize and sustain community policing after Federal 

funding has ended. The ultimate goal of incorporating community policing is to improve 

public safety through better police work, while increasing the public's interaction and 

satisfaction with police services. 

The checklist is grouped by the eight compliance categories, which are further subdivided 

by several performance standards. Performance standards represent distinct statements for 

each compliance category that together comprise a complete definition of each goal. Each 

standard is accompanied by a list of indicators that can be used to help determine 

compliance satisfaction within each category. Comments are available for each standard to 

provide additional information about the performance indicators; however, for detailed 

explanations refer to Section V of this Guide. 

Grant Monitoring Standards for Hiring and Redeployment 40 

Revised July 2001 
A. Community Policing 

GOAL: Law enforcement activities executed under the grant program qualify as 

community policing. 

Performance Standards Performance Indicators Comments 

Refer to section V, pages 10-16 for a complete definition of Community Policing. 

Hiring and MORE Grants: 

Local law enforcement agencies use 

grant funds to begin or enhance their 

community policing effort. 

Grant funds under the COPS in 

Schools (CIS) Grant Program are used 

as an incentive for law enforcement 

agencies to build working 

relationships with schools to use 

community policing efforts to combat 

school violence. 

Community policing activities actually 

executed by the local law enforcement agency 

are generally the same as the activities 

identified in the approved grant application, or 

in any changes received in writing. 

Under the CIS Grant Program, there are 

specific community policing requirements that 

pertain to this particular grant program. For 

example, as a result of this grant award, an 

officer must be deployed to work in and around 

primary and secondary schools on youthrelated activities for a minimum of 75% of their 

time. Overall, there must be an increase in the 

level of community policing activities that are 

being performed in the schools as a result of 

receiving a COPS in Schools award. 

Any significant changes to 

the community policing 

activities identified in the 

grant application must be 

submitted in writing to the 

COPS Office for approval. 

Hiring Grants: 

Local law enforcement agencies use 

grant funds to hire new officers or to 

redeploy veteran officers resulting in 

enhanced community policing 

activities. 

MORE Grants: 

Time savings from MORE grants 

result in enhanced community 

policing activities. 

Evidence of an agency’s compliance with 

community policing activities may include, but 

is not limited to, the following: 

• Working with citizen advocacy groups, 

and/or meeting with community groups and 

businesses to address local crime problems. 

• Participating in crime analysis. 

• Establishing crime prevention or drug 

prevention programs or participating in 

prevention efforts. 

• Performing bike or foot patrols. 

• Working with other government agencies 

to address crime and disorder problems. 

• Having a written strategic plan for 

community policing. 

• Offering or attending training in 

community policing. 

• Incorporating community policing into 

performance evaluations. 

• Decentralizing decision-making authority. 

• Assigning officers to a geographic beat to 

encourage community-police relations. 

• Establishing community partnerships. 

• Performing problem-solving activities. 

• Responding to specific community needs. 

• Establishing youth programs and 

activities. 

• Incorporating the use of volunteers into 

police work. 

One or more of these 

indicators may be evidence 

that the local law 

enforcement agencies are 

using awards consistent 

with community policing. 

For more information, 

please see section V.A. 

Grant Monitoring Standards for Hiring and Redeployment 41 

Revised July 2001 
B. Time Savings for Redeployment 

GOAL: MORE Grant Program awards result in time savings that are directly 

related to the redeployment of sworn officers who participate in community policing. 

Performance Standards Performance Indicators Comments 

Refer to section V, pages 16-19 for a complete definition of Time Savings for Redeployment. 

MORE Grants: 

Time savings resulting from 

MORE grant award 

implementation is being tracked. 

Documented tracking plans developed by 

grantees show how time savings will be 

tracked for each item, system or group of like 

items requested. One or more of the following 

may be used to verify compliance: 

• Work study plans. 

• Studies using sampling techniques. 

• Directly tracking hours. 

• Acceptable cost accounting methods. 

• Any reasonable time estimation 

technique. 

No single tracking method can 

cover all situations and all 

jurisdictions. Each jurisdiction 

varies in size and each situation 

varies in complexity. 

A time savings tracking plan 

should be developed as soon as 

possible during the grant award 

period and tracking must continue 

for at least one full year from the 

date technology or equipment is 

declared fully operational. 

These plans should include a 

statement explaining how time is 

being saved, the method used to 

track time savings (estimation, 

direct tracking sample, study, 

etc.), the hours to complete the 

activity before and after 

equipment or technology is 

implemented, and a short 

description of enhanced 

community policing activities 

resulting from the time savings. 

MORE Grants: 

Time is saved as a result of 

equipment, technology, overtime 

(funded only to MORE ‘95 grant 

recipients), or civilians awarded 

under the MORE Program. 

One or more of the following may verify 

compliance: 

• Documented tracking plans maintained 

by grantees that support time saved as a result 

of MORE grant awards. 

• Redeployment tracking documentation 

that supports time saved as a result of MORE 

grant awards submitted with MORE ’98 

Progress Reports. 

Tracking a project’s time savings 

is required once a single, stand 

alone, independent item, element, 

function or operation is fully 

implemented. 

Once time savings has been 

tracked and a determination can 

be made about the actual total 

hours saved, a redeployment 

tracking worksheet summarizing 

results of FTEs saved should be 

submitted with progress reports, 

effective beginning January 1999. 

MORE renewals require evidence 

of continued, but not additional, 

redeployment. 

Grant Monitoring Standards for Hiring and Redeployment 42 

Revised July 2001 
Time Savings for Redeployment, continued 

Performance Standards Performance Indicators Comments 

Refer to section V, pages 16-19 for a complete definition of Time Savings for Redeployment. 

Performance Standards Performance Indicators Comments 

MORE Grants: 

As a result of time saved, 

grantees demonstrated enhanced 

community policing activities. 

Documentation kept by local law enforcement 

agency showing that time saved as a result of 

equipment, technology, overtime (funded only 

to MORE ’95 grant recipients), or civilians 

(MORE 2000 funded civilian support 

resources only) awarded, results in additional 

community policing activity. 

Grantees are required to identify 

the kind of community policing 

activities that have been enhanced 

as a result of time saved under the 

MORE grant. 

Grant Monitoring Standards for Hiring and Redeployment 43 

Revised July 2001 
C. Retention 

GOAL: Additional positions and/or the level of redeployment funded under the 

grant program are retained with State or local funding at the conclusion of the grant 

program for at least one full local budget cycle.

4 

Performance 

Standards 

Performance Indicators Comments 

Refer to section V, pages 20-23 for a complete definition of Retention. 

Hiring Grants: 

AHEAD, FAST, UHP, 

COPS in School, 

Distressed Neighborhood 

Pilot Project, and Small 

Community Grant 

Program grantees are 

required to plan for the 

retention of added officer 

positions with non-COPS 

grant funding. 

MORE Grants: 

Grantees must plan to 

retain the federally 

funded 

technology/equipment 

and/or civilians5

 and the 

resulting redeployment 

after the required level of 

redeployment6

 has been 

met. 

Hiring Grants: 

As of June 16, 1998, a retention plan must be submitted 

with the grant application 

One or more of the following may verify compliance: 

• Written assurance is submitted with the grant award 

application that State and local agencies will plan to seek 

local or State (or certain Federal agreements) funding to 

retain the COPS-funded officer position(s). 

• Certification in the application that states grantees 

understand and will abide by their submitted plans. 

• Written assurance is submitted with the Department 

Annual Reports that states how local agencies are 

planning to seek local or State (or certain Federal 

agreements) funding to add officer positions to their 

local budgets or maintain the level of redeployment after 

the COPS grant ends. 

• Grantees that received awards prior to June 16, 1998 

can provide other evidence of retention planning efforts 

upon request. 

MORE Grants: 

One or more of the following may verify compliance: 

• Retention statement is submitted with the MORE 

’98 and 2000 grant award application that State and local 

agencies will plan to seek local or State (or certain 

federal agreements) funding to retain the level of 

redeployment after the required level of redeployment 

has been met. 

• Written assurance is submitted with the MORE 

Progress Report that states how local agencies are 

planning to seek local or State (or certain federal 

agreements) funding to maintain the level of 

redeployment after the required level of redeployment 

has been met. 

Retention planning means that 

grantees must enter the threeyear Hiring grant program or, 

for MORE, the one-year grant 

period, with the understanding 

that they are required to seek 

local funding to add these 

positions to their local budgets 

or maintain the level of 

redeployment after the COPS 

grant ends. 

Requirement to submit a 

retention plan with the Hiring 

grant application was effective 

June 16, 1998. The plan also 

includes supporting 

documentation. 

Supporting planning evidence 

for Hiring grants is made up of 

memoranda, minutes of 

meetings, and other planning 

documents during the grant 

period. 

4

 There are two exceptions to this general rule. The Phase I grant conditions did not include a retention

requirement and MORE ‘95 overtime grantees are required to plan to continue the proposed overtime 

activities funded under COPS MORE. 5

 MORE ‘95 overtime grantees are required to plan to continue the proposed overtime activities funded under 

COPS MORE. 6

 In this document the required level of redeployment is used generically, referring to the level of

redeployment grantees must reach to be in compliance with their grant terms and conditions. See Appendix

A for more information about the required level of redeployment for specific MORE grant programs. 

Grant Monitoring Standards for Hiring and Redeployment 44 

Revised July 2001 
Retention, continued 

Performance 

Standards 

Performance Indicators Comments 

Refer to section V, pages 20-23 for a complete definition of Retention. 

• Grantees that received MORE grant awards prior to 

MORE ’98 and 2000 can provide other evidence of 

retention planning efforts upon request 

Hiring Grants: 

Retention of officer 

positions is maintained 

for one full local budget 

cycle after the Hiring 

grant funding period7 

ends. 

MORE Grants: 

Retention of the federally 

funded technology/ 

equipment and/or 

civilians and the resulting 

redeployment is 

maintained for one full 

local budget cycle after 

the required level of 

redeployment8

 has been 

met. 

Hiring Grants: 

Retention plan is fulfilled, if applicable, and retention 

maintained at least one full local budget cycle after the 

Hiring grant funding period ends. 

MORE Grants: 

Grantees retain the level of redeployment for one full 

local budget cycle after achieving the required level of 

redeployment. 

Regardless of when, during the 

local budget cycle, the grant 

funding period ends, the 

grantee must retain officer 

positions or level of 

redeployment from the 

beginning of the next local 

budget cycle to the end of that 

local budget cycle. 

Mitigating circumstances may 

impact the retention 

requirement. 

7

 The Phase I grant conditions did not include a retention requirement. See Appendix A for a definition of

the Hiring grant funding period. 8

 In this document the required level of redeployment is used generically, referring to the level of

redeployment grantees must reach to be in compliance with their grant terms and conditions. See Appendix

A for more information about the required level of redeployment for specific MORE grant programs. 

Grant Monitoring Standards for Hiring and Redeployment 45 

Revised July 2001 
D. Allowable Costs 

GOAL: Reimbursable costs issued under the COPS Program are reasonable in 

nature and permissible under the specific grant conditions. Grantees that receive 

waivers may receive more than 75% of officer salary or MORE project costs. 

Performance Standards Performance Indicators Comments 

Refer to pages 23-28 for a complete explanation of Allowable Costs. 

Hiring Grants: 

Recruited and hired agreed upon 

number of COPS-funded officers. 

Supporting documentation verifies 

that positions filled since grant was 

awarded agree with the approved 

costs for hiring officers, as identified 

in the COPS grant award. 

The grantee may recruit or hire, 

using COPS funding and following 

historic local practices, only the 

number of officer positions agreed 

upon in the approved grant award. 

Hiring Grants: 

Requested reimbursement for 75% of 

entry-level salary for an officer, 

including benefits, for duration of 

grant. The maximum amount per 

officer is $75,000 unless a waiver has 

been granted by the COPS Office. 

One or more of the following may 

verify compliance 

• Hiring confirmation paperwork 

with the offered and accepted salary, 

including benefits, available for 

review. 

• Documented entry-level salary, 

including benefits, available for 

review. 

• Reimbursement request agrees 

with 75% of department documented 

entry-level salary and benefits 

package for officers over three years. 

Only 75% of an officer’s entry-level 

salary, including benefits, may be 

reimbursable under the Hiring grant 

programs with a cap of $75,000 over 

three years (unless a waiver has 

been granted). The remaining 25%, 

any costs over the cap, and any costs 

for salaries and benefits above entrylevel must be paid by local funding. 

Furthermore, the percentage of total 

officers’ salaries and benefits paid 

with federal funds must be less in 

year two than in year one and less in 

year three than in year two. 

CIS Grants : 

Provides a designated portion of the 

salary and benefits over the three-year 

grant period, not to exceed $125,000. 

Any remainder of salary or benefits, if 

any, is to be paid by State or local 

funds. 

One or more of the following may 

verify compliance 

• Hiring confirmation paperwork 

with the offered and accepted salary, 

including benefits, available for 

review. 

• Documented salary, including 

benefits, available for review. 

• No waivers are offered under 

the CIS Program. 

• Officer position must be a new 

hire, but not necessarily an entrylevel position. 

MORE Grants: 

Requested reimbursement for civilian 

support services extend over the 

allowable period. 

Copy of grant award and any 

approved renewals or extensions, if 

applicable, which verifies allowable 

reimbursement requests of costs. 

MORE grants are awarded for one 

year only, with renewal available for 

up to two years after the initial grant 

period ends for civilian hires and 

overtime (MORE ’95), at the 

discretion of the COPS Office, and 

subject to funding availability. 

MORE Grants: 

Requested reimbursement for 

authorized technology/equipment. 

Copy of approved grant award, which 

supports technology and/or 

equipment requests for 

reimbursement. 

The grantee may only request 

reimbursement for those items 

agreed upon by the COPS Office on 

the approved grant award. 

Grant Monitoring Standards for Hiring and Redeployment 46 

Revised July 2001 
Allowable Costs, continued 

Performance Standards Performance Indicators Comments 

Refer to pages 23-28 for a complete explanation of Allowable Costs. 

Hiring Grants: 

Officer positions funded as full-time 

positions are filled with officers 

working full-time and positions 

funded as part-time are filled with 

officers working part-time. 

Supporting documentation is available 

detailing that COPS-funded officers 

are, in fact, working either full time or 

part time, in accordance with the grant 

award. 

Hiring grants can be awarded for 

either full-time or for part-time 

positions. Depending on the type of 

grant award, the officer must work 

either full or part time to justify 

salary and benefit costs. 

Hiring Grants: 

If a previous part-time officer was 

promoted to full-time under a COPS 

grant, then COPS monies were only 

expended after the vacant position 

was filled using local funding. 

One or more of the following may 

verify compliance 

• Paperwork associated with hiring 

new officers confirms that a 

replacement part-time officer was 

hired with local funding. 

• Department budget and payroll 

accounts verify previous part-time 

officer was not paid salary and 

approved benefits from COPS 

monies until the part-time 

replacement was hired. 

The law enforcement agency is 

required to hire new, additional parttime officers with local funds to 

replace any previously employed 

part-time officers who were 

promoted to full-time status under a 

COPS grant. The grantee cannot 

use COPS monies to reimburse the 

salary and approved benefits costs 

of the promoted part-time officer 

until a replacement part-time officer 

has been hired. 

MORE Grants: 

Cost of purchased technology/ 

equipment is within parameters as 

stated on the approved award, or as 

approved by the COPS Office. 

One or more of the following may 

verify compliance: 

• Purchase requests and payment 

receipts for each item purchased 

available for review. 

• Copy of approved grant award 

confirms reasonableness of item’s 

cost. 

If the payment of an item is to be 

deemed allowable, the cost must be 

reasonable. The approved grant 

award has the authorized amount 

available for use for the cost of an 

item. A comparison of the cost and 

the approved cost will assist in 

judging reasonableness. 

It should be noted that it may be 

permissible to obtain additional 

items in support of the MORE grant 

as a result of cost savings. Please 

see Section V.D. for more details. 

MORE Grants: 

Requested reimbursement for 75% of 

salary, including benefits, for a 

civilian hire for the duration of grant. 

One or more of the following may 

verify compliance 

• Hiring confirmation paperwork 

with the offered and accepted salary, 

including benefits, available for 

review. 

• Documented salary level, 

including benefits, available for 

review. 

• Reimbursement request agrees 

with 75% of department documented 

salary and benefits package for 

civilian support services. 

Only 75% of a civilian hire’s salary, 

including benefits, may be 

reimbursable under the MORE 

grants throughout the duration of the 

grant. The remaining 25% must be 

paid by local funding (unless a 

waiver is granted by the COPS 

Office). 

Fringe benefits for overtime were 

not an allowable cost under MORE 

’95 grant funding. 

Grant Monitoring Standards for Hiring and Redeployment 47 

Revised July 2001 
Allowable Costs, continued 

Performance Standards Performance Indicators Comments 

Refer to pages 23-28 for a complete explanation of Allowable Costs. 

MORE Grants: 

Time spent working on support 

service activities equivalent to full 

time or part time, measured in FTE’s. 

Supporting documents detailing either 

time spent working on support 

activities or attendance records is 

equivalent to full time or part time, 

measured in FTEs. 

MORE civilian grants can be 

awarded for either full-time or for 

part-time positions. Depending on 

the type of grant award, civilian hire 

must work either full time or part 

time to justify the salary and benefit 

costs. 

Performance Standards Performance Indicators Comments 

MORE Grants: 

If a previous part-time civilian was 

promoted to full-time under a COPS 

grant, then COPS monies were only 

expended after the vacant part-time 

position was filled using local 

funding. 

One or more of the following may 

verify compliance: 

• Paperwork associated with hiring 

new civilians confirms that a 

replacement part-time civilian was 

hired with local funding. 

• Department budget and payroll 

accounts verify that the previous 

part-time civilian was not paid salary 

and approved benefits from COPS 

monies until the part-time 

replacement was hired. 

The law enforcement agency is 

required to hire new, additional parttime civilians with local funds to 

replace any previously employed 

part-time civilians who were 

promoted to full-time status under a 

COPS grant. The grantee cannot 

use COPS monies to reimburse the 

salary and approved benefits costs 

of the promoted part-time civilian 

until a replacement civilian has been 

hired. 

Grant Monitoring Standards for Hiring and Redeployment 48 

Revised July 2001 
E. Source of Matching Funds 

GOAL: Grantee contributes at least 25% (unless granted a waiver) of the costs of the 

program, project, or activity that is funded by the COPS Program. 

Performance Standards Performance Indicators Comments 

Refer to pages 28-30 for a complete explanation of Source of Matching Funds. 

Hiring Grants: 

The grantee matched, or intends to 

match, the agreed upon percentage 

for the agreed upon hiring costs. 

One or more of the following may 

verify compliance: 

• Copy of approved grant award 

specifies agreed upon costs and 

percentage of match. 

• Copy of departmental budget 

confirms the intention of the grantee 

to pay the match, or budget 

confirms that match has already 

been paid. 

• Copy of departmental budget or 

other documents reflect the source, 

timing, and amount of match. 

The COPS grant will provide for UP TO 

75% over three years with a maximum 

of $75,000 for an entry-level officer’s 

salary and fringe benefits package. The 

grantee must cover AT LEAST 25% of 

the costs, unless a waiver has been 

granted by the COPS Office. 

The CIS Grant Program will cover up to 

a maximum amount of $125,000 for 

salary and benefits. Any costs over the 

maximum award must be paid by local 

or State funding. 

MORE Grants: 

The grantee matched, or intends to 

match, the agreed upon percentage 

for the agreed upon costs for the 

hiring of civilian support services and 

technology and equipment purchases. 

One or more of the following may 

verify compliance: 

• Copy of approved grant award 

specifies agreed upon costs and 

percentage of match. 

• Copy of departmental budget 

confirms the intention of the grantee 

to pay the match, or budget 

confirms that match has already 

been paid. 

The COPS grant will provide for UP TO 

75% of the costs throughout the 

duration of the grant, including renewal 

periods if applicable, civilian hire’s 

salary and fringe benefits package. The 

grantee must cover AT LEAST 25% of 

the costs, unless a waiver has been 

granted by the COPS Office. 

The grantee must pay AT LEAST 25% 

of all technology and equipment 

purchases (unless a waiver has been 

granted) while the COPS grant will 

contribute UP TO 75%. 

Hiring and MORE Grants: 

The source of the match is cash. 

Payment receipts or other 

documentation indicates the source 

of the match is cash. 

The source of the match must be cash 

according to COPS program policy. 

Hiring and MORE Grants: 

The source of the cash match is State, 

local, or approved Federal funds. 

Department budget and payment 

receipts, or other documentation, 

verify source of the cash match is 

State, local, equitable sharing or 

other approved federal or non-COPS 

grant funds. 

Source of funds is state, local, or 

Federal. Funds may not be Federal 

unless a tribal government has 

permission to use the Bureau of Indian 

Affairs monies or the Federal agency 

gives express permission to the grantee 

to use the funds for a match. The funds 

may not have come from other COPS 

grants or grant supplements. 

Hiring and MORE Grants: 

Source of match was not previously 

budgeted for other law enforcement 

purposes. 

Department budget, general ledger, 

payment receipts, or other 

documentation verify that the source 

of the match has not been 

specifically budgeted for other law 

enforcement needs. 

The source of the cash match must be in 

addition to funds previously budgeted 

for law enforcement purposes. 

Grant Monitoring Standards for Hiring and Redeployment 49 

Revised July 2001 
Source of Matching Funds, continued 

Performance Standards Performance Indicators Comments 

Refer to pages 28-30 for a complete explanation of Source of Matching Funds. 

Hiring Grants: 

The local contribution share increases 

each grant year while the Federal 

share decreases. 

Department budget, general ledger, 

or other documentation verify that 

the federal contribution is 

decreasing, while the local 

contribution is increasing each grant 

year. 

As a percentage of the total, the local 

share must increase each year during the 

grant period, and, conversely, the 

federal share must decrease. 

Hiring and MORE Grants: 

Cash match was paid in full before 

the grant period ended. 

One or more of the following may 

verify compliance: 

• Copy of approved award, 

including any approved no-cost 

extensions, specifies the end of the 

grant period. 

• Copy of department’s budget, 

general ledger, or other 

documentation verifies payment of 

match before the end of the grant 

period. Or, if applicable, a copy of 

a waiver verifies that the grantee is 

excused from the entire match or a 

portion of the match. 

The cash match must be fully paid 

before the end of the grant period. 

The grantee is excused from either the 

whole, or a portion of the, local cash 

match if the department has obtained a 

waiver. 

Grant Monitoring Standards for Hiring and Redeployment 50 

Revised July 2001 
F. Supplanting 

GOAL: COPS grant funds are used to supplement the budget of the law enforcement 

agency, not replace any funds which would have been budgeted for the grant-funded 

purpose in the absence of the grant. 

Performance Standards Performance Indicators Comments 

Refer to pages 31-35 for a complete explanation of Supplanting. 

Hiring Grants: 

The COPS funding increased the 

baseline level of funding for sworn 

officers and, concurrently, the 

baseline level of sworn officer 

positions. 

Copy of department and local 

government budget reflects no 

decrease in State or local funds for 

sworn personnel during each fiscal 

year of grant implementation. 

Or, if the baseline level of funding 

for sworn officers, or the level of 

sworn officer positions, decreased, 

copies of department and local 

government budgets and other 

supporting documentation verify that 

the decrease occurred for reasons 

unrelated to receiving the grant 

award. 

The goal of the grants is to increase the 

“baseline” level of State, local, or 

Bureau of Indian Affair funds that 

would have been budgeted for sworn 

officers in the absence of COPS 

funding. 

If there is a decrease in the baseline 

funds for officers or level of officer 

positions during the life of the grant, 

grantees must show that the decrease 

occurred for reasons unrelated to the 

award of grant funding. If the decrease 

occurred because the grantee received 

COPS grant funding, a supplanting 

violation exists. 

Hiring Grants: 

Grantee followed standard 

procedures used to recruit and hire 

part-time and full-time locally funded 

officer vacancies in a timely and 

active manner during the life of the 

grant. 

One or more of the following will 

verify compliance: 

• Copy of formal written 

procedures confirms grantee has not 

delayed in filling locally funded 

positions. 

• If there are no formal written 

procedures, review of historic hiring 

practices support grantee’s 

compliance with actively trying to 

fill locally funded positions. 

• Copy of civil service list and the 

grantee’s, or civil service officer’s, 

confirmation that historical hiring 

practices are being followed. 

• Copy of State, local or law 

enforcement training academy 

schedule verifies grantee’s intent to 

fill or actual filling of locally 

funded positions in conjunction 

with training schedules. 

• Documented high turnover rate 

for department supports grantee’s 

delay in filling vacant positions. 

• Rate that both COPS-funded 

vacancies and locally funded 

vacancies are filled is 

approximately the same or the 

grantee evidences that this did not 

occur for reasons unrelated to 

receipt of grant funding. 

The COPS guidelines state that the 

standard procedures used to fill locally 

funded officer vacancies must be 

followed by the grantee in a timely and 

active manner during the grant period. 

To determine if the grantee has 

continued its standard recruiting and 

hiring practice, various factors must be 

reviewed. Because of the unique 

recruiting and hiring practices of each 

agency, discretion is necessary. 

Grant Monitoring Standards for Hiring and Redeployment 51 

Revised July 2001 
Supplanting, continued 

Performance Standards Performance Indicators Comments 

Refer to pages 31-35 for a complete explanation of Supplanting. 

�� Grantee fills CIS-funded 

vacancies prior to filling locally 

funded, non-school resource officer 

vacancies, but continues to take 

active and timely steps to fill locally 

funded vacancies. 

Hiring Grants: 

Grantee delayed in following 

standard procedures used to recruit 

and hire locally funded part-time and 

full-time officer vacancies in a timely 

and active manner after the award of 

grant money for reasons unrelated to 

the receipt of grant funding. (May 

not be applicable to all grantees.) 

Supporting documentation verifies 

the delay in filling locally funded 

part-time and full-time officer 

vacancies occurred for reasons 

unrelated to grant funding. 

The COPS guidelines state that the 

standard procedures used to fill locally 

funded vacancies must be followed by 

the grantee in a timely and active 

manner after the receipt of grant 

money. If there has been a delay in 

filling locally funded officer positions, 

the cause of the delay must be for 

reasons unrelated to the grant award. 

Because of the unique recruiting and 

hiring procedures of each agency, 

discretion in judgment is necessary. 

Hiring Grants: 

Grantee uses local funds to fill a parttime officer position left vacant when 

an officer was promoted to fill a fulltime grant-funded position. Grant 

funds were not expended until the 

vacant position was backfilled. 

All of the following are necessary to 

verify compliance: 

• Copy of local budget documents 

indicating that the level of funding 

for part-time positions has at least 

remained the same as before the 

grant award. 

• Copy of documentation 

demonstrating that the part-time 

officer was hired with local funds 

before grant funds were expended 

on the promoted full-time officer. 

If a grantee chooses to promote a 

previously employed part-time officer 

to fill a full-time COPS grant position, 

then grantee must hire a new, 

additional part-time officer with local 

funds to backfill the resulting vacancy. 

The grantee may not expend COPS 

Hiring grant funds on the new full-time 

position until it has filled the part-time 

vacancy. 

Hiring Grants: 

Officers funded under the COPS 

grants were hired after the award of 

the grant. 

Documentation verifies the grant 

officers’ hire date to be after the 

grant award date. 

Or, if officers were hired before the 

award date, supporting 

documentation confirms officers 

were hired with the direct 

anticipation of receiving a COPS 

grant. 

COPS-funded officers are to be hired 

after the award date of the grant unless 

hired in direct anticipation of the grant. 

If officers were hired before the award 

date of the grant, and grant money is 

used to pay for the costs of salaries and 

benefits after the award, the grantee 

must demonstrate that the officers were 

hired in anticipation of the grant 

award. 

MORE Grants: 

State or local baseline level of 

funding for civilians and level of 

civilian positions does not decrease 

during the life of the grant. 

Copy of department or local 

government budget reflects no 

decrease in Stateor local funding for 

civilian personnel during each fiscal 

year of grant implementation. 

The goal of the grants is to increase the 

“baseline” level of State, local, or 

Bureau of Indian Affair funds that 

would have been budgeted for civilian 

personnel in the absence of COPS 

funding. 

Grant Monitoring Standards for Hiring and Redeployment 52 

Revised July 2001 
Supplanting, continued 

Performance Standards Performance Indicators Comments 

Refer to pages 31-35 for a complete explanation of Supplanting. 

Or, if the baseline level of funding 

for civilians or the level of civilians 

positions decreased, copies of 

department, local government 

budgets, or other supporting 

documentation verify that the 

decrease occurred for reasons 

unrelated to the grant award. 

If there is a decrease in the State or 

local baseline funds for civilians or 

level of civilian personnel during the 

life of the grant, grantees must show 

that the decrease occurred for reasons 

unrelated to the award of grant 

funding. If the decrease occurred 

because the grantee received grant 

funding, a supplanting violation exists. 

MORE Grants: 

Grantee followed standard 

procedures used to recruit and hire 

part-time and full-time locally funded 

civilian support vacancies in a timely 

and active manner during the life of 

the grant. 

One or more of the following will 

verify compliance: 

• Copy of formal written 

procedures confirms grantee has not 

delayed in filling locally funded 

positions. 

• If there are no formal written 

procedures, review of historic hiring 

practices support grantee’s 

compliance with filling, or actively 

trying to fill locally funded 

positions. 

• Copy of civil service list and the 

grantee’s, or civil service officer’s, 

confirmation that historical hiring 

practices are being followed. 

• Documented high turnover rate 

for department supports grantee’s 

delay in filling vacant positions. 

• Rate that COPS-funded 

vacancies and locally funded 

vacancies are filled is 

approximately the same or the 

grantee provides evidence that a 

delay in filing local vacancies 

occurred for reasons unrelated to 

receipt of grant funding. 

The COPS guidelines state that the 

standard procedures used to fill locally 

funded civilian support vacancies must 

be followed by the grantee in a timely 

and active manner during the grant 

period. To determine if the grantee has 

continued its standard recruiting and 

hiring practice, various factors must be 

reviewed. Because of the unique 

recruiting and hiring practices of each 

agency, discretion is necessary. 

MORE Grants: 

Grantee delayed in following 

standard procedures used to recruit 

and hire locally funded part-time and 

full-time civilian vacancies in a 

timely and active manner after the 

award of grant money because of 

reasons unrelated to the receipt of 

grant funding. (May not be 

applicable to all grantees.) 

Supporting documentation verifies 

that the delay occurred for reasons 

unrelated to the receipt of COPS 

grant funding. 

The COPS guidelines state that the 

standard procedures used to fill locally 

funded vacancies must be followed by 

the grantee in a timely and active 

manner after the receipt of grant 

money. If there has been a delay in 

filling locally funded civilian 

positions, the delay must have 

occurred for reasons unrelated to the 

grant award. Because of the unique 

recruiting and hiring procedures of 

each agency, discretion in judgement is 

necessary. 

Grant Monitoring Standards for Hiring and Redeployment 53 

Revised July 2001 
Supplanting, continued 

Performance Standards Performance Indicators Comments 

Refer to pages 31-35 for a complete explanation of Supplanting. 

MORE Grants: 

Grantee funded a part-time civilian 

position with local monies to backfill 

a position that was left vacant when 

another part-time civilian was 

promoted to fill a full-time grantfunded position. rant funds were 

not expended until the vacant 

position was backfilled. 

All of the following are necessary to 

verify compliance: 

• Copy of budget documents 

indicating that the level of funding 

for part-time positions has at least 

remained the same as before the 

grant award. 

• Copy of documentation 

demonstrating that the part-time 

civilian was hired with local funds 

before grant funds were expended 

on the promoted full-time civilian. 

If a grantee chooses to promote a 

part-time civilian to fill a full-time 

COPS grant position, then grantee 

must hire a new, additional part-time 

civilian with local funds to backfill 

the resulting vacancy. The grantee 

may not expend COPS Hiring grant 

funds on the new full-time position 

until it has filled the part-time 

vacancy. 

MORE Grants: 

Purchase of approved technology and 

equipment occurred after the award 

start date. 

Purchase requests, payment receipts, 

or other documentation for each item 

purchased verifies purchase occurred 

after date of grant award. 

Or, if purchase of approved 

technology and equipment occurred 

before the award date, then purchase 

requests, payment receipts, 

department budget, or other 

supporting documentation confirms 

that purchases were made with the 

direct anticipation of receiving a 

COPS grant. 

COPS-funded technology and 

equipment items are to be purchased 

after the award date of the grant 

unless purchased in direct anticipation 

of the grant. 

If approved technology and 

equipment items are purchased before 

the award date of the grant, and grant 

money is used to pay for the costs of 

the items after the award, it must be 

proved that the items were purchased 

in anticipation of the grant award. 

MORE Grants: 

Civilians performing support services 

under the COPS grants were hired 

after the award start date. 

Paperwork associated with the hiring 

of new civilians for support services 

verifies the hire date to be after the 

award start date. 

Or, if new civilians were hired 

before the award date, then 

department budget and other 

supporting documentation confirms 

that civilians were hired with the 

direct anticipation of receiving a 

COPS grant. 

COPS-funded civilian hires are to be 

hired after the award date of the grant 

unless hired in direct anticipation of 

the grant. 

If civilians were hired before the 

award date of the grant, and grant 

money is used to pay for the costs of 

salaries and benefits after the award, 

it must be proved that the civilians 

were hired in anticipation of the grant 

award. 

G

Grant Monitoring Standards for Hiring and Redeployment 54 

Revised July 2001 
G. Training: Special Conditioned Grantees 

GOAL: Sworn officers, representing a “special conditioned” local law enforcement 

department and school administrators, receive the required, respective COPS Office 

community policing training or SRO training. 

Performance Standards Performance Indicators Comments 

Refer to pages 37 for a complete explanation of Training. 

Hiring and MORE Grants: 

Sworn officers from a department 

with a “special condition” 

designation have attended the two 

mandatory COPS community 

policing trainings before the end of 

the grant period – for grants issued 

prior to 2001. 

COPS in Schools (CIS) Grants: 

Each COPS funded SRO and the 

school administrator representing the 

lead partnering agency must attend 

one COPS-sponsored SRO training 

session. 

One of the following verified 

compliance: 

• Copy of training attendance 

verifying that a sworn officer had 

fulfilled the requirement and/or 

documentation of on-site training. 

• Evidence showing that the 

training was completed before the 

grant period ended. 

The following will verify 

compliance: 

Evidence showing that the training 

was completed before the grant 

period ended. 

A sworn officer must have acted as a 

representative for each department 

with a “special condition” designation. 

Department representative(s) must 

have completed two trainings to 

achieve compliance. 

CIS grantees are encouraged to meet 

the training requirement in the early 

stages of the grant period. Both the 

COPS funded SRO(s) and school 

administrator are encouraged to attend 

the training together 

Grant Monitoring Standards for Hiring and Redeployment 55 

Revised July 2001 
H. Reporting 

GOAL: Program Progress Reports and Financial Status Reports that provide 

information about the status of grants are promptly submitted to the proper Federal 

agency. 

Performance Standards Performance Indicators Comments 

Refer to pages 37-39 for a complete explanation of Reporting. 

Hiring Grants: 

Department Initial Reports are 

completed and submitted to the COPS 

Office within 45 days of receipt. 

All of the following are necessary to verify 

compliance: 

• Department Initial Report received by the 

COPS Office. 

• Department Initial Report completed 

accurately. 

• Department Initial Report submitted on 

time. 

• Sworn Force Level reported by two 

distinct categories: 1) Budgeted, and 2) 

Actual. 

The Department Initial Report 

is required only if a Hiring 

grant is awarded for the first 

time. This applies to Hiring 

grants only. 

Hiring Grants: 

Department Annual Reports are 

completed and submitted to the COPS 

Office in February of each year. 

All of the following are necessary to verify 

compliance: 

• Department Annual Report received by 

the COPS Office, even if the grant has been 

in effect for only a portion of the reporting 

period. 

• Department Annual Report completed 

accurately. 

• Department Annual Report submitted on 

time. 

• Sworn Force Level reported by two 

distinct categories: 1) Budgeted and 2) 

Actual. 

Department Annual Reports 

are required annually until 

grant is closed out. 

MORE Grants: 

MORE Progress Reports are 

completed and promptly submitted to 

the COPS Office within 45 days of 

receipt. 

All of the following are necessary to verify 

compliance: 

• MORE Progress Report received by the 

COPS Office, even if civilian personnel are 

not hired or equipment is not purchased. 

• MORE Progress Report completed 

accurately. 

• MORE Progress Report submitted on 

time. 

Only one progress report is 

required for MORE grants. 

As of January 1, 1999, 

grantees have been required to 

submit a redeployment 

tracking plan with the MORE 

Progress Report. 

Grant Monitoring Standards for Hiring and Redeployment 56 

Revised July 2001 
Reporting, continued 

Performance Standards Performance Indicators Comments 

Refer to pages 37-39 for a complete explanation of Reporting. 

Hiring Grants: 

Officer Progress Reports – See 

Comments. 

Beginning in December 1999 

and for future reporting 

periods, the Officer Progress 

Report has no longer been 

required due to incorporation 

of the questions into the 

COPS Count Surveys. 

Hiring and MORE Grants: 

Financial Status Reports are 

completed and submitted to the COPS 

Office within 45 days after the end of 

the calendar quarter. 

All of the following are necessary to verify 

compliance: 

• Financial Status Reports, SF-269A, 

received by the COPS Office. 

• Financial Status Reports, SF-269A, 

completed accurately. 

• Financial Status Reports, SF-269A, 

submitted on time. 

Grant Monitoring Standards for Hiring and Redeployment 57 

Revised July 2001 
Appendix A: Glossary of Terms 

Allowable Costs 

The Hiring programs provide for the salaries and approved fringe benefits for three years 

for sworn entry-level, lateral-transfer, or rehired officers. Only entry-level salary and 

fringe benefit costs are allowable costs under the grant. Overtime, training (other than 

salary and benefits paid during training), weapons, communication equipment, uniforms, 

vehicles and indirect cost are not allowable costs. The COPS budget memorandum 

itemizes what costs are allowable. 

The MORE Program provides for the salaries and approved fringe benefits for the duration 

of the grant period, including through the renewal period if applicable, for civilian hires 

who perform support and administrative services. Equipment and technology 

reimbursement requests are also permissible under the program as long as the purchases 

contribute to time savings for the officers who can then be deployed to community 

policing activities. Overtime costs were also allowable under the MORE ’95 Program. 

The Memorandum of Recommended and Estimated Funding and the COPS budget 

memorandum specify what costs are allowable under the MORE grants. 

Authorized Official 

The authorized and/or budgetary official is the individual in a grantee’s organization who 

has final responsibility for all programmatic and financial decisions regarding a grant 

award. 

Baseline Level 

The “baseline” is the level of State or local funding for sworn personnel (if a Hiring grant) 

or for civilians (if a MORE grant) which would exist in the absence of the COPS grant 

funds. To comply with the non-supplanting requirement, the grantee must use COPS grant 

funding to increase (supplement) the baseline at all times during the grant period. 

Reductions in the State or locally funded baseline must be justified by the grantee as 

unrelated to the receipt of COPS grant funding. 

Community Policing 

Community Policing is a policing philosophy that promotes and supports organizational 

strategies to address the causes, and reduce the fear, of crime and social disorder through 

problem-solving tactics and community-police partnership. 

Grant Monitoring Standards for Hiring and Redeployment 58 

Revised July 2001 
COPS Office 

The Office of Community Oriented Policing Services (COPS) is the "grantor agency" for 

the grantee’s COPS grants. The COPS Office is directly responsible for programmatically 

administering and monitoring the grant for the entire grant period. 

Grant Award Period 

The grant award period runs from the official Award Start Date, which may be found on 

the Award Document, for three full years if a Hiring grant or for one full year if a MORE 

grant. If a grantee obtains a no-cost extension to the grant award period to provide 

additional time for spending grant monies during the three-year or one-year grant, the 

official grant award period is extended until the end date of the no-cost extension. 

Grant Number 

This number, which is located in the upper, left-hand corner of the grant Award Page, 

uniquely identifies each grant, and is presented in different formats depending on the grant 

program type and population the agency serves. The grant number contains 12 alphanumeric characters arranged as shown below. Prior to FY1999, the grant number only 

contained eight characters. 

The first four characters represent the fiscal year the grant was awarded (e.g., FY2001). 

The fifth and sixth characters represent the fund code and population (served by the 

agency) of the program represented (e.g., “UM” which signifies a UHP grant for an agency 

serving a population of less than 150,000). The next two characters will always be “WX”, 

which represent a COPS Office identifier. If the grant is a cooperative agreement, a “K” 

will follow the sixth character. The last four characters represent the order in which the 

grant was awarded by the COPS Office (e.g., the last four digits of the first grant awarded 

in FY2001 would be “0001”, the second grant awarded would be “0002”, etc.). If the 

grant is a cooperative agreement, the last three digits would represent the order in which a 

grant was awarded, instead of four (e.g., “001”, “002”, etc.) 

Using the definition above, a UHP grant which was awarded to an agency serving a 

population of less than 150,000 and which was the 56th grant awarded by the COPS Office 

in FY2001, would be assigned the number “2001UMWX0056.” If the grant were a 

cooperative agreement, it would be assigned the number “2001UMWXK056.” 

Hiring Grant Funding Period 

The Hiring grant funding period begins the day a COPS-funded officer position is filled 

and runs through the time when the specific position has been funded for 36 months 

through COPS funds and the grantee’s local match. The COPS Office recognizes that 

grantees awarded multiple officer positions may fill those positions at different times and 

that there may be interruptions because of these positions becoming vacant. Therefore, it 

is possible that there is a separate Hiring grant funding period for each officer position and 

Grant Monitoring Standards for Hiring and Redeployment 59 

Revised July 2001 
that the 36 months of funding may require more than three years to complete. The COPS 

Office will measure successful retention as retention for one full local budget cycle 

following the conclusion of the Hiring grant funding period for each position. 

Lateral Transfer 

A “lateral transfer” is an additional experienced law enforcement officer that a COPS 

grantee newly hires from another law enforcement agency to fill a COPS grant position. 

As with all grant officers, lateral transfers must be hired by the COPS grantee after the 

official COPS grant award date or hiring authorization date if earlier (see Appendix C). 

Matching Funds 

Under AHEAD, FAST, UHP and MORE, the grantee is required to match, in cash, a 

portion of the allowable costs of the program, project, or activity as funded by the COPS 

program. Grant awards may cover up to 75% of the costs as outlined in the budget 

submission, and the grantee must contribute at least 25% unless a waiver is obtained. The 

CIS Grant Program has no local match requirement up to a maximum award amount of 

$125,000 for entry-level salary and benefits. Any costs over the maximum award must be 

paid by local or State funding. 

Obligation of Funds 

Obligation means a legal liability to pay determinable sums for services or goods incurred 

during the grant period. Federal funds are considered "obligated" when the Director of the 

COPS Office, or his designated official, signs the grant award document. Funds are 

reserved against the grant until the grantee is reimbursed for all allowable expenses 

incurred and reported, or until the grant expires. Local funds are considered "obligated" 

when the salaries and benefits have been paid or will be paid for work performed by the 

officer(s) during a previous pay period. 

The Public Safety Partnership and Community Policing Act of 1994 

The COPS Office is charged with fulfilling the mandates of this law. The purposes of the 

law are to: substantially increase the number of law enforcement officers interacting with 

members of the community; provide additional and more effective training to law 

enforcement officers to enhance their problem-solving, service and other skills needed 

when interacting with members of the community; encourage the development and 

implementation of innovative programs to permit members of the community to assist law 

enforcement agencies in the prevention of crime; and encourage the development of new 

technologies to assist law enforcement agencies in reorienting the emphasis of their 

activities from reacting to crime to preventing crime. 

Grant Monitoring Standards for Hiring and Redeployment 60 

Revised July 2001 
Redeployment 

Redeployment is defined as when sworn officers, currently employed by the grantee’s law 

enforcement agency, become available to participate in enhanced community policing as a 

direct result of the purchase of technology or equipment or the hiring of civilian support 

personnel. 

Reduction in Baseline Funding in Sworn Personnel 

If the baseline funding decreases during the grant period, as a result of a reduction in State 

or local funding, the grantee must prove that the reduction is (or was) unrelated to the 

receipt of COPS funding to demonstrate compliance with the non-supplanting requirement. 

Rehired Officer 

A “rehired officer” is an officer who was (or is about to be) laid off for financial reasons 

unrelated to the COPS grant and is “rehired” with COPS grant funds after the official 

COPS grant award date. If the officer was (or will be) laid off after the grant award start 

date, COPS grantees should obtain written authorization from the COPS Office to use 

COPS grants funds to rehire a laid off officer. 

Required Level of Redeployment 

In this document the required level of redeployment is used generically, referring to the 

level of redeployment grantees must reach to be in compliance with their grant terms and 

conditions. MORE ’96, ’98, and 2000 grantees are required to meet the “Required Level 

of Redeployment” stated on their grant award document. MORE ‘95 grantees are required 

to meet what was termed the “projected/actual level of redeployment” that they projected 

on their application and appears on their grant award document. Please see below for more 

information. It is important to note that grantees generally will not be able to reach their 

required level of redeployment until the project has been fully operational for 12 months. 

For example, after six months of full operation, a grantee would likely have achieved only 

half the required number of redeployed FTEs (full time equivalents). The COPS Office 

will measure successful retention as retention for one full local budget cycle after the 

required level of redeployment has been met. 

a) MORE ’96, ’98, and 2000: These MORE grant programs used the term “Required 

Level of Redeployment” to refer to the number of FTEs that a grantee must redeploy 

as a result of time savings achieved through the purchase of equipment and technology 

or the hiring of civilians (MORE 2000-funded civilian support resources only) in order 

to meet the conditions of the grant under the MORE ‘96, ’98 and 2000 programs. This 

number is based on the calculation of up to 75% of the total project cost of items 

awarded divided by 75% of the cost of an officer up to $25,000. 

Grant Monitoring Standards for Hiring and Redeployment 61 

Revised July 2001 
Example: The Marysville Police Department would like to be awarded funding for 

20 laptop computers. The total cost of these laptops is $100,000. The department 

can request up to 75% of the cost of the item ($75,000). To calculate the 

“Required Level of Redeployment,” the COPS Office divides 75% of the total cost 

of the item by 75% of the cost of an officer’s salary for one year up to $25,000. 

Officers at this department make $40,000 per year. 75% of 40,000 goes over the 

$25,000 cap, so COPS uses the $25,000 figure. The formula used to calculate the 

department’s “Required Level of Redeployment” is as follows: 

75,000/25,000 = 3.0 FTEs. (“Required Level of Redeployment”) 

Therefore, the grantee would reach the required level of redeployment when the 

equivalent of 3.0 FTEs has been redeployed. 

b) MORE ’95: The MORE ’95 Grant Program used the term “projected/actual level of 

redeployment” to refer to the number of FTEs a grantee projected that they will redeploy as a 

result of time savings achieved through the purchase of equipment and technology or the 

hiring of civilians. Under the MORE ‘95 program, grantees are required to achieve the 

“Actual Level of Redeployment” to meet the conditions of the grant. This number is 

calculated by multiplying the number of hours that are projected to be saved by the number 

of officers who will realize time savings and the number of shifts each of these officers will 

work in a year. This is divided by the COPS standard of 1,824 hours per year for one FTE. 

It should be noted that grantees may use different variations of this formula to calculate their 

estimated time savings as long as they use the COPS 1,824 hours standard for one FTE. 

Example: The Marysville Police Department estimates that by using laptop 

computers to write their reports in the field, each of the officers in the department

will be able to save 1 hour per shift. There are 30 officers in the department who 

will realize this time savings. The formula used to calculate the department’s

“Actual Level of Redeployment” is as follows: 

1 hour x 30 officers x 228 shifts (COPS standard) = 6,840 hours 

6,840 / 1,824 (COPS standard) = 3.8 FTEs. (“Actual Level of Redeployment”) 

Therefore, the grantee would reach the required level of redeployment when the 

equivalent of 3.8 FTEs has been redeployed. 

Supplanting 

For the purpose of a COPS grant, supplanting means replacing State or local funds, which 

otherwise would have been spent on the specific law enforcement purposes of the COPS 

grant, (e.g. hiring sworn officers; hiring civilians; purchasing equipment or technology) with 

federal COPS funds. A grantee is prohibited from supplanting throughout the grant period, 

which means that a grantee may not use COPS funds to pay for any personnel, civilians or 

officers, or any technology and equipment that otherwise would have been employed, 

purchased, or made available with State or local funds in the absence of the COPS Program. 

COPS funds must be used, instead, to supplement a grantee’s law enforcement budget for 

these purposes. 

Grant Monitoring Standards for Hiring and Redeployment 62 

Revised July 2001 
Supplemental Grant Award 

A Supplemental Grant Award is a grant award, which adds monies to, and increases the 

scope of, an existing grant under the same grant award number. Supplemental funds may 

be added to COPS AHEAD, FAST, and UHP grants. Although supplemental grant funds 

are added to an existing grant award number, they are not renewals of the existing grant. 

For all compliance purposes, supplemental grants are new grant awards with new grant 

start and end dates. The benefit of this is that the grantee’s jurisdiction need only fill out 

one set of Program Progress Reports and Financial Status Reports for both the original 

grant award and any supplemental awards. 

Support Services 

Support services are those services provided by non-sworn personnel, including civilians, 

funded under the COPS MORE Programs. The hiring of these personnel must result in the 

redeployment of sworn officers into community policing. 

Sworn Career Law Enforcement Officer 

A sworn career law enforcement officer is an officer, hired on a permanent basis, who is 

authorized by law or by a State or local public agency, to engage in, or supervise, the 

prevention, detection or investigation of violations of criminal law. 

Threshold Review Date 

The COPS Office first measures the grantee’s baseline as of a threshold review date 

(standard for each program), plus any Stateor local funding added for additional sworn 

officer positions after the threshold review date during the grant period. The baseline 

therefore may increase during the grant period if additional State or local funding is 

budgeted for sworn personnel (see Appendix C). Reductions in the baseline after the 

threshold review date may be indications of supplanting (see Chapter V.F.) 

Grant Monitoring Standards for Hiring and Redeployment 63 

Revised July 2001 
Appendix B: Examples of Compliance/Non-Compliance Cases 

Source of Matching Funds 

EXAMPLE 1. When audited, a police department shows that it paid its 25% local match 

to a COPS MORE grant with funds from the department’s “equipment and technology” 

line item. 

Possible Source of Matching Funds Violation. If grantees include the source of the local 

match in the current year’s operating budget, it must be intentionally budgeted in 

anticipation of the grant award; or previously budgeted as reserve or discretionary monies; 

and have not been previously budgeted for specific law enforcement purposes. 

Investigation and Analysis. The department provided a memorandum and related budget 

documents from its city budget office that showed the city had provided new, additional 

local funds to the department specifically to pay for the local match to the COPS grant. 

Because the MORE grant application requested funding for equipment, the city chose to 

place the required match into the “equipment and technology” budget line item. Further, 

other documentation revealed that the city also provided the additional local funding for 

the department in anticipation of the grant award. 

Final Resolution. The grantee is in compliance with the source of matching funds 

requirement. 

Supplanting 

EXAMPLE 1. The department has one open locally funded full-time position. However, 

this position continues to be vacant while the city continues to hire COPS-funded officers. 

Possible Supplanting Violation. In assessing the presence of supplanting, it is expected 

that the grantee will continue to hire new officers at a level consistent with the recent 

historical practice and take positive steps to fill all vacancies resulting from attrition. 

These steps must be taken in addition to hiring the officers funded with the COPS grant. A 

grant recipient may show, however, based on particular local fiscal or other conditions, that 

it is not possible to take all of these steps, or that it would have taken the same action that 

raises a question of supplanting even if the COPS grant had not been awarded. 

Investigation and Analysis. The city has been deemed to be in a state of financial 

emergency. Enough debt has been accumulated on behalf of the city such that it needs to 

procure a $300,000 loan simply to continue to exist. Further, it is understood that the 

entire city personnel staff has been laid off except for the City Manager and the remaining 

police personnel. The city provides documentation demonstrating that all departments, 

including the police department, are under a citywide hiring freeze. 

Grant Monitoring Standards for Hiring and Redeployment 64 

Revised July 2001 
Final Resolution. The grantee is compliant with the non-supplanting requirements. The 

vacancy is a result of a citywide hiring freeze that is unrelated to the COPS grant. 

EXAMPLE 2. Before receiving a COPS Hiring grant, a city passes a tax increase for the 

specific purpose of adding 10 sworn officer positions to the police department. At the time 

of the grant award, the department has not hired any new officers for the additional 10 

positions. Upon receiving grant funding, the department hires 10 new sworn officers and 

pays for the additional positions with COPS grant funds. The city then reduces the taxes 

the following year to “return” the previously enacted tax increase to the citizens. 

Possible Supplanting Violation. The department is required to hire all new, additional 

officer positions for which the State or local funds would be budgeted in the absence of the 

grant in addition to hiring the additional COPS grant positions. The city may not reduce the 

department’s budget for sworn personnel as a direct result of the receipt of Hiring grant funds. 

Investigation and Analysis. The city committed additional local funds to hire 10 new 

sworn officers for the department before the COPS grant award was funded. This 

commitment of local funding increased the city’s baseline level of locally funded sworn 

personnel by the additional 10 positions. The fact that the department has not filled these 

positions at the award date of the grant is irrelevant to the non-supplanting analysis. 

Final Resolution. The city violated the non-supplanting requirement by using grant funds to 

replace local funds when hiring the 10 officers. The city had specifically instituted a tax 

increase for the purpose of hiring 10 new, additional sworn officers, and once the officers were 

hired, after the award of grant funding, the city “returned” the tax increase to the citizens. 

The city ultimately agreed that it supplanted the local funds initially raised through 

increased taxes with COPS grant funds. The city agreed to repay the grant funds to the 

COPS Office to remedy the non-supplanting violation. 

EXAMPLE 3. A department receives a MORE grant to purchase 10 mobile data 

terminals (MDTs). The grant award start date is October 1, 1998. When audited, the 

department provides copies of the purchase orders for the MDTs, which were signed on 

June 1, 1998. The department did not pay for the terminals until November 1, 1998, and 

the MDTs were not delivered to the department until December 1, 1998. 

Possible Supplanting Violation. All COPS MORE grant funds must be expended on 

civilians hired or equipment purchased following the award date of the COPS grant. If 

personnel are recruited or hired before the award date of the grant, or if equipment was 

purchased before the award date, there must be a clear and direct causal link between the 

hiring and the anticipation of grant funding. Further, MORE grantees must purchase new, 

additional equipment and technology that would otherwise not be purchase with State or 

local funds. 

Grant Monitoring Standards for Hiring and Redeployment 65 

Revised July 2001 
Investigation and Analysis. If the signed purchase order from June 1, 1998 represented a 

commitment to purchase the MDTs without regard to the availability to COPS grant 

funding, the date of payment and delivery is irrelevant to supplanting analysis. 

The department was unable to provide any supporting documentation to link the signed 

purchase order of June 1, 1998 to the anticipation of the MORE grant funding. The 

purchase order itself did not reference the source of funding for the MDT’s, and it did not 

contain any clause that purchase was contingent upon outside factors regarding the source 

of funding. The department was unable to supply any correspondence between department 

officials and the vendor to indicate that the MORE funds had been discussed in any way in 

relation to the signed purchase order. In addition, a May 1998 memorandum from the city 

manager’s office to the department authorized the department to sign the purchase order 

with the understanding that the city would pay for the terminals “if the federal grant did 

not come through.” 

Final Resolution. The grantee is not compliant with the supplanting requirement because 

it used grant funds to purchase the MDTs pre-award and not in direct anticipation of the 

award. The violation was confirmed with the memorandum from the city manager stating 

that the city would pay for the terminals if the COPS Office did not award the department a 

grant. 

The department repaid the COPS MORE grant funds that had been expended on the 

MDTs. 

Financial Reports 

EXAMPLE 1. Records indicate that the grantee is behind in submitting financial status 

reports. 

Possible Financial Reporting Violation. A Financial Status Report (SF-269A) must be 

completed by grantee and returned on a quarterly basis to the COPS Office. The Financial 

Status Reports request information on monies spent, or accrued, including amounts for 

Federal expenditures, local matching contributions and the unobligated balance of the 

award. 

Investigation and Analysis. There had not been any financial activity on the grantee’s 

behalf for the past two quarters, but the financial reports must be completed and submitted to 

the COPS Office. The grantee completed one report covering all periods for which it was 

delinquent (two quarters in this case) and faxed it to the appropriate COPS point of contact. 

Final Resolution. The grantee is compliant with the financial reporting requirement. 

Grant Monitoring Standards for Hiring and Redeployment 66 

Revised July 2001 
EXAMPLE 2. Grantee claims they did not draw down funds in the amount of $13,897 on 

11/13/97 as the Office of the Comptroller’s records indicate. 

Possible Financial Reporting Violation. Financial Status Report (SF-269A) must be 

completed by grantee and returned on a quarterly basis to the COPS Office. The Financial 

Status Reports request information on monies spent including amounts for both the Federal 

and local match portion of the award. 

Investigation and Analysis. Although the grantee does not have any record of the 

transaction, a previous draw down for the same amount was processed six months earlier, 

and there were two draw downs from that account, one of which was posted on 11/13/97 

according the Office of the Comptroller financial transactions records and the grantee’s 

banking institution. It appears as if the grantee's accounting records are in error and should 

be adjusted. 

Final Resolution. Once the grantee adjusts their accounting records and verifies that their 

quarterly financial report accurately reflects grant expenditures, then they will be 

compliant with the financial reporting requirement. 

Grant Monitoring Standards for Hiring and Redeployment 67 

Revised July 2001 
Appendix C: Grant Threshold Review Dates

COPS Hiring Grants Program 

Name 

Threshold Supplanting 

Review Date 

Early Hire 

Review Date 

Phase I October 1, 1994 October 1, 1994 

AHEAD October 1, 1994 October 1, 1994 

FAST October 1, 1994 February 8, 1995 

Universal Hiring Program (UHP) 

and COPS in Schools (CIS) 

5/1/00 – 4/30/01 application May 1, 2000 Award Start Date 

5/1/99 – 4/30/00 application May 1, 1999 Award Start Date 

5/1/98 – 4/30/99 application May 1, 1998 Award Start Date 

5/1/97 – 4/30/98 application May 1, 1997 Award Start Date 

5/1/96 – 4/30/97 application May 1, 1996 Award Start Date 

5/1/95 – 4/30/96 application May 1, 1995 Award Start Date 

COPS Redeployment 

Grants 

Program Name 

Threshold Supplanting 

Review Date 

Early Hire or 

Purchase 

Review Date 

COPS MORE ‘95 Application Submission Date Award Start Date 

COPS MORE ‘96 Application Submission Date Award Start Date 

COPS MORE ‘98 Application Submission Date Award Start Date 

COPS MORE 2000 Application Submission Date Award Start Date 

Grant Monitoring Standards for Hiring and Redeployment 68 

Revised July 2001 
Appendix D: Examples of Redeployment Tracking 

EXAMPLE 1: REDEPLOYMENT BY SHIFT 

The Neely County Sheriff's Department applies for a MORE grant to purchase 10 Mobile 

Data Terminals (MDTs). The department has 20 full-time officers assigned to patrol; each 

MDT will be used by more than one officer. Currently, each patrol officer runs an average 

of 20 tag or license checks per shift. Each check takes about five minutes. If the 

department receives the MORE grant, they estimate that each officer will only need three 

minutes per check, a savings of two minutes per check. The cost of the 10 MDTs is 

$100,000. To determine their required level of redeployment, the department would use the 

following formula which is laid out in the Cost Effectiveness Worksheet portion of the 

grant application: 

Required Redeployment 

Line 1 Entry level salary of SWORN police officer (as of Jan. 1, 1998) 1. $ 28,000 

Line 2 Fringe benefits of SWORN police officer (as of Jan. 1, 1998) 2. $ 5,000 

Line 3 Add lines 1 and 2 3. $ 33,000 

Line 4 Multiply line 3 by .75 4. $ 24,750 

Line 5 Enter figure on line 4 or $25,000, whichever is less 5. $ 24,750 

Line 6 Total cost of item, system, or group of like items (100%) 6. $ 100,000 

Line 7 Federal amount requested. Can be no more than 75% of total 7. $ 75,000 

item cost (line 6) 

Line 8 Divide line 7 by line 5 8. 3.03 FTEs 

Projected/Actual Redeployment 

The formula used to calculate the projected actual redeployment for this grant would be: 

2 min. saved X 20 checks = 40 min. per shift 

40 min./shift X 20 officers x 228 shifts = 182,400 min./yr. 

182,400 min./60min. = 3,040 hrs. per yr. 

3,040 hrs. /1,824 hrs. (COPS standard) = 1.66 FTEs 

1.66 FTE saved per year 

This is less than the required amount in the above calculation, but as demonstrated below, 

the department plans to use the MDTs for other uses also. 

The department also states that they will use the laptops for report writing while their 

patrol officers are in their vehicles. Again, the laptops will be used by more than one (1) 

officer. Currently, each of the 20 officers spends two hours per shift writing their reports. 

With the laptops, they believe they can save 1 hour per shift. The reports will have 

automated formats and can be sent for approval, via modem, versus driving back to the 

station. 

Grant Monitoring Standards for Hiring and Redeployment 69 

Revised July 2001 
The formula used to calculate the projected actual redeployment is: 

1 hr. per shift X 20 officers X 228 shifts = 4,560 hrs. per yr. 

4,560 hrs./1,824 hrs. (COPS standard) = 2.5 FTEs

So by saving 1.66 FTEs with the tag checks and 2.5 FTEs with the reports, the department 

projects a total redeployment of 4.1 FTEs, which is above the minimum required and the 

department receives the grant. 

Redeployment Tracking Plan 

The next task for the Neely County Sheriff's Department is to develop a redeployment 

tracking plan for its MORE grant. The agency begins its redeployment tracking plan with a 

short summary of the project and how it will save time for officers within the agency: 

“The Neely County Sheriff's Department has been awarded a COPS MORE 

grant for 10 mobile data computers. These mobile data computers will be used as 

part of a pilot project to assess the effectiveness of automated field reporting in 

this agency. We believe that this new technology will allow patrol officers to 

perform quicker records checks and that it will make our reporting process more 

efficient. Through the assistance of the grant-funded technology, officers will be 

able to conduct their own records checks without going through dispatch. The 

field reporting system will reduce the need to enter duplicate information for 

accident and incident reports and will save officer travel time by allowing patrol 

officers to electronically transmit their reports to their supervisor.” 

The next part of the plan explains the method that the Neely County Sheriff's Department 

will use to track the time savings from its grant-funded technology: 

“The Neely County Sheriff's Department will track the time savings from 

the grant-funded mobile data computers by comparing the survey results of 

the officers using the new equipment to the survey results (baseline) of the 

patrol officers writing reports prior to the implementation of the grant 

technology. For one week during each quarter, the 20 officers using the 

mobile data computers will track the number of records checks and reports 

that they write per day and how long these activities take them. Prior to the 

grant award, the Sheriff's Department completed log sheets which 

demonstrated the time necessary to complete various checks and reports. 

The responses will be compared to determine the amount of time savings 

produced by the new technology.” 

The final part of the redeployment tracking plan includes an explanation of how the time 

saved through this grant will allow this agency to enhance its community policing efforts: 

Grant Monitoring Standards for Hiring and Redeployment 70 

Revised July 2001 
“The officers using the computers will devote approximately one hour of their 

time savings per day to problem-solving projects. During this time, the officers 

will contact community residents to identify community concerns and will 

work with community and city agencies to proactively address the causes of 

these concerns. The officers will respond to a minimal number of calls for 

service during this time.” 

Implementing the Redeployment Tracking Plan 

The Neely County Sheriff's Department begins to implement its redeployment tracking 

plan once the grant-funded technology has been purchased and becomes fully operational. 

For one week during each quarter of the one-year redeployment tracking period, the 

agency requires officers to complete daily logs tracking how many reports and records 

checks are performed by officers and how long these activities take. These logs are 

completed by the 20 officers using the mobile data computers and compared to the time 

survey completed prior to the implementation of the technology. The results from the logs 

are used to form projections for time savings over a one-year period. 

Group One: 20 officers prior to technology implementation 

Week 1 Week 2 Week 3 Week 4 Overall 

Averages 

# Shifts 100 110 120 105 

Total hours report 

writing time 

400 312 450 400 

Average hours 

writing reports 

per shift 

4.00 3.12 3.75 3.80 3.67 hours 

Total hours for 

records checks 

180 190 220 210 

Average hours 

performing 

records checks 

per shift 

1.8 1.7 1.8 2.0 1.8 hours 

Grant Monitoring Standards for Hiring and Redeployment 71 

Revised July 2001 
Group Two: 20 officers with mobile data computers 

Week 1 Week 2 Week 3 Week 4 Overall 

Averages 

# Shifts 100 110 120 105 

Total hours report writing 

time 

306 312 400 320 

Average hours writing 

reports per shift 

3.00 3.12 3.33 3.05 3.13 hours 

Total hours for records 

checks 

150 200 180 130 

Average hours performing 

records checks per shift 

1.5 1.8 1.5 1.2 1.5 hours 

Group One: 3.67 hrs. report writing per shift + 1.8 hrs. performing 

records checks per shifts = 5.47 hrs. 

Group Two: 3.13 hrs. report writing per shift + 1.5 hrs. performing 

records checks per shifts = 4.63 hrs. 

Time savings = 5.47 hrs. for officers without technology 

– 4.63 hrs. for officers with technology = 0.84 hrs saved per shift 

0.84 hrs. per shift x 20 officers x 228 shifts 

(COPS Office standard) = 3,830 hrs. 

3,830 hrs./1,824 hrs. (COPS Office standard) = 2.1 FTEs saved 

In this case, the grantee demonstrated a time savings of 2.1 full-time equivalents. While its 

projected/actual redeployment fell short of the 3.03 FTE required redeployment for the 

grant, the grantee could document other unanticipated time savings or other types of

benefits which may have occurred as a result of the project to evaluate the project's

effectiveness.

EXAMPLE 2: REDEPLOYMENT BY WEEK 

The Snoutsville Police Department applies for a MORE grant to purchase a CAD/RMS 

system and 30 laptops. Currently, the department uses radio dispatch and all reports are 

done by hand. The department estimates that each of the 40 patrol officers currently spends 

about 15 hours per week writing reports and driving them back to the station for approval. 

If the department receives the MORE grant, they estimate that each officer will save 

approximately 7.5 hours per week. The cost of the system is $230,000. To determine their 

required level of redeployment, the department would use the following formula that was 

laid out in the Cost Effectiveness Worksheet portion of the grant application. 

Grant Monitoring Standards for Hiring and Redeployment 72 

Revised July 2001 
Required Redeployment 

Line 1 Entry level salary of SWORN police officer (as of Jan. 1, 1998) 1. $ 36,000 

Line 2 Fringe benefits of SWORN police officer (as of Jan. 1, 1998) 2. $ 6,000 

Line 3 Add lines 1 and 2 3. $ 42,000 

Line 4 Multiply line 3 by .75 4. $ 31,500 

Line 5 Enter figure on line 4 or $25,000, whichever is less 5. $ 25,000 

Line 6 Total cost of item, system, or group of like items (100%) 6. $ 230,000 

Line 7 Federal amount requested. Can be no more than 75% of total 7. $ 172,500 

item cost (line 6) 

Line 8 Divide line 7 by line 5 8. 6.9 FTEs 

Projected/Actual Redeployment 

The formula used to calculate the projected actual redeployment for this grant would be: 

7.5 hrs. x 40 officers x 52 weeks = 15,600 hrs. per yr. 

15,600 hrs. / 1,824 hrs. (COPS standard) = 8.6 FTEs 

The department exceeds the required redeployment level and is awarded the MORE grant. 

Redeployment Tracking Plan 

The Snoutsville Police Department must now come up with a plan to track redeployment 

once their system becomes operational. The agency begins its redeployment tracking plan 

with a short summary of the project and how it will save time for officers within the agency. 

“The Snoutsville Police Department was awarded a grant to purchase and 

implement a new CAD/RMS system and MDTs to make our communications and 

report writing systems more efficient and effective. Prior to the implementation of 

the grant, the department estimates that each officer spends an average of 15 

hours per week writing reports and driving them back to the station for 

processing. Through the use of our new CAD/RMS system and MDTs, we 

estimated that we could cut this time in half.” 

The next part of the plan is an explanation of the method that the Snoutsville Police 

Department will use to track the time savings realized through the use of the funded 

equipment. 

“In order to track the time savings that officers will realize under this grant, we 

have issued log sheets to each officer and asked them to log in the time that is 

spent entering reports into the laptop and sending them to headquarters through 

wireless transfer. On a weekly basis, we will use a sample based on the reports of 

8 of the officers to determine the average amount of time that each officer saves 

as a result of the implementation of the CAD/RMS and MDTs.” 

Finally, the department describes how the time savings they realize will enhance its 

community policing efforts. 

Grant Monitoring Standards for Hiring and Redeployment 73 

Revised July 2001 
“With the time saved through the use of the grant-funded equipment, officers 

will attend community meetings with community and business leaders. The 

department will also begin a program to target high crime areas through 

increased foot/bike patrols.” 

Implementing the Tracking Plan 

The department implements the grant, and each officer submits a time log at the end of the 

week showing time savings that is achieved as a result of the grant. The log sheets are then 

totaled for each officer and entered into a spreadsheet tracking the time savings that each 

officer realizes. Because tracking the time savings for 40 officers is very time consuming, 

the department uses a sample of 8 officers who work varying shifts to determine time 

savings across the department. A sample of the spreadsheet that they use to track the hours 

saved follows: 

Officer Sun Mon Tues Wed Thurs Fri Sat Total 

Dame 1.25 1.75 1.5 1 2 7.5 

Chapman 1.5 1.5 2 1 1.25 7.25 

Neely 1.5 1.5 1.25 1.75 2 8.0 

Mehring 1.75 1.75 2 1.5 1 8.0 

Bezdikian 1 1.75 1.5 2 1.5 7.75 

Clark 2 1.5 1.25 1.25 1.5 7.5 

Scrivner 1.5 1 2 1.25 1.25 7.0 

Gorniak 2 1.75 1.5 1.5 1.25 8.0 

Total 7.25 10.0 7.5 9.25 11.5 8.25 7.25 61.0 

The department is able to tabulate on a weekly basis the time savings that accrues over the 

course of the grant. When the COPS Count Operators call at the end of the first 3 months 

of fully operational status, the department reports that, on average (based on the sample), 

officers are spending 7.6 hours per week writing reports. This is a time savings of 7.4 

hours per week. They use the following formula to determine their progress after 12 

weeks: 

7.4 hrs. per officer x 12 weeks x 40 officers = 3,552 hrs. saved 

3,552 hrs. /1,824 hrs. = 1.9 FTEs saved over 12 weeks. 

If the department remains on track with this level of time savings, they will achieve a total 

time savings over a period of 1 year of 7.6 FTEs. Although this is slightly less time savings 

than they originally projected, it still exceeds the required level of redeployment for the 

grant. 

Grant Monitoring Standards for Hiring and Redeployment 74 

Revised July 2001 
After the award, CAD/RMS system has been implemented, the department notices that its 

four (4) criminal investigators are also experiencing some unanticipated time savings as a 

result of the grant. Since the Department now uses a records management system, the four 

detectives each save two hours per week because they no longer need to review lengthy 

handwritten reports that were poorly filed in the past. Now, the detectives have all of the 

available information on their computers, which is much faster than the old process. The 

department decides to track this time savings as well since it will help them in exceeding 

their required redeployment level. Since each detective is saving an average of two hours 

per week, the following time savings can be anticipated over the course of the year (this 

should be tracked incrementally as it accrues): 

2 hrs. per week x 4 officers x 52 weeks = 416 hrs. 

416 hrs. / 1,824 hrs. (COPS Standard) = .2 FTEs 

If the time savings the department is currently achieving stays on track, they can expect to 

realize redeployment of 7.8 FTEs over the course of one year. 

EXAMPLE 3: REDEPLOYMENT BY REPORT 

The Sunshine Police Department applies for a MORE grant to purchase 12 laptop 

computers with supporting hardware and report writing software. Currently, all officers 

hand-write their reports. The department has a sworn force strength of 25 officers with four 

patrol officers assigned to each shift. Last year, the department generated a total of 28,763 

reports. Each officer currently spends about 40 minutes writing each report and averages 

five reports per shift. If the department receives the MORE grant, they estimate that each 

officer will save approximately 20 minutes per report, cutting the time it takes to complete 

the reports in half. The cost of the laptops with supporting hardware/software is $60,000. 

To determine required level of redeployment, the department uses the following formula 

which is laid out in the Cost Effectiveness Worksheet portion of the grant application. 

Required Redeployment 

Line 1 Entry level salary of SWORN police officer (as of Jan. 1, 1998) 1. $ 23,000 

Line 2 Fringe benefits of SWORN police officer (as of Jan. 1, 1998) 2. $ 3,000 

Line 3 Add lines 1 and 2 3. $ 26,000 

Line 4 Multiply line 3 by .75 4. $ 19,500 

Line 5 Enter figure on line 4 or $25,000, whichever is less 5. $ 19,500 

Line 6 Total cost of item, system, or group of like items (100%) 6. $ 60,000 

Line 7 Federal amount requested. Can be no more than 75% of total 7. $ 45,500 

item cost (line 6) 

Line 8 Divide line 7 by line 5 8. 2.3 FTEs 

Grant Monitoring Standards for Hiring and Redeployment 75 

Revised July 2001 
Projected/Actual Redeployment 

Using the number of reports the department generated in the previous year, the department 

uses the following formula to calculate the projected actual redeployment for this grant; 

28,763 reports per yr. x 20 min. per report = 575,260 min. 

575,260 min./ 60 min. = 9,587 hrs. saved 

9,587 hrs. saved / 1,824 hrs. (Cops standard) = 5.3 FTEs 

The department exceeds the required redeployment level and is awarded the MORE grant. 

Redeployment Tracking 

The Sunshine Police Department must now develop a plan to track redeployment once 

their system becomes operational. The agency begins its redeployment tracking plan with a 

short summary of the project and how it will save time for officers within the agency. 

“The Sunshine Police Department was awarded a grant to purchase 12 laptops 

with supporting hardware and report writing software to make writing reports 

more efficient. Prior to the implementation of the grant, the department estimated 

that each officer spent about 40 minutes writing each report. Through the use of 

the new laptops and report writing software, we estimate that we will cut this 

time in half.” 

The department then goes on to explain what method they will use to track the time 

savings realized through the use of the laptops and report writing software. 

“In order to track the time savings that officers will realize under this grant, we 

have issued log sheets to each officer and asked them to log in the time that is 

spent entering reports into the laptop and sending them to headquarters through 

wireless transfer. On a monthly basis we will take a sample of the time logs for 

12 officers on varying shifts to determine the average amount of time officers 

spend writing a report after the awarded equipment becomes operational.” 

The final part of the redeployment tracking plan includes an explanation of how the time 

saved through this grant will allow the department to enhance its community policing efforts. 

“With the time saved through the use of the grant-funded equipment, the 

department will begin a school resource officer program in the high school. 

Additionally, we hope to begin conducting a citizen survey on crime and 

institute several neighborhood watch programs.” 

Implementing the Redeployment Tracking Plan 

The department implements the grant and each officer submits a time log each shift 

showing time savings that is achieved as a result of the grant. The log sheets are then 

totaled for each officer and entered into a spreadsheet tracking the time savings that each 

officer realizes. Because tracking the time savings for 25 officers can be time consuming, 

the department uses a sample of 12 officers who work varying shifts to determine time 

Grant Monitoring Standards for Hiring and Redeployment 76 

Revised July 2001 
savings for the entire department. Using the log sheets, the department is able to create the 

following spreadsheet to determine how long it takes officers to do a report on average. A 

sample of the spreadsheet that they use to track the hours saved follows: 

Officer Reports per Shift Time spent writing reports 

Dame 8 180 minutes (3 hours) 

Chapman 5 135 minutes (2.25 hours) 

Neely 3 60 minutes (1 hour) 

Mehring 6 150 minutes (2.5 hours) 

Bezdikian 6 150 minutes (2.5 hours) 

Clark 2 30 minutes (.5 hours) 

Scrivner 5 120 minutes (2 hours) 

Gorniak 7 225 minutes (3.75 hours) 

Dodge 6 150 minutes (2.5 hours) 

Webb 8 180 minutes (3 hours) 

Phillips 6 150 minutes (2.5 hours) 

Alford 4 120 minutes (2 hours) 

TOTAL 66 1,650 minutes (27.5 hours) 

Three months after the equipment becomes fully operational, the department is able to 

tabulate on a daily basis the time savings that accrues over the course of the grant. Based 

on the sample, the department finds that, on average, each officer spends 25 minutes per 

report. This results in a time savings of 15 minutes per report. 

1,650 min. / 66 reports = 25 min. per report 

40 min. per report (prior to grant) - 25 min. per report (post grant) = 15 min. in savings per 

report 

Over the three-month period, the department has generated 7,230 reports. Therefore, their 

time savings, to date, can be calculated as follows: 

7,230 reports x 15 min. per report = 108,450 min. 

108,450 min. /60 min. = 1,807 hrs. saved 

1,807 hrs. saved / 1,824 hrs. (COPS standard) = 1 FTE 

If the department continues to see this level of time savings for the remainder of the 12 

months, they can expect to realize redeployment of 4 FTE. Although this is slightly less 

time savings than they originally estimated, it still exceeds the required level of 

redeployment for the grant. After the laptops have been implemented, the department 

notices that there is additional time savings that occurs as a result of the grant, including: 

• 	 electronically transferring reports to supervisor instead of driving reports to 

headquarters, and 

• electronic revisions after review instead of re-writing reports. 

Grant Monitoring Standards for Hiring and Redeployment 77 

Revised July 2001 
EXAMPLE 4: REDEPLOYMENT BY ARREST 

Two years ago, arrest processing in the Gotham City Police Department meant transporting 

a prisoner to a central location in downtown Gotham, manually fingerprinting and 

capturing arrest data, taking the arrestee's photograph, and then transporting the prisoner to 

court for arraignment. The backup of prisoners caused delays and officers have, on 

occasion, spent as much as 10 hours processing an arrest! The arrest processing procedures 

consisted of manually fingerprinting and photographing a suspect, entering the suspect's 

information into the department's centralized booking system, and then transporting the 

prisoner to the District Attorney to complete the booking process. On average, Gotham 

police officers spent 8 hours per arrest completing the procedures required to process an 

arrested suspect. 

The Gotham City Police Department applied for a MORE grant to purchase an arrest 

processing system, including video conferencing, Live Scan fingerprinting, photo imaging, 

warrant checks, and automated arrest data processing. 

Line 1 Entry level salary of SWORN police officer 1. $ 30,000 

Line 2 Fringe benefits of SWORN police officer 2. $ 8,500 

Line 3 Add lines 1 and 2 3. $ 38,500 

Line 4 Multiply line 3 by .75 4. $ 28,875 

Line 5 Enter figure on line 4 or $25,000, whichever is less 5. $ 25,000 

Line 6 Total cost of item, system, or group of like items (100%) 6. $ 10,000,000 

Line 7 Federal amount requested. Can be no more than 75% of total 7. $ 7,500,000 

item cost (line 6) 

Line 8 Divide line 7 by line 5 8. 300 FTEs 

Projected/Actual Redeployment 

The formula used to calculate the projected or actual redeployment for this grant would be: 

Time savings per arrest 

Travel time to central booking 

Report writing and mug shots 

Pro-rated travel time to fax & re-fingerprint 

rejected prints 

Travel time for affidavit issuance 

Total Time Savings 

1.5 hours 

.5 hours 

.5 hours 

1.5 hours 

4.0 hours 

136,800 arrests per year (September 1998-September 1999) 

136,800 x 4 hrs. saved = 547,200 hrs. saved 

547,200 hrs. saved / 1,824 hrs. = 300 FTEs redeployed 

Grant Monitoring Standards for Hiring and Redeployment 78 

Revised July 2001 
With the help of a COPS MORE grant, the Gotham City Police Department has now 

completely decentralized its arrest processing system. The GCPD's arrest processing 

system is now composed of five major automated components, including Live Scan 

fingerprinting, photo imaging, warrant checks, automated arrest data processing, and video 

conferencing. The Live Scan units, photo imaging, video conferencing equipment, and the 

upgraded on-line booking system were purchased in 1997 and were completely operational 

in September 1998. Operationally, Live Scan has eliminated the need to manually ink and 

record an arrestee’s fingerprints. It generates computerized files of an individual’s prints 

by guiding the user through the process and rejecting poor quality prints as they are 

generated, eliminating “bad prints” and the need for reprinting suspects. The prints are then 

transmitted to the Department of Criminal Justice Services at the State capital for further 

analysis, and to central records for storage. The photo imaging and warrant system takes, 

stores, and retrieves images for each of the city's five prisoner holding facilities. All 

precincts throughout the city have the ability to display and print the photos. Video 

conferencing is used in each of the precincts, eliminating the need to travel to the District 

Attorney’s office to complete the arrest affidavit. 

Redeployment Summary 

With the installation of the automated components that comprise the department's 

decentralized booking function, it now takes approximately four hours to process an arrest. 

Before the decentralization afforded by the MORE technology, officers had to transport 

arrestees to a centralized booking facility for arrest processing. After the implementation of 

the technology, officers no longer spend an inordinate amount of time travelling 

(sometimes in city or rush hour traffic) to and from the precinct to the centralized booking 

facility. Based on calculated averages of a sample of officers across all the affected 

precincts, one and one-half (11⁄2) hours per arrest are saved through the elimination of 

travel time to the central booking facility. 

Prior to the implementation of the on-line booking system, officers were required to 

complete multiple written reports that often captured duplicative information. Additionally, 

the processing time for mug shot photographs added time to the booking process. With the 

implementation of an on-line booking system and digital mug shot processing, the time to 

process an arrest has been reduced by 30 minutes per arrest by eliminating duplicative 

paperwork and reducing the time spent taking and developing photographs. 

Prior to Live Scan, three fingerprint cards were inked and then faxed to the State capital. 

Some precincts did not have a fax machine that would provide the level of graphic detail 

required to transmit the prints, also resulting in travel time that is no longer needed. If 

prints sent to the State capital were rejected, the arresting officer was required to reprint the 

arrestee and go through this process again. If an arrestee had been moved to a different 

holding facility, time was spent tracking the arrestee down. Based on the proportion of 

prints that required travel to an upgraded fax machine (approximately one-fifth (1/5) of all 

arrestee prints), and the proportion of prints that required reprinting due to rejection at the 

Grant Monitoring Standards for Hiring and Redeployment 79 

Revised July 2001 
State capital (approximately one-fourth (1⁄4) of all arrestee prints), an average of 30 

minutes per arrest is saved through this automated booking technology. 

The last step in the booking process involved transporting arrestees to the District 

Attorney's Office for issuing arrest affidavits. The video conferencing equipment installed 

as part of the upgraded arrest processing function has virtually eliminated all travel 

between the precinct and DA's office for issuing arrest affidavits as all arrestee questioning 

is now conducted in the local precinct via video teleconferencing. The video 

teleconferencing component of the arrest processing system has yielded an average officer 

time savings of 11⁄2 hours per arrest. 

With the implementation of Live Scan, along with the other components of the system, an 

offender is printed and photographed automatically, data is entered directly into the booking 

system from the precinct (paperless reporting), and the arrest affidavit is completed via 

video-teleconferencing. Redeployment occurs by eliminating the need to perform routine 

multiple prints, waiting time for receiving confirmation from the State capital, in reprinting 

rejected prints, taking manual photographs, and most importantly, by reducing travel time to 

and from the precinct to the central booking facility and the District Attorney's Office. In 

sum, the new technology has permitted the Gotham City Police Department to save police 

officer arrest processing time citywide. 

Calculation 

Redeployment Requirement = 300 FTEs, based on an awarded amount of $7,500,000 

($7,500,000/$25,000 maximum allowable per FTE = 300 FTEs) 

Time savings per arrest 

Travel time to central booking 

Report writing and mug shots 

Pro-rated travel time to fax & re-fingerprint 

rejected prints 

Travel time for affidavit issuance 

Total Time Savings 

1.5 hours 

.5 hours 

.5 hours 

1.5 hours 

4.0 hours 

136,800 arrests per year (September 1998-September 1999) 

136,800 x 4 hrs. saved = 547,200 hrs. saved 

547,200 hrs. saved / 1,824 hrs. = 300 FTEs redeployed 

300 FTEs redeployed into community policing since the equipment became fully 

operational in September 1998 

Unanticipated Time Savings 

Because both mug shots and fingerprints are now stored electronically in a centralized 

citywide database, detectives who formerly used to scour through paper files for hours on 

end can now search the fingerprint and mug shot archives during the investigative process. 

Based on a survey of the detectives conducted in the detective bureau, detectives are now 

saving an average of 1 hour per search. 

Grant Monitoring Standards for Hiring and Redeployment 80 

Revised July 2001 
Time savings of 1 hour per search 

1 hour per either fingerprint or mug shot search x 300,000 searches per year citywide 

(September 1998-September 1999) = 300,000 hrs. saved 

300,000 hrs. saved / 1,824 hrs. 

= 164.5 FTEs of unanticipated time savings for detectives 

TOTAL FTEs Redeployed: 300 + 164.5 = 464.5 

Redeployment Tracking 

The Gotham City Police Department must now come up with a plan to track redeployment 

once their system becomes operational. Using the guidelines provided in the 

Redeployment Tracking Q&A Fact Sheet provided by the COPS Office, the department 

prepares the following tracking plan. 

“The Gotham City Police Department was awarded a grant to purchase and 

implement a new arrest processing system to significantly reduce the time spent 

by police officers processing arrestees. Prior to the implementation of the new 

system, the department documented the time spent by randomly sampling 25 

officers (across the department) and tracking their time during each phase of the 

arrest process, which includes: the transport time, fingerprint processing time, 

time spent completing several required paper reports, and the time spent in the 

issuance of arrest affidavits by the prosecuting attorney (includes transport and 

holding time). This entire process averaged 8 hours across the 25 sampled 

arresting officers. With the installation of the multiple component arrest 

processing system, we estimated that this time would be reduced by 50 percent. 

In order to validate these estimates, we waited until all components of the arrest 

processing system were fully operational, which was approximately 18 months 

after receiving the grant award. We then ran the same time tests for each of the 

components of the arrest process on another sample of 25 arresting officers on a 

quarterly basis for one year after becoming fully operational with the arrest 

processing and booking system.” 

The quarterly time test employed by the Gotham City P.D. takes into consideration the 

potential improvements in efficiencies to be experienced by the members of the 

department. Simply put, as officers become familiarized with the automation and the new 

arrest processing system, the time saved could presumably increase. By sampling 25 

officers each quarter, and tracking/documenting their activities during the arrest process, 

the Gotham City P.D. is in a good position to then come up with a reasonable average for 

the number of hours saved per arrest, which could then be applied to the total number of 

arrests per year. 

Grant Monitoring Standards for Hiring and Redeployment 81 

Revised July 2001 
The following is the formula used to determine the actual time savings department-wide 

(formula would need to be applied quarterly, at minimum, with each subsequent sample 

time test period): 

Total hours of time saved per arrest = 

+ Total of transportation time saved 

+ Booking/mug-shots 

+ Fingerprinting 

+ Issuance of arrest affidavits 

Total time saved x number of arrests for the quarter 

= number of hours saved/COPS standard (1,824 hrs) 

= number of FTEs redeployed 

In this case, assuming they met their projected levels, they would save 4 hours per arrest x 

34,200 arrests in the quarter, resulting in 136,800 hours saved, or 75 FTEs redeployed, in 

the quarter. This process would need to be repeated until the full year is complete, which 

would then yield the total time savings/redeployment that would be reported to the COPS 

Office. 

EXAMPLE 5: TASK-ORIENTED CIVILIAN REDEPLOYMENT 

The Wickersville Police Department applies for a MORE grant to hire 4 civilian Police 

Aides to assist with answering non-emergency calls for service. Currently, the department 

estimates that each officer spends about 3 hours per shift answering non-emergency calls 

for service. The department has a sworn force strength of 34 officers with 6 patrol officers 

assigned to each shift. If the department receives the MORE grant, they estimate that each 

officer will save approximately 1.5 hours per shift as a result of the civilian hires. The cost 

of hiring these 4 civilians is $100,000 including salary and benefits. To determine their 

required level of redeployment, the department would use the following formula that was 

laid out in the Cost Effectiveness Worksheet portion of the grant application. 

Line 1 Entry level salary of SWORN police officer (as of Jan. 1, 1998) 1. $ 28,500 

Line 2 Fringe benefits of SWORN police officer (as of Jan. 1, 1998) 2. $ 6,800 

Line 3 Add lines 1 and 2 3. $ 35,300 

Line 4 Multiply line 3 by .75 4. $ 26,475 

Line 5 Enter figure on line 4 or $25,000, whichever is less 5. $ 25,000 

Line 6 Total cost of item, system, or group of like items (100%) 6. $ 100,000 

Line 7 Federal amount requested. Can be no more than 75% of total 7. $ 75,000 

item cost (line 6) 

Line 8 Divide line 7 by line 5 8. 3.0 FTEs 

Grant Monitoring Standards for Hiring and Redeployment 82 

Revised July 2001 
Projected/Actual Redeployment 

Using the estimated number of hours that these civilians could save each officer per shift, the 

department uses the following formula to calculate the projected actual redeployment for this grant: 

1.5 hrs. per officer per shift x 34 officers x 228 shifts = 11,628 hrs. saved 

11,628 / 1,824 hrs = 6.4 FTEs 

The department exceeds the required redeployment level and is awarded the MORE grant. 

Redeployment Tracking 

The Wickersville Police Department must now come up with a plan to track redeployment 

once the civilian positions have all been hired and received the necessary training. Using 

the guidelines provided in the Redeployment Tracking Q&A Fact Sheet provided by the 

COPS Office, the department prepares the following tracking plan. The first portion 

provides a short summary of the project. 

“The Wickersville Police Department was awarded a grant to hire 4 civilian 

Police Aides to assist the department in handling non-emergency calls for 

service. Prior to the implementation of the grant, the department estimated that 

each officer spent about three hours per shift answering these types of calls for 

service. By hiring the civilian Police Aides, we still estimate that we have cut 

this time in half.” 

Next, the department explains the method they plan to use to track the time savings 

resulting from the hiring of the civilian police aides. 

“In order to track the time savings that officers will realize under this grant, 

we have issued log sheets to each officer and asked them to log in the time 

that they spend each shift on non-emergency calls for service. On a monthly 

basis, we will take a sample of the sheets for 10 officers on varying shifts to 

determine the average amount of time per shift that they spend answering nonemergency calls for service after the civilian police aides are hired and 

trained.” 

Finally, the department details the community policing activities that they plan to 

implement as a result of the time saved as a result of the grant. 

“With the time saved through the hiring of these civilians, the department will 

set up a “hot spot” analysis program to target high crime areas.” 

Implementing the Redeployment Tracking Plan 

The department implements the grant, and each officer submits a time log each shift 

showing time savings that is achieved as a result of the grant. The log sheets are then 

totaled for each officer and entered into a spreadsheet tracking the time savings that each 

officer realizes. Once the civilians are hired, the department finds that only 24 officers will 

Grant Monitoring Standards for Hiring and Redeployment 83 

Revised July 2001 
benefit from them because they will not be working the 3rd shift. Because tracking the 

time savings for 24 officers is very time consuming, the department uses a sample of 10 

officers who work varying shifts to determine time savings across the department. Using 

the log sheets, the department is able to create the following spreadsheet to determine how 

long it takes officers to do a report on average. A sample of the spreadsheet that they use to 

track the hours saved follows: 

Officer # of nonemergency calls Hours spent on non-emergency 

calls 

Hoff 3 2 

Townsend 1 1 

Varano 2 1.5 

Smith 2 2.5 

Curtis 3 3 

Morgan 1 1 

Shay 4 3 

Tucker 3 2 

Mehring 2 1.5 

Phillips 3 2.5 

Total 24 20 

Three months after the civilians are hired, the department is able to tabulate on a daily 

basis the time savings that accrues over the course of the grant. The department finds that, 

on average (based on the sample), each officer is spending two hours per shift answering 

non-emergency calls for service. This results in an average of one hour of time savings per 

officer per shift. The department calculates the time savings to date as follows: 

1 hr. x 24 Officers x 57 shifts (1/4 of 228) = 1,368 hrs. saved 

1,368 hrs. / 1,824 hrs. (COPS standard) = .8 FTEs 

If the department continues to see this level of time savings for the remainder of the 12 

months, they can expect to realize redeployment of 3.2 FTEs. This is less time savings than 

what the department had originally projected, but it still exceeds the required level of 

redeployment. The department attributes the reduced savings to the fact that officers on the 

late shift do not have the benefit of the civilians who only work the first two shifts of the 

day. 

Grant Monitoring Standards for Hiring and Redeployment 84 

Revised July 2001 
§

Appendix E: Reference Material 

U.S. Department of Justice Grant Policies 

Financial Guide: U.S. Department of Justice, Office of Justice Programs, Office of the 

Comptroller; Current Edition. 

Universal Hiring Program Grant Owner's Manual: U.S. Department of Justice, 

Office of Community Oriented Policing Services 

COPS MORE '96 Grant Owner's Manual: U.S. Department of Justice, Office of 

Community Oriented Policing Services 

COPS MORE '98 Grant Owner's Manual: U.S. Department of Justice, Office of 

Community Oriented Policing Services 

COPS MORE 2000 Grant Owner's Manual: U.S. Department of Justice, Office of 

Community Oriented Policing Services 

Statutes 

Public Safety Partnership and Community Policing Act of 1994; 

42 USC §3796dd-1 (c) 

Administrative Requirements: 

OMB Circular A-129, “Managing Federal Credit Programs” 

OMB Circular A-102, “Grants and Cooperative Agreements with State and Local 

Governments” 

OMB Circular A-110, “Uniform Administrative Requirements for Grants and 

Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit 

Organizations” 

Cost Principles: 

OMB Circular A-21, “Cost Principles for Educational Institutions” 

OMB Circular A-87, “Cost Principles for State, Local, and Indian Tribal 

Governments” 

OMB Circular A-122, “Cost Principles for Non-Profit Organizations” 

Grant Monitoring Standards for Hiring and Redeployment 85 

Revised July 2001 
Audit Requirements: 

OMB Circular A-133, “Audits of States, Local Governments and Nonprofit 

Institutions” 

Inspector General Act of 1978, as amended (Title 5 U.S.C. Appendix 3) 

Code of Federal Regulations 

4 CFR Parts 101-105, Department of Justice/General Accounting Office, “Joint 

Federal Claims Collections Standards” 

5 CFR Part 1320, “Controlling the Paperwork Burden on the Public” 

5 CFR Part 151, “Political Activities of State and Local Officials or Employees” 

28 CFR Part 23, “Criminal Intelligence Systems Operating Policies” 

28 CFR Part 42, “Nondiscrimination; Equal Employment Opportunity; Policies 

and Procedures” 

28 CFR Part 66, “Uniform Administrative Requirements for Grants and 

Cooperative Agreements with State and Local Units of Government” 

28 CFR Part 67, “Governmentwide Requirements for Drug-Free Workplaces 

(Grants)” 

28 CFR Part 69, “Governmentwide New Restrictions on Lobbying” 

31 CFR Part 205, “Treasury Department Regulations Implementing for Cash 

Management Improvement Act of 1990” 

Executive Order 1254 , “Non-Procurement Debarments and Suspension” 

Executive Order 12372, 28 CFR Part 30, “Intergovernmental Review of Federal 

Programs” 

Executive Order 1229,1 “Regulations” 

Grant Monitoring Standards for Hiring and Redeployment 86 

Revised July 2001