2015 COPS Office Tribal Resources 

Grant Program (TRGP) 

Grant Owner’s Manual

www.cops.usdoj.gov

U.S. Department of Justice, Office of Community Oriented Policing Services
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

i

2015 COPS Office Tribal Resources Grant Program

Grant Owner’s Manual

Coordinated Tribal Assistance Solicitation Purpose Area #1: Public Safety and Community Policing

This manual was created to assist COPS Office Tribal Resources Grant Program (TRGP) grantees with the 

administrative and financial matters associated with their grant.

For more information about your TRGP grant, please contact your COPS Office Grant Program Specialist (GPS). 

If you do not know the name or telephone number of your COPS Office GPS, please contact the COPS Office 

Response Center at 800-421-6770.

U.S. Department of Justice

Office of Community Oriented Policing Services

145 N Street NE

Washington, DC 20530

Visit the COPS Office online: www.cops.usdoj.gov

Published 2015
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

ii

Contents

Getting Started .

I. Grant Acceptance, Terms, and Conditions .

The award document .

Grant conditions .

What are the specific rules regarding termination of grant funding? .

Accepting the grant award .

II. Procurement Process (for TRGP-Equipment/Training grants only) . 

III. Accessing Grant Funds . 

Payment method .

Setting up your account .

Additional payment questions .

Matching funds .

IV. Financial Record Maintenance . 

Accounting systems and records .

V. Federal Audit Requirements . 

Requirements and audits .

Typical audit findings .

VI. Reports . 

Federal Financial Reports .

Program Progress Reports .

Contact points to obtain technical assistance and report violations .

VII. When the Grant Period Has Ended . 

Final Federal Financial Report (SF-425) .

Final Program Progress (Closeout) Report .

Equipment disposition  .

VIII. Conclusion . 

Appendices. . . . . . ... . . ....... . . . . . . ... . . ... . . ... .... . . ... . . ... . . . . ..... ....... ..... ..... .................... 68
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

iii

Appendix A. List of source documents .

Appendix B. Assurances and Certifications .

Appendix C. Community policing defined .

Appendix D. National Institute of Justice (NIJ) bulletproof vest standards .

Appendix E. Whistleblower protection (41 U.S.C. 4712) .

Appendix F. 2 CFR Appendix II to Part 200: Contract provisions for nonfederal entity contracts under federal 

awards  .

Glossary of Terms . 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

1

Getting Started

Congratulations on receiving a grant from the U.S. Department of Justice, Office of Community Oriented 

Policing Services (COPS Office). The 2015 COPS Office Tribal Resources Grant Program (TRGP) provides 

funding directly to federally recognized tribal jurisdictions with established law enforcement agencies. TRGP 

was designed to expand the implementation of community policing and meet the most serious needs of 

law enforcement in tribal communities through a broadened comprehensive program.

In FY 2010, the U.S. Department of Justice (DOJ) issued a single Coordinated Tribal Assistance Solicitation 

(CTAS) that encompasses the department’s available tribal government-specific grant programs. CTAS 

enabled each tribe to submit a single application for available grant funding according to the tribes’ needs. 

This coordinated process allowed DOJ to review a single application from a tribe, and it allowed the DOJ 

grant-making components to coordinate in making award decisions to address these public safety needs on 

a more comprehensive basis.

The 2015 TRGP, which was also CTAS Purpose Area #1: Public Safety and Community Policing, consists of 

two types of grants. The TRGP-Hiring grants are for entry-level salaries and benefits for newly hired or rehired 

career law enforcement officers, and the TRGP-Equipment/Training (TRGP-E/T) grants provide funding for 

background investigations, training, uniforms, basic issue equipment, technology, and vehicles for tribal law 

enforcement agencies.

To support community policing, particularly the development of partnerships and problem solving, 2015 

TRGP grantees may be offered training and technical assistance by COPS Office training and technical 

assistance providers. Trainings will assist grantees in the advancement of community policing and may 

address specific public safety issues facing tribal communities. The COPS Office or its technical assistance 

providers will notify TRGP grantees about training and technical assistance opportunities. Grantees are 

encouraged to participate in the training and technical assistance opportunities to further their public safety 

efforts.

This COPS Office TRGP Grant Owner’s Manual will assist your agency with the administrative and financial 

matters associated with managing your grant. It was developed by the COPS Office to ensure that all 

COPS TRGP grantees clearly understand and meet the requirements of their grant. Please review this 

manual carefully, because a failure to follow grant requirements may result in serious penalties. Please 

do not hesitate to call the COPS Office Response Center at 800-421-6770 if you need assistance with the 

implementation of your grant.

Thank you for providing us with the opportunity to work in partnership with your community.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

2

I. Grant Acceptance, Terms, and Conditions

To officially accept and begin your COPS Office Tribal Resources Grant Program grant, your agency must 

access www.cops.usdoj.gov and select the “Account Access” link in the upper right corner to log in, review, 

and electronically sign the award document (including grant terms and conditions) and, if applicable, 

the special award conditions or high risk conditions within 90 days of the date shown on the award 

congratulatory letter.

Your agency will not be able to draw down grant funds until the COPS Office receives your signed award 

document. For more information on drawing down grant funds, please see section III, “Accessing Grant 

Funds,” on page 56 of this document.

The award document

The award document is the document indicating your official grant funding amount, the number of officer 

positions awarded, the type of positions awarded, the grant number, the grant conditions, and the award 

start and end dates.

The award document is pre-printed with your agency’s law enforcement and government executives’ 

names. If this information is incorrect or has changed, please update your “Agency Contacts” online at 

www.cops.usdoj.gov through the “Account Access” link. If the law enforcement or government official has 

changed since the time of application, please have the current law enforcement executive or government 

executive for your agency create an account through the “Account Access” link, log in, and sign the award 

document once your agency contacts have been updated online. Once you have reviewed your award 

document, please electronically sign it and make a copy of all pages of the document for your records, along 

with all award condition pages, within 90 days of the date shown on the award congratulatory letter.

The award start date indicated on the award document means that your agency may be reimbursed for 

any allowable costs incurred on or after this date. The duration of your TRGP grant award is three years (36 

months) of funding for each position awarded.

Your grant number is in the following format: 2015-HEWX-0000 for TRGP-E/T awards and 2015-HHWX-0000 

for TRGP-Hiring grants awarded in Fiscal Year (FY) 2015. The COPS Office tracks grant information based upon 

this number. Therefore, it is important to have your agency’s grant number (or your agency’s ORI number) 

readily available when corresponding with the COPS Office.

Your originating agency identifier (ORI) number begins with your state abbreviation followed by five 

numbers or letters (e.g., VA00000). This number is assigned by the Federal Bureau of Investigation (FBI) for 

use in tracking information for the Uniform Crime Report (UCR). The COPS Office tracks programmatic grant 

information based upon this ORI number. If your agency does not have an ORI number assigned by the FBI, 

the COPS Office assigns a non-official ORI code to use as an agency identifier (in such cases, the last two 

characters will be “ZZ”). If you have any questions regarding your grant, please refer to your grant number or 

your agency’s ORI number when you contact the COPS Office.

Your Office of Justice Programs (OJP) vendor number, in most circumstances, is your agency’s nine- or 

13-digit federal tax identification number assigned to you by the Internal Revenue Service (IRS). If your OJP 

vendor number differs from your tax identification number, the OJP vendor number is only to be used for 

administrative purposes in connection with this grant program, and should not be used for IRS purposes.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

3

Grant conditions

The grant conditions are listed on your agency’s award document. By accepting this grant, you are obtaining 

federal funds from the COPS Office. As part of that agreement, your agency acknowledges that it will comply 

with these conditions (and, if applicable, additional special conditions specific to your agency). The section 

that follows describes in detail all of the award conditions, their rationales, and their implications. It also 

addresses many frequently asked questions. If you have additional questions concerning any of these grant 

conditions, please contact your COPS Office Grant Program Specialist at 800-421-6770.

In limited circumstances, your award may be subject to special conditions that prevent your agency from 

drawing down or accessing grant funds until the special conditions are satisfied as determined by the COPS 

Office. Any special conditions will be included with your award, which may be accessed at www.cops.usdoj.gov

via the “Account Access” link. However, if you have questions about the special conditions, please call your COPS 

Office Grant Program Specialist at 800-421-6770.

Reasons for grant conditions

The requirements of your grant are established within

•	 the Public Safety Partnership and Community Policing Act of 1994, which established the COPS Office;

•	 applicable rules, regulations, and policies issued by the U.S. Department of Justice, Office of 

Management and Budget (OMB), the Government Accountability Office (GAO), and the United States 

Treasury;

•	 the specific TRGP programmatic requirements established by the COPS Office.

A list of source documents for this booklet is provided in appendix A on page 70. You may request copies of 

any source reference document from:

Office of Administration, Publication Unit

New Executive Office Building

725 17th Street NW, Room G 236

Washington, DC 20503

COPS Office-specific documents may be requested directly from the COPS Office.

Review of grant conditions – Hiring grants

By signing the award document to accept this TRGP-Hiring grant, your agency agrees to abide by the 

following grant conditions:

1. Grant owner’s manual

The grantee agrees to comply with the terms and conditions in the 2015 COPS Office Tribal Resources Grant 

Program (TRGP) Owner’s Manual; COPS Office statute (42 U.S.C. §. 3796dd, et seq.); 2 C.F.R. Part 200 (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by the U.S. 

Department of Justice in 2 C.F.R. § 2800.101; 48 C.F.R. Part 31 (FAR Part 31) (Contract Cost Principles and Procedures); 

other representations made in the TRGP grant application; and all other applicable program requirements, laws, 

orders, regulations, or circulars.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

4

Why this condition:

This manual has been designed to inform you of the requirements, laws, regulations, and policies that apply 

to your grant. Your agency will be responsible for the information and rules contained in this manual and 

for implementing your grant in compliance with the applicable terms, conditions, and regulations. More 

detailed guidance regarding any particular grant requirement or your agency’s specific circumstances can 

be requested through your COPS Office Grant Program Specialist (GPS).

What you should do:

Please read the entire TRGP Grant Owner’s Manual carefully prior to signing the grant award document. If 

you have any questions, please contact your COPS Office GPS. When accepting your grant award, you should 

ensure that the proper reporting and financial systems are in place to satisfy the grant requirements.

2. Assurances and Certifications

The grantee acknowledges its agreement to comply with the Assurances and Certifications forms that were signed 

as part of its grant application.

Why this condition:

Although the COPS Office has made every effort to simplify the process of applying for and receiving grants, 

several provisions of federal law require us to seek your assurances and certification regarding certain 

matters. Most of the assurances and certifications apply to all federal grant programs.

What you should do:

Applicants to COPS Office grant programs are required to sign the Assurances and Certifications forms at 

the time of application. Signing these documents assures the COPS Office that you have read, understood, 

and accepted the grant terms and conditions outlined in the Assurances and Certifications. Your agency 

is required to keep Assurances and Certifications forms that were signed as part of its grant application. 

Please read these documents carefully, because signatures on these documents are treated as a material 

representation of fact upon which reliance will be placed when the U.S. Department of Justice determines 

whether to award the covered grant. Additional copies of the Assurances and Certifications forms are 

contained in appendix B of this manual on page 71. If you have any questions about the Assurances and 

Certifications, please contact your COPS Office GPS at 800-421-6770.

3. Allowable costs

The funding under this project is for the payment of approved costs to meet the most serious needs of law 

enforcement in tribal communities. The allowable costs for which your agency’s grant has been approved are 

limited to those listed on the Financial Clearance Memorandum (FCM), which are included in your agency’s award 

package.

The FCM specifies the amount of TRGP funds awarded to your agency. You should carefully review your FCM, which 

contains the final officer salary and fringe benefit categories and amounts for which your agency was approved. 

Please note that the salary and fringe benefit costs requested in your grant application may have been adjusted or 

removed. Your agency may only be reimbursed for the approved cost categories that are documented within the 

FCM, up to the amounts specified in the FCM. Your agency may not use TRGP grant funds for any costs that are not 

identified as allowable in the Financial Clearance Memorandum. 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

5

Only actual allowable costs incurred during the grant award period will be eligible for reimbursement and 

drawdown. If your agency experiences any cost savings over the course of the grant (for example, your grant 

application overestimated the total entry-level officer salary and fringe benefits package), your agency may not use 

that excess funding to extend the length of the grant beyond 36 months. Any funds remaining after your agency 

has drawn down for the costs of approved salaries and fringe benefits incurred for each awarded position during 

the 36-month funding period for each awarded position will be deobligated during the closeout process, and 

should not be spent by your agency.

Why this condition:

TRGP-Hiring funds may be used only to pay entry-level salaries and fringe benefits for 36 months for career 

law enforcement officers hired or rehired on or after the award start date. You may use the TRGP grant to hire 

or rehire experienced officers, but grant funding must be limited to paying your agency’s entry-level salary 

and fringe benefits; any costs higher than entry level must be paid by your agency with local funds.

TRGP-Hiring grant funding may also be used to pay the approved entry-level salaries and fringe benefits of 

newly hired officer recruits while they are in basic academy training prior to swearing them in, if it is your 

agency’s standard practice to pay recruits while in training.

What you should do:

All grantees should keep and maintain the most recent, approved version of 2015 TRGP application, which 

will contain the approved costs for this grant. Refer to your FCM for the list of approved allowable costs. 

As long as funds are spent during the grant period on the approved salaries and benefits (as applicable), 

equipment, technology, training, or other costs that were documented in your application’s budget 

summary and were approved through the issuance of the FCM, this grant condition will be satisfied.

Salaries covered by TRGP-Hiring must be based on your agency’s standard entry-level salary and fringe 

benefits package under the laws or rules that govern hiring by your agency. Salary and fringe benefits 

payments must be based on payroll records supported by time and attendance records or their equivalent. 

Examples of the types of records your agency must keep to document allowable costs are described in 

section IV on page 59 of this manual. Any additional costs above the approved entry-level salaries and 

fringe benefits are the responsibility of the grantee agency. Civilian positions, overtime, training, weapons, 

communication equipment, and vehicles cannot be funded with your TRGP-Hiring grant.

Allowable costs: Approved salary and benefits

The FCM, included in your award package, specifies the approved amount of COPS Office TRGP-Hiring funds 

awarded to your agency for officer salaries and approved benefits. Please note that the salary and benefit 

costs requested in your original application may have been updated or corrected from the original version 

submitted to the COPS Office. Your agency may only be reimbursed for the approved cost categories and 

amounts that are documented within the FCM. In addition, your agency may not use TRGP funds for any 

costs that are not identified as allowable in the FCM.

Allowable costs: Indirect costs

Indirect costs are costs that are incurred for common or joint purposes and are not readily assignable to 

a particular project but are necessary to the operation of the agency and the performance of the project. 

Examples of indirect costs include those incurred for facility operation and maintenance, depreciation, and 

administrative salaries. Indirect cost usage must adhere to the standards set forth in the applicable Office of 

Management and Budget (OMB) uniform guidance 2 C.F.R. Part 200.56—Indirect (facilities & administrative 

(F&A)) costs and 2 C.F.R. Part 200.414—Indirect (F&A) costs. Additional guidance for your entity can be found 

in the following locations: Appendix III to Part 200—Indirect (F&A) Costs Identification and Assignment, and 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

6

Rate Determination for Institutions of Higher Education (IHEs); Appendix IV to Part 200—Indirect (F&A) Costs 

Identification and Assignment, and Rate Determination for Nonprofit Organizations; Appendix VII to Part 

200—States and Local Government and Indian Tribe Indirect Cost Proposals.

Indirect cost rates are federally negotiated and approved rates that are based on audited and documented 

expenses that are approved to be included within an indirect cost rate. It is important that your agency 

carefully track and update its indirect cost rate during the COPS Office grant award period.

The grantee understands that if it submitted an expired indirect cost rate agreement at the time of 

application, it will be unable to recover federal funds for indirect costs until the COPS Office receives a 

current indirect cost rate agreement covering the award period. A special condition may be added to the 

award prohibiting the obligation, expenditure, or drawdown of funds reimbursement for indirect costs until 

a current indirect cost rate has been approved by your cognizant federal agency and submitted to the COPS 

Office.

If your agency’s approved indirect cost rate expires during the grant award period, a current approved rate 

must be submitted to the COPS Office in order to continue to draw down grant funding for indirect costs. 

Your agency must advise the COPS Office in writing of any changes to your approved indirect cost rate 

during the grant award period and must request a budget modification with the COPS Office to reflect any 

rate change.

If your agency has never received a negotiated indirect cost rate, then you may request up to a flat 10 

percent de minimis indirect cost rate applied to the modified total direct costs (MTDC). 

In addition, before the COPS Office officially closes out your agency’s grant award, your agency must 

reconcile any changes between your approved final indirect cost rate and approved provisional indirect cost 

rate and, if necessary, repay the COPS Office for any indirect cost rate overpayment. If your agency draws 

down excess COPS Office grant funding for indirect costs, please return the overpayment to the COPS Office 

and submit a revised Federal Financial Report (SF-425).

See the COPS Office website for a fact sheet on indirect costs: http://www.cops.usdoj.gov/

pdf/2015AwardDocs/cpd/Indirect_Cost_Rate_Fact_Sheet.pdf.

4. Supplementing, not supplanting

State, local, and tribal governments must use TRGP grant funds to supplement, and not supplant, state, local, or BIA 

funds that are already committed or otherwise would have been committed for grant purposes (hiring, training, 

purchases, and/or activities) during the grant period. In other words, grantees may not use COPS Office funds to 

supplant (replace) state, local, or BIA funds that would have been dedicated to the COPS Office-funded item(s) in 

the absence of the COPS Office grant.

Why this condition:

The COPS Office statutory nonsupplanting requirement mandates that grant funds may not be used to 

replace state or local funds (or, for tribal grantees, BIA funds) that would, in the absence of federal aid, be 

made available for the grant purposes.

What you should do:

TRGP-Hiring grantees may not use grant funds to pay for any item or cost funded under the grant 

(equipment, personnel, training, etc.) if that item or cost was otherwise budgeted with state, local, or BIA 

funds, or committed to the grantee’s budget. 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

7

TRGP-Hiring—To meet this grant condition, you must ensure that the following:

•	 If your agency is redeploying a current employee to perform the work duties of the TRGP-Hiring 

position, the redeployed position must be paid with local funds. The COPS Office grant funds may be 

used to backfill the resulting vacancy with newly hired personnel for an equivalent amount of time. 

Each individual employed under the TRGP-Hiring grant must be newly hired or rehired on or after the 

grant award start date unless an exception is authorized in writing by the COPS Office.

•	 Any officer your agency hires brings your force not only to a number over and above the number of 

funded positions that you had on the date of your Coordinated Tribal Assistance Solicitation (CTAS), 

including funded but vacant positions, but also to a number over and above the number of locally 

funded officer positions during the grant award period.

•	 During the life of your grant, your agency must continue to hire as many new, locally funded officers 

as you would have hired if you had not received your grant. Your agency may not cancel or postpone 

spending money in its budget that is committed to hiring other new officers.

•	 Your agency must take active and timely steps to fill any vacancies that were created on or after the 

date of your grant application by retirement, resignation, or other reasons with new officers in addition 

to your TRGP-Hiring grant-funded positions.

Note: This grant condition applies to all state or locally funded agencies working in partnership with your 

agency under this grant. Your agency is responsible for ensuring that any partner agencies use COPS Office 

funds only to supplement, not supplant, their state, local, or BIA funding as described in this condition.

5. Extensions

Your agency may request an extension of the grant award period to receive additional time to implement your 

grant program. Such extensions do not provide additional funding. Grants may be extended a maximum of 36 

months beyond the initial award expiration date. Any request for an extension beyond 36 months will be evaluated 

on a case-by-case basis. Only those grantees that can provide a reasonable justification for delays will be granted 

no-cost extensions. Reasonable justifications may include difficulties in filling COPS Office-funded positions, officer 

turnover, or other circumstances that interrupt the 36-month grant funding period. An extension allows your 

agency to compensate for such delays by providing additional time to complete the full 36 months of funding for 

each position awarded. Extension requests must be received prior to the end date of the award.

Why this condition:

Under federal regulations, requests to extend the grant award period require prior written approval from the 

COPS Office. Without an approved extension, your agency is not permitted to draw down federal funding 

for costs incurred beyond the official grant award end date. However, if justified, the COPS Office seeks to 

accommodate reasonable requests for no-cost time extensions in order to fully implement the COPS Office grant.

What you should do:

The COPS Office will contact your agency during the last quarter of the grant award period to determine 

whether a no-cost time extension is needed; extensions will not be processed prior to 90 days before the 

grant end date. Requests to extend the grant award period must be received by the COPS Office before the 

official grant award end date. Extension requests received after the expiration date will be considered only 

when the grantee provides justification of extraordinary circumstances; an example of this would be an 

instance in which an unforeseen natural disaster prevented a grantee from requesting an extension. Failure 

to submit a request for a no-cost time extension by the end date may result in the immediate deobligation 

of any remaining grant funds.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

8

Automatic extensions will be granted for grantee requests of six months or less. All extension requests 

beyond six months will require review and approval by the COPS Office. Individual or cumulative requests 

greater than one-half of the grant’s original term (i.e., 18 months) will require additional justification and 

must include a detailed timeline.

If your agency has excess funds remaining at the end of the grant due to salary and fringe benefits costs that 

were lower than anticipated, your agency may not extend the 36-month funding period for the purpose of 

expending those excess funds. Grantees are entitled to a maximum of 36 months of federal funding based 

on the approved salary and fringe benefits costs in the FCM. The COPS Office will deobligate any remaining 

grant funds during the closeout process. If you have any additional questions regarding a no-cost time 

extension, please contact your COPS Office Grant Program Specialist.

6. Modifications

Occasionally, a change in an agency’s fiscal or law enforcement situation necessitates a change in its TRGP award. 

Grant modifications under TRGP are evaluated on a case-by-case basis. All modification requests involving the 

purchase of new budget items must be approved, in writing, by the COPS Office prior to their implementation. In 

addition, please be aware that the COPS Office will not approve any modification request that results in an increase 

of federal funds.

Why this condition:

The COPS Office realizes that agencies may need to reprogram grant funds. Acceptable examples of such 

award modifications include purchasing additional equipment using cost-savings from approved items, 

or purchasing a different type of equipment due to changing needs. Under federal regulations, you may 

expend grant funds only as approved in the FCM. Any requests to change or alter grant awards require 

written approval from the COPS Office prior to their implementation. Without prior written approval, you 

must continue to implement your grant as it was originally awarded and accepted by your agency. Please be 

advised that reprogramming requests for unallowable costs will not be approved (e.g., construction).

What you should do:

For all modifications, your agency must access www.cops.usdoj.gov and select the “Account Access” link 

in the upper right corner to log in and submit your request to the COPS Office, providing the proposed 

changes, details of why the change is needed, etc.

For additional information about the process for submitting your specific grant modification request, please 

contact your COPS Office Grant Program Specialist at 800-421-6770. The COPS Office will then evaluate your 

request and notify your agency of our decision in writing. Implementation of the modified grant award 

may begin following written approval from the COPS Office. Please note that modification approvals for 

active grants will often be accompanied by a modified award document reflecting the approved changes. 

If applicable, your agency is required to sign and submit the modified award document via the “Account 

Access” link to officially accept the grant modification.

7. Evaluations

The COPS Office may conduct monitoring or sponsor national evaluations of the COPS Office Tribal Resources 

Grant Program. The grantee agrees to cooperate with the monitors and evaluators.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

9

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 states that evaluations of the program 

may be carried out or commissioned by the Attorney General for the furtherance of the purposes of the 

act. The COPS Office conducts evaluations to determine which programs are working, how programs may 

be improved, and why certain programs are more successful than others. Specifically, the COPS Office 

may assess the way in which your agency implements its grant. In some jurisdictions, COPS Office staff or 

evaluators may study the effectiveness of funded programs, projects, and activities. Evaluators may collect 

information about the programs’ effect on crime, victims of crime, and the quality of life in communities. In 

addition, they may ask questions about the challenges encountered during project implementation, how 

residents feel about community policing, and how police feel about their work. This information will be 

useful to other communities and police agencies across the country.

What you should do:

When evaluations are undertaken, you may be contacted in writing with specific requests for information. 

In general, evaluators may need to speak with individuals in your agency or department, observe activities, 

and obtain written reports about and from your agency or department. You will be asked to facilitate 

any site visits and information-gathering activities. In addition, you will be asked to provide accurate and 

timely information about your grant activities. You should fully comply with any requests regarding these 

evaluations.

8. Reports/Performance goals

To assist the COPS Office in the monitoring of your award, your agency will be responsible for submitting quarterly 

programmatic progress reports and quarterly Federal Financial Reports using Standard Form 425 (SF-425). The 

progress report is used to track your agency’s progress toward implementing community policing strategies and 

to collect data to gauge the effectiveness of increasing your agency’s community policing capacity through COPS 

Office funding.

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 and other federal regulations and policies 

require that financial assistance provided by the Federal Government be monitored carefully to ensure 

the proper use of federal funds. In addition, the COPS Office seeks to document, on a continuing basis, the 

progress of our programs and grantees.

What you should do:

This grant condition is designed to make your agency aware of reporting requirements associated with TRGP 

grants. Quarterly programmatic progress reports and a final programmatic closeout report will be required 

to be submitted directly to the COPS Office through the “Account Access” portion of the COPS Office 

website at www.cops.usdoj.gov. Your agency is also required to submit quarterly Federal Financial Reports 

using Standard Form 425 (SF-425) within 30 days after the end of each calendar quarter. A final SF-425 will 

be due within 90 days after the end of the grant period. This report reflects the actual cumulative federal 

expenditures incurred during the funding period, and the remaining unobligated balance of federal funds. 

Under federal regulations, your agency is not permitted to draw down federal funding for costs incurred 

after the official grant end date, however you will have a 90-day grace period after the grant award end 

date during which you can drawdown funds for eligible expenditures incurred before the grant end date. 

Agencies with more than one delinquent programmatic or financial report submission per fiscal year may 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

10

be subject to delays in receiving reimbursement for allowable expenses and may be required to receive 

technical assistance to improve compliance with reporting. These reports are discussed in greater detail in 

section VI, “Reports,” on page 64 of this manual. All reports should be submitted within the deadlines given to 

avoid suspension or possible termination of grant funds or other remedial actions; failure to submit required 

reports may also impact future funding opportunities.

9. Grant monitoring activities

Federal law requires that law enforcement agencies receiving federal funding from the COPS Office must be 

monitored to ensure compliance with their grant conditions and other applicable statutory regulations. The COPS 

Office is also interested in tracking the progress of our programs and the advancement of community policing. 

Both aspects of grant implementation—compliance and programmatic benefits—are part of the monitoring 

process coordinated by the U.S. Department of Justice. Grant monitoring activities conducted by the COPS Office 

include site visits, office-based grant reviews, alleged noncompliance reviews, financial and programmatic 

reporting, and audit resolution. As a COPS Office TRGP grantee, you agree to cooperate with and respond to any 

requests for information pertaining to your grant.

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 states that each grant program must 

contain a monitoring component. The COPS Office actively monitors how grantees are adhering to COPS 

Office grant requirements and develops the best technical assistance based on this feedback.

What you should do:

Your agency may be required to accommodate routine and non-routine efforts by the COPS Office, or an 

entity designated by the COPS Office, to examine your agency’s use of federal funds, both programmatically 

and financially. The most common ways are as follows:

•	 site visits. The COPS Office conducts grantee site visits to ensure compliance with grant terms and 

conditions. These visits also provide firsthand observation of the grantee’s community policing 

strategies. The purpose of site visits is threefold: review community policing activities, ensure grantee 

compliance, and provide customer service and technical assistance. If selected, you will be notified in 

writing in advance of any on-site review of your COPS Office grants. This review is generally performed 

over a period of one or more days and also provides an opportunity for agency representatives to seek 

assistance on any grant implementation issues. 

•	 enhanced office-based grant reviews (EOBGR). In lieu of a site visit, certain grants are selected for 

a review conducted at the COPS Office via teleconference or video conference. EOBGRs serve as a 

supplemental activity in support of the COPS Office’s overall grant monitoring strategy. The purpose 

of the EOBGR is threefold: review community policing activities, ensure grantee compliance, and 

provide customer service and technical assistance. If selected, you will be notified in writing in advance 

of any EOBGR of your COPS Office grants. This review is generally performed over a one or more day 

period and also provides an opportunity for agency representatives to seek assistance on any grant 

implementation issues. Your agency will be notified in writing of the results and any action required 

to remedy identified grant violations to include potential and actual vulnerabilities. Additionally, 

promising practices identified during the EOBGR are documented and may be shared with the law 

enforcement community.

•	 alleged noncompliance reviews (ANCR). An alleged noncompliance review is a follow up on complaints 

of alleged noncompliance received from external (media and/or citizen complaints) or internal 

(COPS Office/DOJ staff ) sources. On a case-by-case basis, COPS Office staff members determine the 

appropriate course of action to take to investigate complaints of alleged noncompliance. This may 

include phone or letter contact or a site visit by COPS Office staff or the Office of the Inspector General. 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

11

•	 audit liaison. The U.S. Department of Justice, Office of the Inspector General (OIG) conducts random 

audits for all COPS Office grantees. In the event your agency has any audit recommendations (findings) 

resulting from noncompliance and/or poor accounting practices, the COPS Office Audit Liaison 

Section will work with your agency to resolve and close these recommendations. Remedies to close 

recommendations may include repayment of grant funds and/or the submission of documentation. 

Grantees are responsible for remedying any grant noncompliance that is identified during site visits, 

office-based grant review, and/or alleged noncompliance reviews. In addition, grantees are responsible 

for remedying noncompliance stemming from audit recommendations identified in audits of COPS Office 

grants conducted by the Office of Inspector General (OIG) and the Office of the Chief Financial Officer 

(OCFO). Remedies for noncompliance may include but are not limited to suspending active grant funding, 

repayment of unallowable or unsupported costs, voluntary withdrawal from or involuntary termination 

of remaining grant funds, or restriction from receiving future grants for a period of time. Under certain 

conditions, additional actions may include placement on the U.S. Department of Justice’s High Risk List, 

which will include mandatory completion of the Office of Justice Programs Financial Management Training 

and being subject to increased monitoring of current and future grants while on the list. In the event of 

criminal misuse of grant funds, grantees may also be subject to fines and imprisonment. To avoid findings 

of noncompliance, grantees are strongly encouraged to become familiar with the COPS Grant Monitoring 

Division’s Grant Monitoring Standards and Guidelines and with the Grant Owner’s Manual for the year 

in which the grant is awarded. Grantees should also contact the COPS Office or their Grant Program 

Specialist at any time during the life of a COPS Office grant with questions concerning grant conditions, 

terms, or requirements to seek guidance to avoid noncompliance. It is necessary for grantees to maintain 

all relevant documentation (administrative, financial, and programmatic) used to develop the application 

and implement the grant that may be necessary or required to demonstrate grant compliance. For more 

information, please contact the COPS Office Response Center at 800-421-6770 or at AskCopsRC@usdoj.gov.

10. Federal civil rights

As a condition of receipt of federal financial assistance, you acknowledge and agree that you will not (and will 

require any sub-grantees, contractors, successors, transferees, and assignees not to), on the grounds of race, color, 

religion, national origin (which includes providing limited English proficient persons meaningful access to your 

programs), sex, disability, or age, unlawfully exclude any person from participation in, deny the benefits of or 

employment to any person, or subject any person to discrimination in connection with any programs or activities 

funded in whole or in part with federal funds. These civil rights requirements are found in the nondiscrimination 

provisions of Title VI of the Civil Rights Act of 1964, as amended (42 U.S.C. § 2000d); the Omnibus Crime Control and 

Safe Streets Act of 1968, as amended (42 U.S.C. § 3789d); Section 504 of the Rehabilitation Act of 1973, as amended 

(29 U.S.C. § 794); the Age Discrimination Act of 1975 (42 U.S.C. §6101, et seq.); Title IX of the Education Amendments 

of 1972, as amended (20 U.S.C. § 1681, et seq.); and the corresponding DOJ regulations implementing those 

statutes at 28 C.F.R. Part 42 (subparts C, D, E, G, and I). You also agree to comply with Executive Order 13279 Equal 

Treatment for Faith-Based Organizations and its implementing regulations at 28 C.F.R. Part 38, which requires 

equal treatment of religious organizations in the funding process and nondiscrimination of beneficiaries by FaithBased Organizations on the basis of belief or nonbelief. 

Why this condition:

In establishing financial assistance programs, Congress linked the receipt of federal funding to compliance 

with federal civil rights laws. As a result, grantees are required to comply with the civil rights requirements 

found in the nondiscrimination provisions referenced above. A hold may be placed on your award if it is 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

12

deemed that your agency is not in compliance with federal civil rights laws or is not cooperating with an 

ongoing federal civil rights investigation. If a hold is placed on your award, you will not be able to obligate 

or draw down federal funds under your agency’s COPS Office grant award until you comply with federal civil 

rights laws or cooperate with any ongoing federal civil rights investigation.

What you should do:

As a recipient of federal financial assistance from the COPS Office, you are required to comply with the 

applicable federal civil rights laws, to collect data and information sufficient to permit effective enforcement 

of such laws, and to cooperate with any federal civil rights investigation, which includes providing access to 

records, accounts, documents, information, facilities, and staff.

11. Equal Employment Opportunity Plan

All recipients of funding from the COPS Office must comply with the federal regulations pertaining to the 

development and implementation of an Equal Employment Opportunity Plan (28 C.F.R. Part 42 subpart E).

Why this condition:

It is the experience of the U.S. Department of Justice in implementing its responsibilities under the Omnibus 

Crime Control and Safe Streets Act of 1968 (Safe Streets Act), the statute that established the COPS Office, 

that “the full and equal participation of women and minority individuals in employment opportunities in 

the criminal justice system is a necessary component to the Safe Streets Act’s program to reduce crime and 

delinquency in the United States” 28 C.F.R. § 42.301. The Equal Employment Opportunity Plan (EEOP) does 

not impose quotas or hiring requirements on recipients of federal funds.

What you should do:

The obligations to comply with the EEOP requirement differ depending on your organization’s legal status, 

the number of its employees, and the amount of the award.

If your organization has fewer than 50 employees or receives an award of less than $25,000 or is a nonprofit 

organization, a medical institution, an educational institution, or an Indian tribe, then it is exempt from the 

EEOP requirement. To claim the exemption, your organization must complete and submit section A of the 

Certification Form to the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice, 

810 7th Street NW, Washington, DC 20531. The Certification Form can be found at http://www.ojp.usdoj.gov/

about/ocr/pdfs/cert.pdf.

If your organization is a governmental agency or private business and has received an award between 

$25,000 and $500,000 and has 50 or more employees (counting both full- and part-time employees but 

excluding political appointees), then it must prepare a Utilization Report (formerly called an EEOP Short 

Form), but it does not need to submit it to the OCR for review. Instead, your organization must maintain 

the Utilization Report on file and make it available to the OCR for review on request. In addition, your 

organization must complete and submit section B of the Certification Form to the Office for Civil Rights 

(OCR), Office of Justice Programs, U.S. Department of Justice, 810 7th Street NW, Washington, DC 20531. The 

Certification Form can be found at www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf.

If your organization is a governmental agency or private business and has received an award for $500,000 or 

more and has 50 or more employees (counting both full- and part-time employees but excluding political 

appointees), then it must prepare a Utilization Report (formerly called an EEOP Short Form) and submit it 

to the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice, 810 7th Street 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

13

NW, Washington, DC 20531 for review within 60 days of the notification of the award. In addition, your 

organization must complete and submit section C of the Certification Form to the OCR. The Certification 

Form can be found at www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf.

For assistance in developing a Utilization Report, please consult the OCR’s website at www.ojp.usdoj.

gov/about/ocr/eeop.htm. To comply with the EEOP requirements, you may request technical assistance 

from an EEOP specialist at the OCR by telephone at 202-307-0690, by TTY at 202-307-2027, or by e-mail at 

EEOsubmissions@usdoj.gov.

12. Community policing

Community policing activities to be initiated or enhanced by your agency were identified and described in your 

grant application. All equipment, technology, training, and/or sworn officer positions awarded under the TRGP 

grant must be linked to the implementation or enhancement of community policing.

Why this condition:

The COPS Office defines community policing as a philosophy that promotes organizational strategies that 

support the systematic use of partnerships and problem-solving techniques to proactively address the 

immediate conditions giving rise to public safety issues such as crime, social disorder, and fear of crime. 

TRGP grants must be used to initiate or enhance community policing activities. All newly hired, additional, or 

rehired officers (or an equal number of redeployed veteran officers) funded under TRGP-Hiring must engage 

in community policing activities. While the COPS Office recognizes that your COPS Office-funded officer(s) 

(or an equal number of redeployed veteran officers) will participate in some or all aspects of your identified 

community policing plan and advance your agency’s community policing activities over the life of the grant, 

we also encourage your agency to move toward an organization-wide philosophy and commitment to 

community policing.

COPS Office grants are designed to increase community policing capacity and crime prevention efforts. 

This is achieved through problem-solving tactics and community policing partnerships. It enhances police 

professionalism by providing officers with the skills and motivation to act in innovative ways to solve 

community crime-related problems. Your organization may be monitored or audited to ensure that it is 

initiating or enhancing community policing in accordance with your proposed plan, and that the officers 

hired (or an equal number of redeployed veteran officers) are used to implement this plan and advance 

your agency’s community policing activities over the life of the grant. The COPS Office may also use this 

information to understand the needs of the field and potentially provide for training, technical assistance, 

problem solving, and community policing implementation tools.

What you should do:

Community policing activities to be implemented or enhanced by your agency were identified in your grant 

application. Your community policing needs may change during the life of your grant, and minor changes to 

this plan may be made without prior approval of the COPS Office. If your agency’s community policing plan 

changes significantly, however, you must submit those changes in writing to the COPS Office for approval. 

Changes are significant if they deviate from the range of possible community policing activities identified 

and approved in the original community policing plan submitted with your application.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

14

13. Contracts with other jurisdictions 

Equipment, technology, training, vehicles, and/or sworn law enforcement officer positions awarded may only be 

used for law enforcement activities or services that exclusively benefit your agency and the population that it serves. 

The items funded under the TRGP grant cannot be utilized by other agencies unless the items would exclusively 

benefit the population that your agency serves.

Why this condition:

The TRGP was created under a Congressional appropriation specifically designated for tribal law 

enforcement agencies to improve public safety in Indian communities. The TRGP-Hiring grant funding is 

intended to benefit the communities within the grantee’s primary law enforcement jurisdiction. Therefore, 

the grantee must use the TRGP grant funding to benefit its own population exclusively.

What you should do:

Your law enforcement agency should avoid any agreements with other jurisdictions to share officer 

positions or other awarded equipment, technology, or vehicles unless the agreement complies with the 

requirement that COPS Office-funded items must exclusively benefit the grantee service population. For 

example, if your jurisdiction has a tribal police department and a BIA department, items funded under the 

grant might be able to be used by the BIA department as long as this would result in an exclusive benefit 

to the population that you serve. You may not, however, allow officers, equipment, technology, or vehicles 

funded under the grant to be used by any agency or transferred to any agency that does not exclusively 

benefit the population that you serve. For example, you may not, during the grant term, loan two of your 

awarded computers to a neighboring county’s sheriff’s department.

Officers funded under TRGP-Hiring may not provide contract law enforcement services to other agencies 

unless they will directly benefit the grantee’s jurisdiction. For example, your agency may not use an officer 

funded under TRGP-Hiring to provide contract law enforcement services to a neighboring county, but 

your agency may use the officer to provide direct law enforcement services to the population within your 

agency’s own jurisdiction.

Before you enter into any agreement with another law enforcement agency, you should contact your COPS 

Office Grant Program Specialist (GPS) at 800-421-6770 for additional guidance.

14. False statements 

False statements or claims made in connection with COPS Office grants may result in fines, imprisonment, or 

debarment from participating in federal grants or contracts, and/or any other remedy available by law.

Why this condition:

This condition advises recipients of the consequences of submitting false claims or statements on 

applications, financial and programmatic reports, or other grant documents.

What you should do:

Ensure that all documentation related to your agency’s receipt and use of grant funding (grant applications, 

progress reports, Federal Financial Reports, etc.) is true and accurate.

15. Duplicative funding

The recipient understands and agrees to notify the COPS Office if it receives, from any other source, funding for the 

same item or service also funded under this award.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

15

Why this condition:

This grant was awarded to your agency to address its law enforcement needs that are not funded from 

other sources, including federal, state, local, tribal, or BIA funds. Consequently, your agency may not use this 

funding for items or services for which you already have funding from other sources.

What you should do:

If your agency receives funding from another source for the same item(s) or services(s) also funded under 

this award, please contact your COPS Office GPS at 800-421-6770. If necessary, the COPS Office will work 

with your agency to reprogram funding for items or services that are allowable under this grant program.

16. Additional high-risk grantee requirements

The recipient agrees to comply with any additional requirements that may be imposed during the grant 

performance period if the awarding agency determines that the recipient is a high-risk grantee (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.207 as 

adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101). 

Why this condition:

In accordance with 2 C.F.R. § 200.207, the U.S. Department of Justice (DOJ) may impose additional 

requirements specific to your award, as needed, when it determines that there is unsatisfactory performance, 

financial or administrative instability, noncompliance with award terms and conditions, or other lack of 

responsibility risk factors. In such cases, the U.S. Department of Justice may impose special conditions or 

restrictions that may include requiring the production of documentation, financial grant administration 

training, on-site monitoring, prior approval for expenditure of funds, quarterly progress reports, separate 

bank accounts, or other requirements.

What you should do:

In order to obtain a COPS Office grant, recipients must agree to comply with any additional requirements 

that may be imposed during the grant performance period if the awarding agency determines that the 

recipient is a high-risk grantee.

17. System for Award Management and Universal Identifier requirements

The Office of Management and Budget requires federal agencies to include the following standard award term in 

all grants and cooperative agreements made on or after October 1, 2010:

A. Requirement for System for Award Management (SAM)

Unless you are exempted from this requirement under 2 C.F.R. Part 25.110, you as the recipient must 

maintain the currency of your information in the SAM until you submit the final financial report required 

under this award or receive the final payment, whichever is later. This requires that you review and update 

the information at least annually after the initial registration, and more frequently if required by changes in 

your information or another award term.

B. Requirement for Data Universal Numbering System (DUNS) Numbers

If you are authorized to make subawards under this award, you:

1. Must notify potential subrecipients that no entity (see definition in paragraph C of this award term) 

may receive a subaward from you unless the entity has provided its DUNS number to you.

2. May not make a subaward to an entity unless the entity has provided its DUNS number to you.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

16

C. Definitions

For purposes of this award term:

1. System for Award Management (SAM) means the federal repository into which an entity must 

provide information required for the conduct of business as a recipient. Additional information about 

registration procedures may be found at the SAM Internet site at www.sam.gov.

2. Data Universal Numbering System (DUNS) number means the nine- or thirteen-digit number 

established and assigned by Dun and Bradstreet, Inc. (D&B) to uniquely identify business entities. A 

DUNS number may be obtained from D&B by telephone (currently 866-705-5711) or the Internet at 

http://fedgov.dnb.com/webform.

3. Entity, as it is used in this award term, means all of the following, as defined at 2 C.F.R. Part 25, 

subpart C:

a. A governmental organization, which is a state, local government, or Indian Tribe;

b. A foreign public entity;

c. A domestic or foreign non-profit organization;

d. A domestic or foreign for-profit organization; and

e. A federal agency, but only as a subrecipient under an award or subaward to a non-federal 

entity.

4. Subaward:

a. This term means a legal instrument to provide support for the performance of any portion of 

the substantive project or program for which you received this award and that you as the recipient 

award to an eligible subrecipient.

b. The term does not include your procurement of property and services needed to carry out 

the project or program (for further explanation, see Sec. ___.210 of the attachment to OMB Circular 

A-133, “Audits of States, Local Governments, and Non-Profit Organizations”).

c. A subaward may be provided through any legal agreement, including an agreement that you 

consider a contract.

5. Subrecipient means an entity that:

a. Receives a subaward from you under this award; and

b. Is accountable to you for the use of the federal funds provided by the subaward.

Why this condition:

The purpose of this standard award term is to ensure government-wide uniformity in establishing the DUNS 

number as the universal identifier for federal financial assistance applicants, as well as recipients and their 

direct subrecipients (if applicable) and to establish the SAM as the repository for standard information about 

applicants and recipients.

What you should do:

At the time of grant application, your agency was required to provide its DUNS number and be registered in 

the SAM database.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

17

Your agency should continue to use the same DUNS number provided in your grant application and 

update, as needed, the information associated with that DUNS number. If your agency is authorized to make 

subawards under its award, your agency may make subawards only to entities that have DUNS numbers. For 

more information about your DUNS number, please contact D&B using the toll-free number 866-705-5711 or 

visit http://fedgov.dnb.com/webform.

Your agency must maintain active registration and current information in the SAM until you submit the final 

financial report or receive the final payment under your award, whichever is later. Your agency must review 

and update its SAM information at least once per year to maintain an active registration status. For more 

information about SAM registration, please visit www.sam.gov.

18. Reporting subawards and executive compensation

The Office of Management and Budget requires federal agencies to include the following standard award term in 

all grants and cooperative agreements made on or after October 1, 2010: 

a. Reporting of first-tier sub-awards.

1. Applicability. Unless you are exempt as provided in paragraph d. of this award term, you must 

report each action that obligates $25,000 or more in federal funds that does not include Recovery funds 

(as defined in section 1512(a)(2) of the American Recovery and Reinvestment Act of 2009, Pub. L. 111–5) 

for a subaward to an entity (see definitions in paragraph e. of this award term).

2. Where and when to report.

i. You must report each obligating action described in paragraph a.1. of this award term to 

www.fsrs.gov.

ii. For subaward information, report no later than the end of the month following the month in 

which the obligation was made. (For example, if the obligation was made on November 7, 2010, 

the obligation must be reported by no later than December 31, 2010.)

3. What to report. You must report the information about each obligating action that the submission 

instructions posted at www.fsrs.gov specify.

b. Reporting Total Compensation of Recipient Executives.

1. Applicability and what to report. You must report total compensation for each of your five most 

highly compensated executives for the preceding completed fiscal year, if—

i. the total federal funding authorized to date under this award is $25,000 or more;

ii. in the preceding fiscal year, you received—

(A) 80 percent or more of your annual gross revenues from federal procurement contracts 

(and subcontracts) and federal financial assistance subject to the Transparency Act, as defined 

at 2 C.F.R. Part 170.320 (and subawards); and

(B) $25,000,000 or more in annual gross revenues from federal procurement contracts (and 

subcontracts) and federal financial assistance subject to the Transparency Act, as defined at 2 

C.F.R. Part 170.320 (and subawards); and

iii. The public does not have access to information about the compensation of the executives 

through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 

(15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine 

if the public has access to the compensation information, see the U.S. Security and Exchange 

Commission total compensation filings at www.sec.gov/answers/execomp.htm.)
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

18

2. Where and when to report. You must report executive total compensation described in paragraph 

b.1 of this award term:

i. As part of your registration profile at www.sam.gov.

ii. By the end of the month following the month in which this award is made, and annually 

thereafter.

c. Reporting of Total Compensation of Sub-recipient Executives.

1. Applicability and what to report. Unless you are exempt as provided in paragraph d. of this 

award term, for each first-tier subrecipient under this award, you shall report the names and total 

compensation of each of the subrecipient’s five most highly compensated executives for the 

subrecipient’s preceding completed fiscal year, if—

i. in the subrecipient’s preceding fiscal year, the sub-recipient received—

(A) 80 percent or more of its annual gross revenues from federal procurement contracts (and 

subcontracts) and federal financial assistance subject to the Transparency Act, as defined at 2 

C.F.R. Part 170.320 (and subawards); and

(B) $25,000,000 or more in annual gross revenues from federal procurement contracts (and 

subcontracts), and federal financial assistance subject to the Transparency Act (and subawards); and

ii. The public does not have access to information about the compensation of the executives 

through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 

(15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine 

if the public has access to the compensation information, see the U.S. Security and Exchange 

Commission total compensation filings at www.sec.gov/answers/execomp.htm.)

3. Where and when to report. You must report sub-recipient executive total compensation described 

in paragraph c.1. of this award term:

i. To the recipient.

ii. By the end of the month following the month during which you make the subaward.

For example, if a sub-award is obligated on any date during the month of October of a given year 

(i.e., between October 1 and 31), you must report any required compensation information of the 

sub-recipient by November 30 of that year.

d. Exemptions.

If, in the previous tax year, you had gross income, from all sources, under $300,000, you are exempt from the 

requirements to report:

i. Subawards, and

ii. The total compensation of the five most highly compensated executives of any subrecipient.

e. Definitions. For purposes of this award term:

1. Entity means all of the following, as defined in 2 C.F.R. Part 25:

i. A governmental organization, which is a state, local government, or Indian tribe;

ii. A foreign public entity;

iii. A domestic or foreign non-profits organization;

iv. A domestic or foreign for-profit organization;

v. A federal agency, but only as a sub-recipient under an award or sub-award to a non-federal 

entity.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

19

2. Executive means officers, managing partners, or any other employees in management positions.

3. Subaward:

i. This term means a legal instrument to provide support for the performance of any portion of 

the substantive project or program for which you received this award and that you as the recipient 

award to an eligible subrecipient.

ii. The term does not include your procurement of property and services needed to carry out 

the project or program (for further explanation, see Sec. __.210 of the attachment to OMB Circular 

A–133, “Audits of States, Local Governments, and Non-Profit Organizations”).

iii. A subaward may be provided through any legal agreement, including an agreement that you 

or a subrecipient considers a contract.

4. Subrecipient means an entity that:

i. Receives a subaward from you (the recipient) under this award; and

ii. Is accountable to you for the use of the federal funds provided by the subaward.

5. Total compensation means the cash and noncash dollar value earned by the executive during the 

recipient’s or sub-recipient’s preceding fiscal year and includes the following (for more information see 

17 C.F.R. Part 229.402(c)(2)):

i. Salary and bonus.

ii. Awards of stock, stock options, and stock appreciation rights. Use the dollar amount 

recognized for financial statement reporting purposes with respect to the fiscal year in accordance 

with the Statement of Financial Accounting Standards No. 123 (Revised 2004) (FAS 123R), Shared 

Based Payments.

iii. Earnings for services under non-equity incentive plans. This does not include group life, health, 

hospitalization or medical reimbursement plans that do not discriminate in favor of executives, and 

are available generally to all salaried employees.

iv. Change in pension value. This is the change in present value of defined benefit and actuarial 

pension plans.

v. Above-market earnings on deferred compensation which is not tax-qualified.

vi. Other compensation, if the aggregate value of all such other compensation (e.g., severance, 

termination payments, value of life insurance paid on behalf of the employee, perquisites or 

property) for the executive exceeds $10,000.

Why this condition:

To further federal spending transparency, the Federal Funding Accountability and Transparency Act of 2006 

(FFATA) requires, among other things, that information on federal awards (federal financial assistance and 

expenditures) be made available to the public via a single, searchable website, which is www.USASpending.gov. 

Grantees are responsible for reporting their applicable executive compensation and sub-award information, 

and the award term provides guidance to report the related information as required by FFATA.

What you should do:

At the time of grant application, your agency was asked to ensure that it has the necessary processes 

and systems in place to comply with the applicable subaward and executive compensation reporting 

requirements should it receive funding. If your agency received awards of $25,000 or more, you are required 

to report award information on any first-tier subawards totaling $25,000 or more, and, in certain cases, to 

report information on the names and total compensation of the five most highly compensated executives 

of the recipient and first-tier subrecipients. The FFATA Subaward Reporting System (FSRS), accessible via the 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

20

website at www.fsrs.gov, is the reporting tool that your agency will use to capture and report subaward 

information and any executive compensation data required by FFATA. The subaward information entered 

in FSRS will then be displayed on www.USASpending.gov associated with your agency’s award, furthering 

federal spending transparency.

For additional information regarding the executive compensation and subaward reporting 

requirements, please see Vol. 75, No. 177 (September 14, 2010) of the Federal Register, 

www.gpo.gov/fdsys/pkg/FR-2010-09-14/pdf/2010-22705.pdf.

19. Retention

At the time of grant application, your agency committed to retaining all sworn officer positions awarded under 

the TRGP Hiring grant with state and/or local funds for a minimum of 12 months following the conclusion of 36 

months of federal funding for each position, over and above the number of locally funded sworn officer positions 

that would have existed in the absence of the grant. Your agency cannot satisfy the retention requirement by using 

TRGP funded positions to fill locally funded vacancies resulting from attrition.

Why this condition:

The retention requirement ensures that the increased officer staffing level under the TRGP-Hiring grant 

continues with state or local funds for a minimum of 12 months after federal funding ends.

What you should do:

At the time of grant application, your agency was required to affirm that it planned to retain all sworn officer 

positions awarded under the TRGP-Hiring grant and identify the planned source(s) of retention funding. Your 

agency committed to retaining each awarded position for at least 12 months following the conclusion of 36 

months of federal funding for that position. The retention period begins for an awarded officer position once 

that position has completed the 36-month implementation period. If an agency is awarded several officer 

positions, the retention period for each individual officer position begins upon completion of 36 months of 

funding for that position (not based on the cumulative grant award end date).

The retained TRGP funded position(s) must be added to your agency’s law enforcement budget with state 

or local funds at the conclusion of grant funding, over and above the number of locally funded sworn officer 

positions that would have existed in the absence of the grant. Absorbing TRGP-funded positions through 

attrition (rather than adding the extra positions to your budget with additional funding) does not meet the 

retention requirement.

Your agency should maintain documentation demonstrating when the 36-month grant funding period 

expires for each awarded position and that each retained position is above and beyond the number of 

officer positions that your agency would otherwise have funded with state or local funds. We understand 

that your agency’s identified source(s) of retention funding may change during the life of the grant, so 

your agency should maintain documentation of any changes in the event of an audit, monitoring, or other 

evaluation of your grant compliance.

Please note that your agency is required to retain the officer position(s) awarded under the TRGP-Hiring 

grant and not the specific officer(s) hired to fill the grant position(s). If a position funded by the TRGPHiring grant becomes vacant during the retention period, your agency is required to take active and timely 

steps consistent with your agency’s hiring policies and procedures to fill the position with a new officer to 

complete the remainder of the 12-month retention period. Your agency should maintain documentation 

demonstrating that you did not delay filling the position and that the steps your agency took to fill the 

position were consistent with your hiring policies and procedures.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

21

At the conclusion of federal funding, agencies that fail to retain the sworn officer positions awarded under 

the TRGP-Hiring grant may be ineligible to receive future COPS Office grants for a period of three years. If 

your agency is unable to retain any of the awarded officer positions, you should contact your COPS Office 

GPS for further review.

20. Employment eligibility

The grantee agrees to complete and keep on file, as appropriate, a Bureau of Citizenship and Immigration Services 

Employment Eligibility Verification Form (I-9). This form is to be used by recipients of federal funds to verify that 

persons are eligible to work in the United States.

Why this condition:

Under federal immigration law, all employers are required to take certain steps to ensure that persons that 

are hired are legally permitted to work in the United States. The Bureau of Citizenship and Immigration 

Services Employment Eligibility Verification Form (I-9) outlines the types of documents that an employer 

should review to confirm that a new hire is eligible for employment.

What you should do:

You do not need to submit any documentation to the COPS Office to satisfy this condition. Rather, you 

should complete and maintain the I-9 forms for all new employees under the guidelines set forth by the 

Bureau of Citizenship and Immigration Services. The I-9 form can be found at www.uscis.gov/files/form/i-9.

pdf. For further information about this requirement, you may contact the Bureau’s Office of Business Liaison 

at 800-357-2099 or the National Customer Service Center at 800-375-5283.

21. Debarment and suspension

The recipient agrees not to award Federal funds under this program to any party which is debarred or suspended 

from participation in Federal assistance programs.

Why this condition:

Under federal regulations, recipients are required to ensure that federal funds are not given to parties that 

are debarred or suspended from participation in federal assistance programs. This is to protect the public 

interest and to ensure proper management and integrity in federal activities by conducting business 

only with responsible parties. For details regarding the debarment and suspension requirements, please 

see 2 C.F.R. Part 180 (Government-wide Debarment and Suspension), and 2 C.F.R. Part 2867 (DOJ-specific 

requirements.)

What you should do:

If under a COPS Office award you enter into a contract for goods or services that is for $25,000 or more or 

any subaward, you must verify that the vendor or subawardee and their respective principals (e.g., owners, 

top managers) with whom you intend to do business are not excluded or disqualified from participation 

in federal assistance programs. In addition, you must include a term or condition in the contract or 

subaward requiring the vendor or subawardee to comply with subpart C of the OMB guidance in 2 C.F.R. 

Part 180 (Government-wide Debarment and Suspension) and subpart C of 2 C.F.R. Part 2867 (DOJ-specific 

requirements).

22. Whistleblower protection

The recipient agrees not to discharge, demote, or otherwise discriminate against an employee as reprisal for the 

employee disclosing information that he/she reasonably believes is evidence of gross mismanagement of a Federal 

contract or grant, a gross waste of Federal funds, an abuse of authority relating to a Federal contract or grant, a 

substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a Federal 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

22

contract (including the competition for or negotiation of a contract) or grant. The recipient also agrees to provide 

to their employees in writing (in the predominant native language of the workforce) of the rights and remedies 

provided in 41 U.S.C. § 4712. Please see Appendix E in the Grant Owner’s Manual for a full text of the statute.

Why this condition:

Under the “Pilot program for enhancement of contractor protection from reprisal for disclosure of certain 

information” (41 U.S.C. § 4712), which is in effect through January 1, 2017, recipients are prohibited from 

taking reprisal actions against employees for certain whistleblowing activities in connection with federal 

grants and contracts. The pilot program protects the public interest and ensures the proper management 

and use of federal funds.

What you should do:

The recipient must not take reprisal actions against an employee for disclosing misconduct under federal 

contracts and grants to certain persons and entities.

The recipient is prohibited from discharging, demoting, or otherwise discriminating against an employee as 

reprisal for disclosing information that he or she reasonably believes is evidence of 

•	 gross mismanagement of a federal contract or grant;

•	 a gross waste of federal funds;

•	 an abuse of authority relating to a federal contract or grant;

•	 a substantial and specific danger to public health or safety;

•	 a violation of law, rule, or regulation related to a federal contract (including the competition for or 

negotiation of a contract) or grant.

In addition, the disclosure must also have been made to

•	 a member of Congress or a representative of a committee of Congress; 

•	 an inspector general;

•	 the Government Accountability Office;

•	 a federal employee responsible for contract or grant oversight or management at the relevant agency;

•	 an authorized official of the U.S. Department of Justice or other law enforcement agency;

•	 a court or grand jury;

•	 a management official or other employee of the contractor, subcontractor, or grantee who has the 

responsibility to investigate, discover, or address misconduct.

An employee is deemed to have made a protected disclosure if he or she initiates or provides evidence 

of misconduct in any judicial or administrative proceeding relating to waste, fraud, or abuse on a federal 

contract or grant.

The recipient must inform its employees in writing, in the predominant language of the workforce, of 

employee whistleblower rights, protections, and remedies under 41 U.S.C. § 4712.

Please see appendix E on page 82 of this manual for a full text of the “Pilot program for enhancement of 

contractor protection from reprisal for disclosure of certain information” (41 U.S.C. § 4712).
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

23

23. Restrictions on internal confidentiality agreements

No recipient or subrecipient under this award, or entity that receives a contract or subcontract with any funds 

under this award, may require any employee or contractor to sign an internal confidentiality agreement or 

statement that prohibits or otherwise restricts the lawful reporting of waste, fraud, or abuse to an investigative or 

law enforcement representative of a federal department or agency authorized to receive such information.

Why this condition:

Under section 743 of Division E, Title VIII, of the Consolidated and Further Continuing Appropriations 

Act, 2015 (Pub. L. 113-235), neither the recipient, subrecipient, nor any entity that receives a contract or 

subcontract with any funds under this or any other Act may require its employees or contractors to sign an 

internal confidentiality agreement or statement prohibiting or otherwise restricting their lawful reporting 

of waste, fraud, or abuse to an investigative or law enforcement representative of a federal department 

or agency. This provision protects the public interest and ensures the proper management and use of 

federal funds. This limitation is not intended, and shall not be understood by the agency making this award, 

to contravene requirements applicable to Standard Form 312 (which relates to classified information), 

Form 4414 (which relates to sensitive compartmented information), or any other form issued by a federal 

department or agency governing the nondisclosure of classified information.

What you should do:

1. In accepting this award, the recipient

•	 represents that it neither requires nor has required internal confidentiality agreements or statements 

from employees or contractors that currently prohibit or otherwise restrict (or purport to prohibit or 

restrict) employees or contractors from reporting waste, fraud, or abuse as described above;

•	 represents that, if it learns or is notified that it is or has been requiring its employees or contractors to 

execute agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict) 

reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations 

of award funds, will provide prompt written notification to the agency making this award, and will 

resume such obligations only if expressly authorized to do so by that agency.

2. If the recipient does or is authorized to make subawards or contracts under this award, in accepting, the 

recipient

•	 represents that it has or will determine that no other entity that the recipient proposes may or will 

receive award funds (whether through a subaward, contract, or subcontract) either requires or has 

required internal confidentiality agreements or statements from employees or contractors that 

currently prohibit or otherwise restrict (or purport to prohibit or restrict) employees or contractors from 

reporting waste, fraud, or abuse as described above;

•	 represents that it has or will make appropriate inquiry, or otherwise has an adequate factual basis, to 

support this representation;

•	 represents that, if it learns or is notified that any subrecipient, contractor, or subcontractor entity that 

receives funds under this award is or has been requiring its employees or contractors to execute 

agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict) 

reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations 

of award funds to or by that entity, will provide prompt written notification to the agency making this 

award, and will resume (or permit resumption of ) such obligations only if expressly authorized to do so 

by that agency.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

24

24. Mandatory disclosure

The recipients and subrecipients must timely disclose in writing to the COPS Office or pass-through entity, as 

applicable, all federal criminal law violations involving fraud, bribery, or gratuity that may potentially affect the 

awarded federal funding. Failure to make required disclosures can result in any of the remedies, including suspension 

and debarment, described in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for 

Federal Awards, 2 C.F.R. § 200.338 as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101.

Why this condition:

Federal regulations require recipients and subrecipients to report all federal violations involving fraud, bribery, 

or gratuity that may affect the awarded federal funds. This condition advises your agency of the requirement 

and the consequences of failing to report such violations to the COPS Office or pass-through entity.

What you should do:

Ensure that you timely report in writing to the COPS Office or pass-through entity all federal violations 

involving fraud, bribery, or gratuity that may affect your federal award.

25. Conflict of interest

Federal awardees and subawardees must disclose in writing to the COPS Office or pass-through entity, as 

applicable, any potential conflict of interest affecting the awarded federal funding in accordance with the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.112 as 

adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101.

Why this condition:

Awardees and subawardees are required to use federal funding in the best interest of their award program. 

Any decisions related to these funds must be free of hidden personal or organizational conflicts of interest, 

both in fact and in appearance.

This means that awardees and subawardees should not participate in any award-related decisions or 

recommendations that involve any of the following people or groups: 

•	 An immediate family member

•	 A partner

•	 An organization in which they are serving as an officer, director, partner, or employee

•	 Any person or organization with whom they are negotiating or who has an arrangement concerning 

prospective employment, has a financial interest, or for other reasons can have less than an unbiased 

transaction with the awardee or subawardee

This also means that awardees and subawardees should avoid any action which might result in or create the 

appearance of

•	 using your official position for private gain;

•	 giving special treatment to any person;

•	 losing complete independence or objectivity;

•	 making an official decision outside official channels; or

•	 affecting negatively the confidence of the public in the integrity of the Federal Government or the 

program.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

25

What you should do:

Ensure that you report in writing to the COPS Office or pass-through entity, as applicable, any potential 

conflict of interest that may affect your federal award.

25. Contract provision 

All contracts made by the award recipients under the federal award must contain the provisions required under 2 

C.F.R. Appendix II to part 200 (Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under 

Federal Awards) as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101. Please see appendix F in the 

Grant Owner’s Manual for a full text of the contract provisions.

Why this condition:

Federal regulations require recipients and subrecipients to comply with the necessary contract provisions 

in order to standardize and strengthen oversight of all contracts made under federal awards. This provision 

protects the public interest and ensures the proper management and use of federal funds as it relates to 

contracts entered into by the recipient. 

What you should do:

The recipient should review all contracts made under the federal award to ensure that they contain the 

provisions required in appendix F of the Grant Owner’s Manual.

Review of grant conditions – Equipment/Training grants

By signing the award document to accept this TRGP-Equipment/Training grant, your agency agrees to abide 

by the following grant conditions:

1. Grant owner’s manual

The grantee agrees to comply with the terms and conditions in the 2015 COPS Office Tribal Resources Grant 

Program (TRGP) Owner’s Manual; COPS Office statute (42 U.S.C. § 3796dd, et seq.); 2 C.F.R. Part 200 (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by the U.S. 

Department of Justice in 2 C.F.R. § 2800.101; 48 C.F.R. Part 31 (FAR Part 31) (Contract Cost Principles and Procedures); 

other representations made in the TRGP grant application; and all other applicable program requirements, laws, 

orders, regulations, or circulars.

Why this condition:

This manual has been designed to inform you of the requirements, laws, regulations, and policies that apply 

to your grant. Your agency will be responsible for the information and rules contained in this manual and 

for implementing your grant in compliance with the applicable terms, conditions, and regulations. More 

detailed guidance regarding any particular grant requirement or your agency’s specific circumstances can 

be requested through your COPS Office Grant Program Specialist (GPS).

What you should do:

Please read the entire TRGP Grant Owner’s Manual carefully prior to signing the grant award document. If 

you have any questions, please contact your COPS Office GPS. When accepting your grant award, you should 

ensure that the proper reporting and financial systems are in place to satisfy the grant requirements.

2. Assurances and Certifications

The grantee acknowledges its agreement to comply with the Assurances and Certifications forms that were signed 

as part of its grant application.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

26

Why this condition:

Although the COPS Office has made every effort to simplify the process of applying for and receiving grants, 

several provisions of federal law require us to seek your assurances and certification regarding certain 

matters. Most of the assurances and certifications apply to all federal grant programs.

What you should do:

Applicants to COPS Office grant programs are required to sign the Assurances and Certifications forms at 

the time of application. Signing these documents assures the COPS Office that you have read, understood, 

and accepted the grant terms and conditions outlined in the Assurances and Certifications. Your agency 

is required to keep Assurances and Certifications forms that were signed as part of its grant application. 

Please read these documents carefully, because signatures on these documents are treated as a material 

representation of fact upon which reliance will be placed when the U.S. Department of Justice determines 

whether to award the covered grant. Additional copies of the Assurances and Certifications forms are 

contained in appendix B of this manual on page 71. If you have any questions about the Assurances and 

Certifications, please contact your COPS Office GPS at 800-421-6770.

3. Allowable costs

The funding under this project is for the payment of approved costs to meet the most serious needs of law 

enforcement in tribal communities. The allowable costs for which your agency’s grant has been approved are 

limited to those listed on the Financial Clearance Memorandum (FCM), which are included in your agency’s award 

package. The FCM specifies the exact items that your agency is allowed to fund with your TRGP grant, and specifies 

the overall amount approved for each budget request category. Your agency may not use TRGP grant funds for any 

costs that are not identified as allowable in the FCM.

Why this condition:

TRGP-Equipment/Training may only be used for the purchase of equipment, technology, training, uniforms, 

and other items approved by the COPS Office as reflected in the FCM. The COPS Office TRGP funds the 

purchase of items that have a link to the implementation or enhancement of community policing initiatives 

in your agency. 

To be eligible for payment under this grant, the purchase of approved items must be made after the grant 

award start date and comply with the guidelines described in section III, “Accessing Grant Funds,” on page 56 

of this manual. Section IV, “Financial Record Maintenance,” on page 59, outlines the types of records you must 

keep to document that you followed this grant condition. Purchases must also reflect the costs that were 

approved as shown in the FCM.

What you should do:

All grantees should keep and maintain the most recent, approved version of 2015 TRGP application, which 

will contain the approved costs for this grant. Refer to your FCM for the list of approved allowable costs. 

As long as funds are spent during the grant period on the approved salaries or benefits (as applicable), 

equipment, technology, training, or other costs that were documented in your application’s budget 

summary and were approved through the issuance of the FCM, this grant condition will be satisfied.

A. Allowable costs: Background investigations

Based on the FCM, grantees may have been awarded funding for background investigations for newly 

hired officer positions if other funding (state, local, or Bureau of Indian Affairs (BIA)) was not budgeted 

for the same background investigations. Background investigations must be completed before 

expenses incurred in connection with such investigations can be reimbursed. Funded background 

investigations may not be initiated prior to the official award start date of the grant period.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

27

B. Allowable costs: Training

Based on the FCM, grantees may have been awarded funding for otherwise unfunded expenses 

associated with sending recruits to a state academy that will train and certify tribal police officers, 

to the BIA Indian Police Academy in Artesia, New Mexico, or to basic training from an established 

academy that trains Indian police officers such as the Navajo Nation’s Academy. Basic law 

enforcement training is encouraged for existing police officers who have not received it, depending 

on the needs of your department and the availability of funding. Grant funding may only be used 

for one cycle of basic training per officer. The grantee agency will be responsible for any additional 

costs associated with an officer not completing basic training on the first attempt.

TRGP funds may also pay for community policing and problem-solving training; specialized law 

enforcement training in such topics as counterterrorism, family violence, and crime prevention and 

detection; and training related to Indian Country jurisdictional issues. Only requests for training 

by recognized training providers such as the Federal Law Enforcement Training Center, the FBI, 

the BIA Indian Police Academy, a state police academy, COPS Office Regional Community Policing 

Institutes, or a tribal community college will be considered. In addition, funding may be used to 

attend training conferences such as the National Native American Law Enforcement Association’s 

annual training conference or any COPS Office-sponsored conference.

Funding for community policing or other law enforcement training will cover only travel, 

lodging, and per diem expenses for each representative to and from the training site (if training 

is conducted more than 50 miles from your agency headquarters). State academy training costs 

include training instruction fees, academy tuition, course fees, textbooks, manuals, supplies, and 

travel in connection with the training (transportation, lodging, per diem, etc.) if the training is 

located more than 50 miles from the job site. If your state academy does not charge for the training, 

your department will be reimbursed only for travel in connection with the training. Departments 

that send officers to the BIA Indian Police Academy will be reimbursed for travel costs only, as there 

is no cost for tuition at the BIA Indian Police Academy for tribal officers.

TRGP-E/T funds may pay for computer training for systems, hardware, or software that grantees 

already own but may not be utilizing to the fullest extent due to of a lack of training. Applicants 

must demonstrate that the training enhances law enforcement activities, particularly in support of 

community policing. TRGP-E/T funding may be used only for training costs not already funded in 

the applicant’s budget with state, local, or BIA funds.

In addition, TRGP-E/T funding may be used for off-site training required to increase tribal capacity 

to operate a crime information gathering system compatible with the FBI Uniform Crime Reporting 

System.

C. Allowable costs: Uniforms and basic issue equipment

Any bulletproof vest purchased under TRGP-E/T must meet National Institute of Justice standards 

as shown on the list of acceptable vests included in appendix D of this manual on page 80.

D. Allowable costs: Technology

To be eligible for payment under this grant, the purchase of equipment and technology must occur 

on or after the award start date, the items must be those specifically applied for and approved by 

the COPS Office, and the items must meet the guidelines described in 2 C.F.R. Part 200 (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted 

by the U.S. Department of Justice in 2 C.F.R. § 2800.101. Equipment or technology purchased on or 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

28

after the award start date must be in addition to purchases that the grantee is obligated or funded to 

make in its current budget. Funds currently allocated to purchase equipment or technology may not 

be reallocated to other purposes or reimbursed upon the award of your agency’s TRGP-E/T grant.

E. Allowable costs: Police vehicles

Allowable items include police cars, basic vehicle accessory packages, and special conveyances 

such as sport utility vehicles, bicycles, motorcycles, snowmobiles, and all-terrain vehicles (ATV). The 

items must be those specifically applied for and approved by the COPS Office.

F. Allowable costs: Travel

Travel costs for transportation, lodging, subsistence, and related items are allowable under your 

agency’s TRGP-E/T grant if specifically approved by the COPS Office. In accordance with 2 C.F.R. 

§200.474, travel costs for official business directly related to the award will be reimbursed based upon 

the grantee’s written travel reimbursement policies if the costs are reasonable and allocable under 

the project. In the absence of an acceptable written policy regarding travel costs, allowable rates and 

amounts established by the U.S. General Services Administration (GSA) for the relevant geographic 

area will apply. The current GSA travel policy and per diem rates can be found at www.gsa.gov.

Allowable airfare costs will be reimbursed based upon the least expensive unrestricted 

accommodations class offered by commercial airlines—for example, lowest discount commercial 

airfare, the Federal Government contract airfare (if authorized and available), or standard coach 

airfare—unless otherwise authorized in advance by the COPS Office.

For grantees subject to 48 C.F.R. Part 31.000, et seq. (FAR-31.2) Cost Principles for Commercial 

Organizations, travel costs incurred directly by the grantee will be reimbursed if the costs are 

reasonable and allocable under the project. Travel costs for lodging, meals, and incidental expenses 

may be reimbursed based upon per diem, actual expenses, or a combination of these methods, as 

long as the reimbursement rate does not exceed established GSA per diem rates as set forth in the 

Federal Travel Regulation. Transportation costs may be reimbursed based on mileage rates, actual 

costs incurred, or a combination of these methods. Allowable airfare travel costs will be reimbursed 

based upon standard coach fare, unless otherwise authorized in advance by the COPS Office.

The COPS Office TRGP-E/T will fund grant-related travel costs for the grantee agency or other (nongrantee) individuals to attend training and technical assistance conferences, seminars, or classes, or 

to visit a site specified in the application. Allowable expenses for grant-related lodging, meals, and 

incidental expenses that were included in the application have been approved by the COPS Office 

as part of the TRGP-E/T award and final budget. Your agency should keep timely and accurate 

records of all travel expenses. If at any time these costs change, you should immediately contact 

your COPS Office GPS to obtain a grant modification.

Temporary dependent care costs above and beyond regular dependent care that directly results 

from conference travels are allowable as long as the costs incurred (1) are a direct result of the 

individual’s travel for the federal award; (2) are consistent with the recipient’s documented travel 

policy for all entity travel; and (3) are only temporary during the travel period.

G. Allowable costs: Supplies

All supplies must be solely used for the project identified in your project proposal. Reimbursements 

for office supplies that are consumed by routine administrative purposes instead of project-related 

activities are prohibited. Items must meet the guidelines described in 2 C.F.R. Part 200 (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as 

adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101. 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

29

H. Allowable costs: Contracts/consultants

Compensation for individual consultant services procured under a COPS Office grant must be 

reasonable and allocable in accordance with 2 C.F.R. Subpart E—Cost Principles and consistent with 

that paid for similar services in the marketplace. Unless otherwise approved by the COPS Office, 

consultant rates will be based on the salary a consultant receives from his or her primary employer, 

as applicable, up to $550 per day. For consultant or contractor rates which exceed $550 per day, the 

COPS Office requires written justification if the consultants or contractors are hired through a noncompetitive bidding process and grantees must receive COPS Office approval of those rates before 

drawing down grant funds. Determinations will be made on a case-by-case basis.

I. Allowable costs: Other costs

The purchases of project-related expenditures that do not conform to any other category 

descriptions specified above were included in this section of your FCM. In addition, items that have 

a direct correlation to the overall success of a grantee’s project objectives and are necessary for the 

project to reach full implementation are considered on a case-by-case basis by the COPS Office.

Requests may be made only for items or positions that are not otherwise budgeted with state, 

local, or BIA funds, and would not be funded in the absence of the TRGP grant.

Allowable costs: Indirect costs

Indirect costs are costs that are incurred for common or joint purposes and are not readily assignable to 

a particular project but are necessary to the operation of the agency and the performance of the project. 

Examples of indirect costs include those incurred for facility operation and maintenance, depreciation, and 

administrative salaries. Indirect cost usage must adhere to the standards set forth in the applicable Office of 

Management and Budget (OMB) uniform guidance 2 C.F.R. Part 200.56—Indirect (facilities & administrative 

(F&A)) costs and 2 C.F.R. Part 200.414—Indirect (F&A) costs. Additional guidance for your entity can be found 

in the following locations: Appendix III to Part 200—Indirect (F&A) Costs Identification and Assignment, and 

Rate Determination for Institutions of Higher Education (IHEs); Appendix IV to Part 200—Indirect (F&A) Costs 

Identification and Assignment, and Rate Determination for Nonprofit Organizations; Appendix VII to Part 

200—States and Local Government and Indian Tribe Indirect Cost Proposals.

Indirect cost rates are federally negotiated and approved rates that are based on audited and documented 

expenses that are approved to be included within an indirect cost rate. It is important that your agency 

carefully track and update its indirect cost rate during the COPS Office grant award period.

The grantee understands that if it submitted an expired indirect cost rate agreement at the time of application, 

it will be unable to recover federal funds for indirect costs until the COPS Office receives a current indirect cost 

rate agreement covering the award period. A special condition may be added to the award prohibiting the 

obligation, expenditure, or drawdown of funds reimbursement for indirect costs until a current indirect cost 

rate has been approved by your cognizant federal agency and submitted to the COPS Office.

If your agency’s approved indirect cost rate expires during the grant award period, a current approved rate 

must be submitted to the COPS Office in order to continue to draw down grant funding for indirect costs. 

Your agency must advise the COPS Office in writing of any changes to your approved indirect cost rate 

during the grant award period and must request a budget modification with the COPS Office to reflect any 

rate change.

If your agency has never received a negotiated indirect cost rate, then you may request up to a flat 10 

percent de minimis indirect cost rate applied to the modified total direct costs (MTDC). 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

30

In addition, before the COPS Office officially closes out your agency’s grant award, your agency must 

reconcile any changes between your approved final indirect cost rate and approved provisional indirect cost 

rate and, if necessary, repay the COPS Office for any indirect cost rate overpayment. If your agency draws 

down excess COPS Office grant funding for indirect costs, please return the overpayment to the COPS Office 

and submit a revised Federal Financial Report (SF-425).

See the COPS Office website for a fact sheet on indirect costs, http://www.cops.usdoj.gov/

pdf/2015AwardDocs/cpd/Indirect_Cost_Rate_Fact_Sheet.pdf.

4. Travel costs

Travel costs for transportation, lodging and subsistence, and related items are allowable under the TRGP with 

prior approval from the COPS Office. Payment for allowable travel costs will be in accordance with 2 C.F.R. Part 200 

(Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by 

the U.S. Department of Justice in 2 C.F.R. § 2800.101, and 48 C.F.R. Part 31. (FAR-31, Cost Principles for Commercial 

Organizations), as applicable.

Why this condition:

The CTAS Program will fund grant-related travel costs for the grantee agency or other (non-grantee) individuals 

to attend training and technical assistance conferences, seminars, or classes or to visit a site specified in the 

original application. Allowable expenses for grant-related lodging, meals, and incidental expenses that were 

included in the application were approved by the COPS Office as part of your agency’s CTAS award and final 

budget. For more information, please refer to award condition #3 on page 28, “Allowable Costs.”

What you should do:

Your agency should refer to your FCM for a list of approved travel costs and use CTAS funds only for those 

approved travel costs incurred during the grant period. In addition, your agency should keep timely and 

accurate records of all travel expenses. If at any time these costs change, you should immediately contact 

your COPS Office Grant Program Specialist. 

5. Supplementing, not supplanting

State, local, and tribal governments must use TRGP grant funds to supplement, and not supplant, state, local, or BIA 

funds that are already committed or otherwise would have been committed for grant purposes (hiring, training, 

purchases, and/or activities) during the grant period. In other words, grantees may not use COPS Office funds to 

supplant (replace) state, local, or BIA funds that would have been dedicated to the COPS Office-funded item(s) in 

the absence of the COPS Office grant.

Why this condition:

The COPS Office statutory nonsupplanting requirement mandates that grant funds may not be used to 

replace state or local funds (or, for tribal grantees, BIA funds) that would, in the absence of federal aid, be 

made available for the grant purposes.

What you should do:

TRGP-E/T grantees may not use grant funds to pay for any item or cost funded under the grant (equipment, 

personnel, training, etc.) if that item or cost was otherwise budgeted with state, local, or BIA funds or 

committed to the grantee’s budget.

In addition, grantees may not reallocate state, local, or BIA funds from one area within the law enforcement 

budget to another as a result of receiving TRGP grant funds. For example, grantees who have budgeted 

funds to pay for new computer equipment may not reallocate those funds to pay for any other law 

enforcement cost as a result of receiving TRGP-E/T grant funds for the same computer equipment.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

31

TRGP Equipment and Training—To meet this grant condition, you must ensure the following:

•	 Equipment and technology must be purchased on or after the award start date (unless an exception 

is authorized in writing by the COPS Office) and must be in addition to purchases that the grantee has 

obligated funding in the current budget to make. Funds currently allocated to purchase equipment 

or technology may not be reallocated to other purposes or reimbursed upon the award of a TRGP-E/T 

grant. For example, grantees who have budgeted local funds to pay for a new computer system may 

not reallocate those funds to pay for any other law enforcement cost as a result of receiving TRGP-E/T 

funds for the same computer system.

•	 Any training covered by TRGP-E/T funds is in addition to the number of hours of training already 

provided by your agency. Funds currently allocated for training may not be reallocated to other 

purposes.

Note: This grant condition applies to all state or locally funded agencies working in partnership with your 

agency under this grant. Your agency is responsible for ensuring that any partner agencies use COPS Office 

funds only to supplement, not supplant, their state, local, or BIA funding as described in this condition.

6. Extensions

Your agency may request an extension of the grant award period to receive additional time to implement your 

grant program. Such extensions do not provide additional funding. Grants may be extended a maximum of 36 

months beyond the initial award expiration date. Any request for an extension beyond 36 months will be evaluated 

on a case-by-case basis. Only those grantees that can provide a reasonable justification for delays will be granted 

no-cost extensions. Reasonable justifications may include technology implementation delays, training delays, 

or other circumstances that interrupt the 36-month grant funding period. An extension allows your agency to 

compensate for such delays by providing additional time to complete the full 36 months of funding. Extension 

requests must be received prior to the end date of the award.

Why this condition:

Under federal regulations, requests to extend the grant award period require prior written approval from the 

COPS Office. Without an approved extension, your agency is not permitted to draw down federal funding 

for costs incurred beyond the official grant award end date. However, if justified, the COPS Office seeks to 

accommodate reasonable requests for no-cost time extensions in order to fully implement the COPS Office grant.

What you should do:

The COPS Office will contact your agency during the last quarter of the grant award period to determine 

whether a no-cost time extension is needed; extensions will not be processed prior to 90 days of the grant 

end date. Requests to extend the grant award period must be received by the COPS Office before the official 

grant award end date. Extension requests received after the expiration date will be considered only when 

the grantee provides justification of extraordinary circumstances; an example of this would be an instance 

in which an unforeseen natural disaster prevented a grantee from requesting an extension. Failure to submit 

a request for a no-cost time extension by the end date may result in the immediate deobligation of any 

remaining grant funds.

Automatic extensions will be granted for grantee requests of six months or less. All extension requests 

beyond six months will require review and approval by the COPS Office. Individual or cumulative requests 

greater than one-half of the grant’s original term (i.e., 18 months) will require additional justification and 

must include a detailed timeline.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

32

If your agency has excess funds remaining at the end of the grant due to salary and fringe benefits costs that 

were lower than anticipated, your agency may not extend the 36-month funding period for the purpose of 

expending those excess funds. Grantees are entitled to a maximum of 36 months of federal funding based 

on the approved salary and fringe benefits costs in the FCM. The COPS Office will deobligate any remaining 

grant funds during the closeout process. If you have any additional questions regarding a no-cost time 

extension, please contact your COPS Office Grant Program Specialist.

7. Modifications

Occasionally, a change in an agency’s fiscal or law enforcement situation necessitates a change in its TRGP award. 

Grant modifications under TRGP are evaluated on a case-by-case basis. All modification requests involving the 

purchase of new budget items must be approved, in writing, by the COPS Office prior to their implementation. In 

addition, please be aware that the COPS Office will not approve any modification request that results in an increase 

of federal funds.

Why this condition:

The COPS Office realizes that agencies may need to reprogram grant funds. Acceptable examples of such 

award modifications include purchasing additional equipment using cost savings from approved items 

or purchasing a different type of equipment due to changing needs. Under federal regulations, you may 

expend grant funds only as approved in the FCM. Any requests to change or alter grant awards require 

written approval from the COPS Office prior to their implementation. Without prior written approval, you 

must continue to implement your grant as it was originally awarded and accepted by your agency. Please be 

advised that reprogramming requests for unallowable costs (e.g., construction) will not be approved.

What you should do:

For all modifications, your agency must access www.cops.usdoj.gov and select the “Account Access” link 

in the upper right corner to log in and submit your request to the COPS Office, providing the proposed 

changes, details of why the change is needed, etc.

For additional information about the process for submitting your specific grant modification request, please 

contact your COPS Office Grant Program Specialist at 800-421-6770. The COPS Office will then evaluate your 

request and notify your agency of our decision in writing. Implementation of the modified grant award 

may begin following written approval from the COPS Office. Please note that modification approvals for 

active grants will often be accompanied by a modified award document reflecting the approved changes. 

If applicable, your agency is required to sign and submit the modified award document via the Account 

Access link to officially accept the grant modification.

8. Evaluations

The COPS Office may conduct monitoring or sponsor national evaluations of the COPS Office TRGP. The grantee 

agrees to cooperate with the monitors and evaluators.

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 states that evaluations of the program 

may be carried out or commissioned by the Attorney general for the furtherance of the purposes of the 

Act. The COPS Office conducts evaluations to determine which programs are working, how programs may 

be improved, and why certain programs are more successful than others. Specifically, the COPS Office 

may assess the way in which your agency implements its grant. In some jurisdictions, COPS Office staff or 

evaluators may study the effectiveness of funded programs, projects, and activities. Evaluators may collect 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

33

information about the programs’ effect on crime, victims of crime, and the quality of life in communities. In 

addition, they may ask questions about the challenges encountered during project implementation, how 

residents feel about community policing, and how police feel about their work. This information will be 

useful to other communities and police agencies across the country.

What you should do:

When evaluations are undertaken, you may be contacted in writing with specific requests for information. 

In general, evaluators may need to speak with individuals in your agency or department, observe activities, 

and obtain written reports about and from your agency or department. You will be asked to facilitate 

any site visits and information-gathering activities. In addition, you will be asked to provide accurate and 

timely information about your grant activities. You should fully comply with any requests regarding these 

evaluations.

9. Reports/Performance goals

To assist the COPS Office in monitoring and tracking the performance of your award, your agency will be 

responsible for submitting quarterly programmatic progress reports that describe project activities during the 

reporting period and quarterly Federal Financial Reports using Standard Form 425 (SF-425). The progress report is 

used to track your agency’s progress toward implementing community policing strategies and to collect data to 

gauge the effectiveness of increasing your agency’s community policing capacity through COPS Office funding. 

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 and other federal regulations and policies 

require that financial assistance provided by the Federal Government be monitored carefully to ensure 

the proper use of federal funds. In addition, the COPS Office seeks to document, on a continuing basis, the 

progress of our programs and grantees.

What you should do:

This grant condition is designed to make your agency aware of reporting requirements associated with TRGP 

grants. Quarterly programmatic progress reports and a final programmatic closeout report will be required 

to be submitted directly to the COPS Office through the “Account Access” portion of the COPS Office 

website at www.cops.usdoj.gov. Your agency is also required to submit quarterly Federal Financial Reports 

using Standard Form 425 (SF-425) within 30 days after the end of each calendar quarter. A final SF-425 will 

be due within 90 days after the end of the grant period. This report reflects the actual cumulative federal 

expenditures incurred during the funding period, and the remaining unobligated balance of federal funds. 

Under federal regulations, your agency is not permitted to draw down federal funding for costs incurred 

after the official grant end date, however you will have a 90-day grace period after the grant award end 

date during which you can drawdown funds for eligible expenditures incurred before the grant end date.. 

Agencies with more than one delinquent programmatic or financial report submission per fiscal year may 

be subject to delays in receiving reimbursement for allowable expenses and may be required to receive 

technical assistance to improve compliance with reporting. These reports are discussed in greater detail in 

section VI, “Reports,” on page 64 of this manual. All reports should be submitted within the deadlines given to 

avoid suspension or possible termination of grant funds or other remedial actions; failure to submit required 

reports may also impact future funding opportunities.

10. Grant monitoring activities

Federal law requires that law enforcement agencies receiving federal funding from the COPS Office must be 

monitored to ensure compliance with their grant conditions and other applicable statutory regulations. The COPS 

Office is also interested in tracking the progress of our programs and the advancement of community policing. 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

34

Both aspects of grant implementation—compliance and programmatic benefits—are part of the monitoring 

process coordinated by the U.S. Department of Justice. Grant monitoring activities conducted by the COPS Office 

include site visits, office-based grant reviews, alleged noncompliance reviews, financial and programmatic 

reporting, and audit resolution. As a COPS Office TRGP grantee, you agree to cooperate with and respond to any 

requests for information pertaining to your grant.

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 states that each grant program must 

contain a monitoring component. The COPS Office actively monitors how grantees are adhering to COPS 

Office grant requirements.

What you should do:

Your agency may be required to accommodate routine and non-routine efforts by the COPS Office, or an 

entity designated by the COPS Office, to examine your agency’s use of federal funds, both programmatically 

and financially. The most common ways are as follows:

•	 site visits. The COPS Office conducts awardee site visits to ensure compliance with award terms 

and conditions. These visits also provide firsthand observation of the awardee’s community policing 

strategies. The purpose of site visits is threefold: review community policing activities, ensure awardee 

compliance, and provide customer service and technical assistance. If selected, you will be notified in 

writing in advance of any on-site review of your COPS Office awards. This review is generally performed 

over one or more days and also provides an opportunity for your agency representatives to seek 

assistance on any award implementation issues. 

•	 enhanced office-based grant reviews (EOBGR). In lieu of a site visit, certain grants are selected for 

a review conducted at the COPS Office via teleconference or video conference. EOBGRs serve as a 

supplemental activity in support of the COPS Office’s overall grant monitoring strategy. The purpose 

of the EOBGR is threefold: review community policing activities, ensure grantee compliance, and 

provide customer service and technical assistance. If selected, you will be notified in writing in advance 

of any EOBGR of your COPS Office grants. This review is generally performed over a one or more day 

period and also provides an opportunity for agency representatives to seek assistance on any grant 

implementation issues. Your agency will be notified in writing of the results and any action required 

to remedy identified grant violations to include potential and actual vulnerabilities. Additionally, 

promising practices identified during the EOBGR are documented and may be shared with the law 

enforcement community.

•	 alleged noncompliance reviews (ANCR) . An alleged noncompliance review is a follow up on 

complaints of alleged noncompliance received from external (media and/or citizen complaints) or 

internal (COPS Office/DOJ staff ) sources. On a case-by-case basis, COPS Office staff members determine 

the appropriate course of action to take to investigate complaints of alleged noncompliance. This may 

include phone or letter contact or a site visit by COPS Office staff or the Office of the Inspector General.

•	 audit liaison. The U.S. Department of Justice, Office of Inspector General (OIG) conducts random 

audits for all COPS Office grantees. In the event your agency has any audit recommendations (finding) 

resulting from noncompliance and/or poor accounting practices, the COPS Office Audit Liaison 

Section will work with your agency to resolve and close these recommendations. Remedies to close 

recommendations may include repayment of grant funds and/or the submission of documentation. 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

35

Grantees are responsible for remedying any grant noncompliance that is identified during site visits, 

office-based grant review, and/or alleged noncompliance reviews. In addition, grantees are responsible 

for remedying noncompliance stemming from audit recommendations identified in audits of COPS Office 

grants conducted by the Office of Inspector General (OIG) and the Office of the Chief Financial Officer 

(OCFO). Remedies for noncompliance may include but are not limited to suspending active grant funding, 

repayment of unallowable or unsupported costs, voluntary withdrawal from or involuntary termination 

of remaining grant funds, or restriction from receiving future grants for a period of time. Under certain 

conditions, additional actions may include placement on the U.S. Department of Justice’s High Risk List, 

which will include mandatory completion of the Office of Justice Programs Financial Management Training 

and being subject to increased monitoring of current and future grants while on the list. In the event of 

criminal misuse of grant funds, grantees may also be subject to fines and imprisonment. To avoid findings 

of noncompliance, grantees are strongly encouraged to become familiar with the COPS Grant Monitoring 

Division’s Grant Monitoring Standards and Guidelines and with the Grant Owner’s Manual for the year 

in which the grant is awarded. Grantees should also contact the COPS Office or their Grant Program 

Specialist at any time during the life of a COPS Office grant with questions concerning grant conditions, 

terms, or requirements to seek guidance to avoid noncompliance. It is necessary for grantees to maintain 

all relevant documentation (administrative, financial, and programmatic) used to develop the application 

and implement the grant that may be necessary or required to demonstrate grant compliance. For more 

information, please contact the COPS Office Response Center at 800-421-6770 or at AskCopsRC@usdoj.gov.

11. Federal civil rights

As a condition of receipt of federal financial assistance, you acknowledge and agree that you will not (and will 

require any sub-grantees, contractors, successors, transferees, and assignees not to), on the grounds of race, color, 

religion, national origin (which includes providing limited English proficient persons meaningful access to your 

programs), sex, disability, or age, unlawfully exclude any person from participation in, deny the benefits of or 

employment to any person, or subject any person to discrimination in connection with any programs or activities 

funded in whole or in part with federal funds. These civil rights requirements are found in the non-discrimination 

provisions of Title VI of the Civil Rights Act of 1964, as amended (42 U.S.C. § 2000d); the Omnibus Crime Control and 

Safe Streets Act of 1968, as amended (42 U.S.C. § 3789d); Section 504 of the Rehabilitation Act of 1973, as amended 

(29 U.S.C. § 794); the Age Discrimination Act of 1975 (42 U.S.C. §6101, et seq.); Title IX of the Education Amendments 

of 1972, as amended (20 U.S.C. § 1681, et seq.); and the corresponding DOJ regulations implementing those 

statutes at 28 C.F.R. Part 42 (subparts C, D, E, G, and I). You also agree to comply with Executive Order 13279 Equal 

Treatment for Faith-Based Organizations and its implementing regulations at 28 C.F.R. Part 38, which requires 

equal treatment of religious organizations in the funding process and non-discrimination of beneficiaries by FaithBased Organizations on the basis of belief or non-belief.

Why this condition:

In establishing financial assistance programs, Congress linked the receipt of federal funding to compliance 

with federal civil rights laws. As a result, grantees are required to comply with the civil rights requirements 

found in the non-discrimination provisions referenced above. A hold may be placed on your award if it is 

deemed that your agency is not in compliance with federal civil rights laws or is not cooperating with an 

ongoing federal civil rights investigation. If a hold is placed on your award, you will not be able to obligate 

or draw down federal funds under your agency’s COPS Office grant award until you comply with federal civil 

rights laws or cooperate with any ongoing federal civil rights investigation.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

36

What you should do:

As a recipient of federal financial assistance from the COPS Office, you are required to comply with the 

applicable federal civil rights laws and to collect data and information sufficient to permit effective 

enforcement of such laws and to cooperate with any federal civil rights investigation, which includes 

providing access to records, accounts, documents, information, facilities, and staff.

12. Equal employment opportunity plan

All recipients of funding from the COPS Office must comply with the federal regulations pertaining to the 

development and implementation of an Equal Employment Opportunity Plan (28 C.F.R. Part 42 subpart E).

Why this condition:

It is the experience of the U.S. Department of Justice in implementing its responsibilities under the Omnibus 

Crime Control and Safe Streets Act of 1968 (Safe Streets Act), the statute that established the COPS Office, 

that “the full and equal participation of women and minority individuals in employment opportunities in 

the criminal justice system is a necessary component to the Safe Streets Act’s program to reduce crime and 

delinquency in the United States” 28 C.F.R. § 42.301. The Equal Employment Opportunity Plan (EEOP) does 

not impose quotas or hiring requirements on recipients of federal funds.

What you should do:

The obligations to comply with the EEOP requirement differ depending on your organization’s legal status, 

the number of its employees, and the amount of the award.

If your organization has fewer than 50 employees or receives an award of less than $25,000 or is a nonprofit 

organization, a medical institution, an educational institution, or an Indian tribe, then it is exempt from the 

EEOP requirement. To claim the exemption, your organization must complete and submit section A of the 

Certification Form to the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice, 

810 7th Street NW, Washington, DC 20531. The Certification Form can be found at http://www.ojp.usdoj.gov/

about/ocr/pdfs/cert.pdf.

If your organization is a governmental agency or private business and has received an award between 

$25,000 and $500,000 and has 50 or more employees (counting both full- and part-time employees but 

excluding political appointees), then it must prepare a Utilization Report (formerly called an EEOP Short 

Form), but it does not need to submit it to the OCR for review. Instead, your organization must maintain 

the Utilization Report on file and make it available to the OCR for review on request. In addition, your 

organization must complete and submit section B of the Certification Form to the Office for Civil Rights 

(OCR), Office of Justice Programs, U.S. Department of Justice, 810 7th Street NW, Washington, DC 20531. The 

Certification Form can be found at www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf.

If your organization is a governmental agency or private business and has received an award for $500,000 or 

more and has 50 or more employees (counting both full- and part-time employees but excluding political 

appointees), then it must prepare a Utilization Report (formerly called an EEOP Short Form) and submit it 

to the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice, 810 7th Street 

NW, Washington, DC 20531 for review within 60 days of the notification of the award. In addition, your 

organization must complete and submit section C of the Certification Form to the OCR. The Certification 

Form can be found at www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf.

For assistance in developing a Utilization Report, please consult the OCR’s website at www.ojp.usdoj.

gov/about/ocr/eeop.htm. To comply with the EEOP requirements, you may request technical assistance 

from an EEOP specialist at the OCR by telephone at 202-307-0690, by TTY at 202-307-2027, or by e-mail at 

EEOsubmissions@usdoj.gov.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

37

13. Community policing

Community policing activities to be initiated or enhanced by your agency were identified and described in your 

grant application. All equipment, technology, training, and/or sworn officer positions awarded under the TRGP 

grant must be linked to the implementation or enhancement of community policing.

Why this condition: 

The COPS Office defines community policing as a philosophy that promotes organizational strategies that 

support the systematic use of partnerships and problem-solving techniques to proactively address the 

immediate conditions giving rise to public safety issues such as crime, social disorder, and fear of crime. 

TRGP grants must be used to initiate or enhance community policing activities. All newly hired, additional, or 

rehired officers (or an equal number of redeployed veteran officers) funded under TRGP-Hiring must engage 

in community policing activities. While the COPS Office recognizes that your COPS Office-funded officer(s) 

(or an equal number of redeployed veteran officers) will participate in some or all aspects of your identified 

community policing plan and advance your agency’s community policing activities over the life of the grant, 

we also encourage your agency to move toward an organization-wide philosophy and commitment to 

community policing.

COPS Office grants are designed to increase community policing capacity and crime prevention efforts. 

This is achieved through problem-solving tactics and community policing partnerships. It enhances police 

professionalism by providing officers with the skills and motivation to act in innovative ways to solve 

community crime-related problems. Your organization may be monitored or audited to ensure that it is 

initiating or enhancing community policing in accordance with your proposed plan, and that the officers 

hired (or an equal number of redeployed veteran officers) are used to implement this plan and advance 

your agency’s community policing activities over the life of the grant. The COPS Office may also use this 

information to understand the needs of the field, and potentially provide for training, technical assistance, 

problem solving, and community policing implementation tools. 

What you should do: 

Community policing activities to be implemented or enhanced by your agency were identified in your grant 

application. Your community policing needs may change during the life of your grant, and minor changes to 

this plan may be made without prior approval of the COPS Office. If your agency’s community policing plan 

changes significantly, however, you must submit those changes in writing to the COPS Office for approval. 

Changes are significant if they deviate from the range of possible community policing activities identified 

and approved in the original community policing plan submitted with your application.

14. Contracts with other jurisdictions

Equipment, technology, training, vehicles, and/or sworn law enforcement officer positions awarded may only be 

used for law enforcement activities or services that exclusively benefit your agency and the population that it serves. 

The items funded under the TRGP grant cannot be utilized by other agencies unless the items would exclusively 

benefit the population that your agency serves.

Why this condition:

The TRGP was created under a Congressional appropriation specifically designated for tribal law 

enforcement agencies to improve public safety in Indian communities. The TRGP-E/T grant funding is 

intended to benefit the communities within the grantee’s primary law enforcement jurisdiction. Therefore, 

the grantee must use the TRGP grant funding to benefit its own population exclusively.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

38

What you should do:

Your law enforcement agency should avoid any agreements with other jurisdictions to share officer 

positions or other awarded equipment, technology, or vehicles, unless the agreement complies with the 

requirement that COPS Office-funded items must exclusively benefit the grantee service population. For 

example, if your jurisdiction has both a tribal police department and a BIA department, items funded under 

the grant might be able to be used by the BIA department as long as this would result in an exclusive 

benefit to the population that you serve. You may not, however, allow officers, equipment, technology, or 

vehicles funded under the grant to be utilized by any agency or transferred to any agency that does not 

exclusively benefit the population that you serve. For example, you may not, during the grant term, loan two 

of your awarded computers to a neighboring county’s sheriff’s department.

Before you enter into any agreement with another law enforcement agency, you should contact your COPS 

Office Grant Program Specialist (GPS) at 800-421-6770 for additional guidance.

15. False statements

False statements or claims made in connection with COPS Office grants may result in fines, imprisonment, or 

debarment from participating in federal grants or contracts, and/or any other remedy available by law.

Why this condition:

This condition advises recipients of the consequences of submitting false claims or statements on 

applications, financial and programmatic reports, or other grant documents.

What you should do:

Ensure that all documentation related to your agency’s receipt and use of grant funding (grant applications, 

progress reports, Federal Financial Reports, etc.) is true and accurate.

16. Duplicative funding

The recipient understands and agrees to notify the COPS Office if it receives, from any other source, funding for the 

same item or service also funded under this award.

Why this condition:

This grant was awarded to your agency to address its law enforcement needs that are not funded with other 

funds, including federal, state, local, tribal, or BIA funds. Consequently, your agency may not use this funding 

for items or services that you already have funding for from other sources.

What you should do:

If your agency receives funding from another source for the same item(s) or services(s) also funded under 

this award, please contact your COPS Office GPS at 800-421-6770. If necessary, the COPS Office will work 

with your agency to reprogram funding for items or services that are allowable under this grant program.

17. Additional high-risk grantee requirements

The recipient agrees to comply with any additional requirements that may be imposed during the grant 

performance period if the awarding agency determines that the recipient is a high-risk grantee (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.207 as 

adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101).
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

39

Why this condition:

In accordance with 2 C.F.R. § 200.207, the U.S. Department of Justice (DOJ) may impose additional 

requirements specific to your award, as needed, when it determines that there is unsatisfactory performance, 

financial or administrative instability, noncompliance with award terms and conditions, or other lack of 

responsibility risk factors. In such cases, the U.S. Department of Justice may impose special conditions or 

restrictions that may include requiring the production of documentation, financial grant administration 

training, onsite monitoring, prior approval for expenditure of funds, quarterly progress reports, separate bank 

accounts, or other requirements.

What you should do:

In order to obtain a COPS Office grant, recipients must agree to comply with any additional requirements 

that may be imposed during the grant performance period if the awarding agency determines that the 

recipient is a high-risk grantee.

18. System for Award Management and Universal Identifier requirements

The Office of Management and Budget requires federal agencies to include the following standard award term in 

all grants and cooperative agreements made on or after October 1, 2010:

A. Requirement for System for Award Management (SAM)

Unless you are exempted from this requirement under 2 C.F.R. Part 25.110, you as the recipient must 

maintain the currency of your information in the SAM until you submit the final financial report required 

under this award or receive the final payment, whichever is later. This requires that you review and update 

the information at least annually after the initial registration, and more frequently if required by changes in 

your information or another award term.

B. Requirement for Data Universal Numbering System (DUNS) Numbers

If you are authorized to make subawards under this award, you:

1. Must notify potential subrecipients that no entity (see definition in paragraph C of this award term) 

may receive a subaward from you unless the entity has provided its DUNS number to you.

2. May not make a subaward to an entity unless the entity has provided its DUNS number to you.

C. Definitions

For purposes of this award term:

1. System for Award Management (SAM) means the federal repository into which an entity must 

provide information required for the conduct of business as a recipient. Additional information about 

registration procedures may be found at the SAM Internet site at www.sam.gov.

2. Data Universal Numbering System (DUNS) number means the nine- or thirteen-digit number 

established and assigned by Dun and Bradstreet, Inc. (D&B) to uniquely identify business entities. A 

DUNS number may be obtained from D&B by telephone (currently 866-705-5711) or the Internet at 

http://fedgov.dnb.com/webform.

3. Entity, as it is used in this award term, means all of the following, as defined at 2 C.F.R. Part 25, 

subpart C:

a. A governmental organization, which is a state, local government, or Indian Tribe;

b. A foreign public entity;

c. A domestic or foreign non-profit organization;

d. A domestic or foreign for-profit organization; and

e. A federal agency, but only as a subrecipient under an award or subaward to a non-federal 

entity.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

40

4. Subaward:

a. This term means a legal instrument to provide support for the performance of any portion of 

the substantive project or program for which you received this award and that you as the recipient 

award to an eligible subrecipient.

b. The term does not include your procurement of property and services needed to carry out 

the project or program (for further explanation, see Sec. ___.210 of the attachment to OMB Circular 

A-133, “Audits of States, Local Governments, and Non-Profit Organizations”).

c. A subaward may be provided through any legal agreement, including an agreement that you 

consider a contract.

5. Subrecipient means an entity that:

a. Receives a subaward from you under this award; and

b. Is accountable to you for the use of the federal funds provided by the subaward.

Why this condition:

The purpose of this standard award term is to ensure government-wide uniformity in establishing the DUNS 

number as the universal identifier for federal financial assistance applicants, as well as recipients and their 

direct subrecipients (if applicable), and to establish the SAM as the repository for standard information about 

applicants and recipients.

What you should do:

At the time of grant application, your agency was required to provide its DUNS number and be registered in 

the SAM database. 

Your agency should continue to use the same DUNS number provided in your grant application and 

update, as needed, the information associated with that DUNS number. If your agency is authorized to make 

subawards under its award, your agency may make subawards only to entities that have DUNS numbers. For 

more information about your DUNS number, please contact D&B using the toll-free number 866-705-5711 or 

visit http://fedgov.dnb.com/webform.

Your agency must maintain active registration and current information in the SAM until you submit the final 

financial report or receive the final payment under your award, whichever is later. Your agency must review 

and update its SAM information at least once per year to maintain an active registration status. For more 

information about SAM registration, please visit www.sam.gov.

19. Reporting subawards and executive compensation

The Office of Management and Budget requires federal agencies to include the following standard award term in 

all grants and cooperative agreements made on or after October 1, 2010:

a. Reporting of first-tier subawards.

1. Applicability. Unless you are exempt as provided in paragraph d. of this award term, you must 

report each action that obligates $25,000 or more in federal funds that does not include Recovery funds 

(as defined in section 1512(a)(2) of the American Recovery and Reinvestment Act of 2009, Pub. L. 111–5) 

for a subaward to an entity (see definitions in paragraph e. of this award term).

2. Where and when to report.

i. You must report each obligating action described in paragraph a.1. of this award term to 

www.fsrs.gov.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

41

ii. For sub-award information, report no later than the end of the month following the month in 

which the obligation was made. (For example, if the obligation was made on November 7, 2010, 

the obligation must be reported by no later than December 31, 2010.)

3. What to report. You must report the information about each obligating action that the submission 

instructions specify. The submission instructions are posted at www.fsrs.gov.

b. Reporting Total Compensation of Recipient Executives.

1. Applicability and what to report. You must report total compensation for each of your five most 

highly compensated executives for the preceding completed fiscal year, if—

i. the total federal funding authorized to date under this award is $25,000 or more;

ii. in the preceding fiscal year, you received—

(A) 80 percent or more of your annual gross revenues from federal procurement contracts 

(and subcontracts) and federal financial assistance subject to the Transparency Act, as defined 

at 2 C.F.R. Part 170.320 (and sub-awards); and

(B) $25,000,000 or more in annual gross revenues from federal procurement contracts 

(and subcontracts) and federal financial assistance subject to the Transparency Act, as defined 

at 2 C.F.R. Part 170.320 (and sub-awards); and

iii. The public does not have access to information about the compensation of the executives 

through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 

(15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine 

if the public has access to the compensation information, see the U.S. Security and Exchange 

Commission total compensation filings at www.sec.gov/answers/execomp.htm.)

2. Where and when to report. You must report executive total compensation described in paragraph 

b.1. of this award term:

i. As part of your registration profile at www.sam.gov.

ii. By the end of the month following the month in which this award is made, and annually 

thereafter.

c. Reporting of Total Compensation of Subrecipient Executives.

1. Applicability and what to report. Unless you are exempt as provided in paragraph d. of this 

award term, for each first-tier subrecipient under this award, you shall report the names and total 

compensation of each of the subrecipient’s five most highly compensated executives for the 

subrecipient’s preceding completed fiscal year, if—

i. in the subrecipient’s preceding fiscal year, the subrecipient received—

(A) 80 percent or more of its annual gross revenues from federal procurement contracts (and 

subcontracts) and federal financial assistance subject to the Transparency Act, as defined at 2 

C.F.R. Part 170.320 (and subawards); and

(B) $25,000,000 or more in annual gross revenues from federal procurement contracts (and 

subcontracts), and federal financial assistance subject to the Transparency Act (and subawards); 

and

ii. The public does not have access to information about the compensation of the executives 

through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 

(15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine 

if the public has access to the compensation information, see the U.S. Security and Exchange 

Commission total compensation filings at www.sec.gov/answers/execomp.htm.)
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

42

2. Where and when to report. You must report subrecipient executive total compensation described 

in paragraph c.1. of this award term:

i. To the recipient.

ii. By the end of the month following the month during which you make the subaward.

For example, if a subaward is obligated on any date during the month of October of a given year 

(i.e., between October 1 and 31), you must report any required compensation information of the 

subrecipient by November 30 of that year.

d. Exemptions.

If, in the previous tax year, you had gross income, from all sources, under $300,000, you are exempt from the 

requirements to report:

i. Subawards, and

ii. The total compensation of the five most highly compensated executives of any subrecipient.

e. Definitions. For purposes of this award term:

1. Entity means all of the following, as defined in 2 C.F.R. Part 25:

i. A governmental organization, which is a state, local government, or Indian tribe;

ii. A foreign public entity;

iii. A domestic or foreign non-profits organization;

iv. A domestic or foreign for-profit organization;

v. A federal agency, but only as a sub-recipient under an award or sub-award to a non-federal 

entity.

2. Executive means officers, managing partners, or any other employees in management positions.

3. Subaward:

i. This term means a legal instrument to provide support for the performance of any portion of 

the substantive project or program for which you received this award and that you as the recipient 

award to an eligible subrecipient.

ii. The term does not include your procurement of property and services needed to carry out 

the project or program (for further explanation, see Sec. __.210 of the attachment to OMB Circular 

A–133, “Audits of States, Local Governments, and Non-Profit Organizations”).

iii. A sub-award may be provided through any legal agreement, including an agreement that you 

or a subrecipient considers a contract.

4. Subrecipient means an entity that:

i. Receives a subaward from you (the recipient) under this award; and

ii. Is accountable to you for the use of the federal funds provided by the subaward.

5. Total compensation means the cash and noncash dollar value earned by the executive during the 

recipient’s or subrecipient’s preceding fiscal year and includes the following (for more information see 

17 C.F.R. Part 229.402(c)(2)):

i. Salary and bonus.

ii. Awards of stock, stock options, and stock appreciation rights. Use the dollar amount 

recognized for financial statement reporting purposes with respect to the fiscal year in accordance 

with the Statement of Financial Accounting Standards No. 123 (Revised 2004) (FAS 123R), Shared 

Based Payments.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

43

iii. Earnings for services under non-equity incentive plans. This does not include group life, health, 

hospitalization or medical reimbursement plans that do not discriminate in favor of executives, and 

are available generally to all salaried employees.

iv. Change in pension value. This is the change in present value of defined benefit and actuarial 

pension plans.

v. Above-market earnings on deferred compensation which is not tax-qualified.

vi. Other compensation, if the aggregate value of all such other compensation (e.g., severance, 

termination payments, value of life insurance paid on behalf of the employee, perquisites or 

property) for the executive exceeds $10,000.

Why this condition:

To further federal spending transparency, the Federal Funding Accountability and Transparency Act of 2006 

(FFATA) requires, among other things, that information on federal awards (federal financial assistance and 

expenditures) be made available to the public via a single, searchable website, which is www.USASpending.

gov. Grantees are responsible for reporting their applicable executive compensation and sub-award 

information and the award term provides guidance to report the related information, as required by FFATA.

What you should do:

At the time of grant application, your agency was asked to ensure that it has the necessary processes 

and systems in place to comply with the applicable subaward and executive compensation reporting 

requirements should it receive funding. If your agency received awards of $25,000 or more, you are required 

to report award information on any first-tier subawards totaling $25,000 or more, and, in certain cases, to 

report information on the names and total compensation of the five most highly compensated executives 

of the recipient and first-tier subrecipients. The FFATA Subaward Reporting System (FSRS), accessible via the 

website at www.fsrs.gov, is the reporting tool that your agency will use to capture and report subaward 

information and any executive compensation data required by FFATA. The subaward information entered 

in FSRS will then be displayed on www.USASpending.gov associated with your agency’s award, furthering 

federal spending transparency.

For additional information regarding the executive compensation and subaward reporting requirements, 

please see Vol. 75, No. 177 (September 14, 2010) of the Federal Register, 

www.gpo.gov/fdsys/pkg/FR-2010-09-14/pdf/2010-22705.pdf.

20. Criminal intelligence systems

Grantees using TRGP funds to operate an inter-jurisdictional criminal intelligence system must comply with 

operating principles of 28 C.F.R. Part 23. The grantee acknowledges that it has completed, signed, and submitted 

with its grant award the relevant Special Condition certifying its compliance with 28 C.F.R. Part 23.

Why this condition:

If your agency receives funding for equipment or technology that will be used to operate an 

interjurisdictional criminal intelligence system, you must comply with the operating principles found at 

28 C.F.R. Part 23. An interjurisdictional criminal intelligence system is generally defined as a system which 

receives, stores, analyzes, and exchanges or disseminates data regarding ongoing pre-arrest criminal 

activities (examples of such activities include, but are not limited to, loan sharking, drug or stolen property 

trafficking, gambling, extortion, smuggling, bribery, and public corruption) and shares this data with other 

law enforcement jurisdictions. 28 C.F.R. Part 23 contains operating principles for these interjurisdictional 

criminal intelligence systems that protect individual privacy and constitutional rights.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

44

If your agency will use TRGP grant funds simply to operate a single agency database (or other unrelated 

forms of technology) and will not share criminal intelligence data with other jurisdictions, 28 C.F.R. Part 23 

does not apply to this grant.

What you should do:

All COPS Office grant recipients were required to agree to the Certification of Review of Criminal Intelligence 

Systems/28 C.F.R. Part 23 as part of their application proposal so the COPS Office can track which agencies 

intend to use their award funds to operate interjurisdictional criminal intelligence systems. If your agency 

intends to use grant funds to operate an interjurisdictional criminal intelligence system, you should indicate 

this on the Criminal Intelligence Systems 28 C.F.R. Part 23 Compliance form that was included with your 

grant award package and certify and submit this form along with your signed grant award document as 

your agency’s agreement to comply with the operating principles found at 28 C.F.R. Part 23. Your agency 

must now comply with 28 C.F.R. Part 23 in operating the interjurisdictional criminal intelligence system 

funded through your COPS Office grant.

21. Sole source justification 

TRGP-Equipment/Training grantees who have been awarded funding for the procurement of an item (or group 

of items) or service in excess of $150,000, and who plan to seek approval for use of a noncompetitive procurement 

process must provide a written sole source justification to the COPS Office for approval prior to obligating, 

expending, or drawing down grant funds for that item or service.

Why this condition:

In general, grant recipients are required to procure funded items through open and free competition. 

However, in some instances, grantees may have already determined that competition is not feasible.

What you should do:

A grant recipient must request written approval from the COPS Office for sole source procurements in 

excess of $150,000 prior to purchasing equipment, technology, or services; obligating funding for a contract; 

or entering into a contract with grant funds. For the purchase of equipment, technology, or services under 

a COPS Office grant or award, recipients must use their own documented procurement procedures that 

reflect applicable state and local laws and regulations, as long as those requirements conform to the federal 

procurement requirements set forth in 2 C.F.R. § 200.320 as adopted by the U.S. Department of Justice in 

2 C.F.R. § 2800.101. A sole source justification request should be submitted if a recipient determines that 

the award of a contract through a competitive process is infeasible. The COPS Office may authorize a 

noncompetitive proposal if one or more of the following circumstances apply:

The initial determination that competition is not feasible can be made if one of the following circumstances 

exists:

•	 The item/service is available only from one source. 

•	 Public exigency or emergency for the requirement will not permit a delay resulting from competitive 

solicitation.

•	 Competition is determined inadequate after solicitation of a number of sources.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

45

The COPS Office will review your request and the supporting information that you provide and will make a 

determination as to whether or not an exception can be granted to the general rule regarding competition. 

If submitting a sole source justification request to the COPS Office, please use the format described in 

section II, “Procurement Process,” on page 54.

For more information on sole source justification, please review the fact sheet: http://www.cops.usdoj.gov/

pdf/2015AwardDocs/Sole_Sorce_Justification_FactSheet.pdf. 

22. Public release information

The grantee agrees to submit one copy of all reports and proposed publications resulting from this award 20 days 

prior to public release. Any publications (written, curricula, visual, sound, or websites) or computer programs, 

whether or not published at government expense, shall contain the following statement: “This project was 

supported by Grant Number __________ awarded by the U.S. Department of Justice, Office of Community 

Oriented Policing Services. The opinions contained herein are those of the author(s) and do not necessarily 

represent the official position or policies of the U.S. Department of Justice. References to specific companies, 

products, or services should not be considered an endorsement by the author(s) or the U.S. Department of Justice. 

Rather, the references are illustrations to supplement discussion of the issues.”

Why this condition:

The COPS Office wants to ensure the quality, objectivity, utility, and integrity of information in funded 

projects that are disseminated to the public. However, award-funded reports and publications are not official 

federal documents and should not be construed to reflect the official policy or position of the DOJ.

In addition, the COPS Office reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, 

publish, or otherwise use and to authorize others to use, for federal government purposes, the following: (1) 

the copyright in any work developed under this award, subaward, or contract and (2) any copyright to which 

an award recipient, subawardee, or a contractor purchases ownership with support from this award.

What you should do:

Ensure that all publications (where applicable) relating to your COPS Office award contain the required 

statement listed above.

In addition, the grantee is responsible for acquiring the rights, and ensuring that its subcontractors/authors 

acquire the rights, to copyrighted material for inclusion in DOJ publications or other products or deliverables 

that are developed under this cooperative agreement, including the payment of required fees. All licensing, 

publishing, or similar agreements with a copyright holder, publisher, or other relevant party shall include 

provisions giving the Federal Government a royalty-free, non-exclusive, and irrevocable license to reproduce, 

publish, or otherwise use, and to authorize others to use, the publication for Federal Government purposes.

23. Debarment and suspension

The recipient agrees not to award Federal funds under this program to any party which is debarred or suspended 

from participation in Federal assistance programs.

Why this condition:

Under federal regulations, recipients are required to ensure that federal funds are not given to parties that are 

debarred or suspended from participation in federal assistance programs. This is to protect the public interest 

and to ensure proper management and integrity in federal activities by conducting business only with 

responsible parties. For details regarding the debarment and suspension requirements, please see 2 C.F.R. Part 

180 (Government-wide Debarment and Suspension), and 2 C.F.R. Part 2867 (DOJ-specific requirements.)
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

46

What you should do:

If, under a COPS Office award, you enter into a contract for goods or services that is for $25,000 or more or 

any subaward, you must verify that the vendor or subawardee and their respective principals (e.g., owners, 

top managers) with whom you intend to do business are not excluded or disqualified from participation 

in federal assistance programs. In addition, you must include a term or condition in the contract or 

subaward requiring the vendor or subawardee to comply with subpart C of the OMB guidance in 2 C.F.R. 

Part 180 (Government-wide Debarment and Suspension) and subpart C of 2 C.F.R. Part 2867 (DOJ-specific 

requirements).

24. Whistleblower protection

The recipient agrees not to discharge, demote, or otherwise discriminate against an employee as reprisal for the 

employee disclosing information that he/she reasonably believes is evidence of gross mismanagement of a Federal 

contract or grant, a gross waste of Federal funds, an abuse of authority relating to a Federal contract or grant, a 

substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a Federal 

contract (including the competition for or negotiation of a contract) or grant. The recipient also agrees to provide 

to their employees in writing (in the predominant native language of the workforce) of the rights and remedies 

provided in 41 U.S.C. § 4712. Please see appendix E in the Grant Owner’s Manual for a full text of the statute.

Why this condition:

Under the “Pilot program for enhancement of contractor protection from reprisal for disclosure of certain 

information” (41 U.S.C. § 4712), which is in effect through January 1, 2017, recipients are prohibited from 

taking reprisal actions against employees for certain whistleblowing activities in connection with federal 

grants and contracts. The pilot program protects the public interest and ensures the proper management 

and use of federal funds.

What you should do:

The recipient must not take reprisal actions against an employee for disclosing misconduct under federal 

contracts and grants to certain persons and entities.

The recipient is prohibited from discharging, demoting, or otherwise discriminating against an employee as 

reprisal for disclosing information that he or she reasonably believes is evidence of

•	 gross mismanagement of a federal contract or grant;

•	 a gross waste of federal funds;

•	 an abuse of authority relating to a federal contract or grant;

•	 a substantial and specific danger to public health or safety;

•	 a violation of law, rule, or regulation related to a federal contract (including the competition for or 

negotiation of a contract) or grant.

In addition, the disclosure must also have been made to

•	 a member of Congress or a representative of a committee of Congress;

•	 an inspector general;

•	 the Government Accountability Office; 

•	 a federal employee responsible for contract or grant oversight or management at the relevant agency;

•	 an authorized official of the U.S. Department of Justice or other law enforcement agency;

•	 a court or grand jury;

•	 a management official or other employee of the contractor, subcontractor, or grantee who has the 

responsibility to investigate, discover, or address misconduct.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

47

An employee is deemed to have made a protected disclosure if he or she initiates or provides evidence 

of misconduct in any judicial or administrative proceeding relating to waste, fraud, or abuse on a federal 

contract or grant.

The recipient must inform its employees in writing, in the predominant language of the workforce, of 

employee whistleblower rights, protections and remedies under 41 U.S.C. 4712.

Please see appendix E on page 82 for a full text of the “Pilot program for enhancement of contractor 

protection from reprisal for disclosure of certain information” (41 U.S.C. 4712).

25. Restrictions on internal confidentiality agreements

No recipient or subrecipient under this award, or entity that receives a contract or subcontract with any funds 

under this award, may require any employee or contractor to sign an internal confidentiality agreement or 

statement that prohibits or otherwise restricts the lawful reporting of waste, fraud, or abuse to an investigative or 

law enforcement representative of a federal department or agency authorized to receive such information.

Why this condition:

 Under section 743 of Division E, Title VIII, of the Consolidated and Further Continuing Appropriations 

Act, 2015 (Pub. L. 113-235), neither the recipient, subrecipient, nor any entity that receives a contract or 

subcontract with any funds under this or any other Act may require its employees or contractors to sign an 

internal confidentiality agreement or statement prohibiting or otherwise restricting their lawful reporting 

of waste, fraud, or abuse to an investigative or law enforcement representative of a federal department 

or agency. This provision protects the public interest and ensures the proper management and use of 

federal funds. This limitation is not intended, and shall not be understood by the agency making this award, 

to contravene requirements applicable to Standard Form 312 (which relates to classified information), 

Form 4414 (which relates to sensitive compartmented information), or any other form issued by a federal 

department or agency governing the nondisclosure of classified information.

What you should do:

1. In accepting this award, the recipient

•	 represents that it neither requires nor has required internal confidentiality agreements or statements 

from employees or contractors that currently prohibit or otherwise restrict (or purport to prohibit or 

restrict) employees or contractors from reporting waste, fraud, or abuse as described above;

•	 represents that, if it learns or is notified that it is or has been requiring its employees or contractors to 

execute agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict) 

reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations 

of award funds, will provide prompt written notification to the agency making this award, and will 

resume such obligations only if expressly authorized to do so by that agency.

2. If the recipient does or is authorized to make subawards or contracts under this award, in accepting, the 

recipient

•	 represents that it has or will determine that no other entity that the recipient proposes may or will 

receive award funds (whether through a subaward, contract, or subcontract) either requires or has 

required internal confidentiality agreements or statements from employees or contractors that 

currently prohibit or otherwise restrict (or purport to prohibit or restrict) employees or contractors from 

reporting waste, fraud, or abuse as described above;

•	 represents that it has or will make appropriate inquiry, or otherwise has an adequate factual basis, to 

support this representation;
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

48

•	 represents that, if it learns or is notified that any subrecipient, contractor, or subcontractor entity that 

receives funds under this award is or has been requiring its employees or contractors to execute 

agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict) 

reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations 

of award funds to or by that entity, will provide prompt written notification to the agency making this 

award, and will resume (or permit resumption of ) such obligations only if expressly authorized to do so 

by that agency.

26. Mandatory disclosure

Recipients and subrecipients must timely disclose in writing to the COPS Office or pass-through entity, as 

applicable, all federal criminal law violations involving fraud, bribery, or gratuity that may potentially affect 

the awarded federal funding. Failure to make required disclosures can result in any of the remedies, including 

suspension and debarment, described in the Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards, 2 C.F.R. § 200.338 as adopted by the U.S. Department of Justice in 2 C.F.R. § 

2800.101.

Why this condition:

Federal regulations require recipients and subrecipients report all federal violations involving fraud, bribery, 

or gratuity that may affect the awarded federal funds. This condition advises your agency of the requirement 

and the consequences of failing to report such violations to the COPS Office or pass-through entity.

What you should do:

Ensure that you timely report in writing to the COPS Office or pass-through entity all federal violations 

involving fraud, bribery, or gratuity that may affect your federal award.

27. Conflict of interest

Federal awardees and subawardees must disclose in writing to the COPS Office or pass-through entity, as 

applicable, any potential conflict of interest affecting the awarded federal funding in accordance with the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.112 as 

adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101.

Why this condition:

Awardees and subawardees are required to use federal funding in the best interest of their award program. 

Any decisions related to these funds must be free of hidden personal or organizational conflicts of interest, 

both in fact and in appearance.

This means that awardees and subawardees should not participate in any award-related decisions or 

recommendations that involve any of the following people or groups: 

•	 An immediate family member

•	 A partner

•	 An organization in which they are serving as an officer, director, partner, or employee

•	 Any person or organization with whom they are negotiating or who has an arrangement concerning 

prospective employment, has a financial interest, or for other reasons can have less than an unbiased 

transaction with the awardee or subawardee
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

49

This also means that awardees and subawardees should avoid any action which might result in or create the 

appearance of

•	 using your official position for private gain;

•	 giving special treatment to any person;

•	 losing complete independence or objectivity;

•	 making an official decision outside official channels; or

•	 affecting negatively the confidence of the public in the integrity of the Federal Government or the 

program.

What you should do:

Ensure that you report in writing to the COPS Office or pass-through entity, as applicable, any potential 

conflict of interest that may affect your federal award.

28. Contract provision 

All contracts made by the award recipients under the federal award must contain the provisions required under 2 

C.F.R. Appendix II to part 200 (Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under 

Federal Awards) as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101. Please see appendix F in the 

Grant Owner’s Manual for a full text of the contract provisions.

For the full text please refer to appendix F of the Grant Owner’s Manual (GOM).

Why this condition:

Federal regulations require recipients and subrecipients to comply with the necessary contract provisions 

in order to standardize and strengthen oversight of all contracts made under federal awards. This provision 

protects the public interest and ensures the proper management and use of federal funds as it relates to 

contracts entered into by the recipient. 

What you should do:

The recipient should review all contracts made under the federal award to ensure that they contain the 

provisions required in appendix F of the Grant Owner’s Manual.

29. Computer network requirement

The recipient understands and agrees that no award funds may be used to maintain or establish a computer 

network unless such network blocks the viewing, downloading, and exchanging of pornography. Nothing in this 

requirement limits the use of funds necessary for any federal, state, tribal, or local law enforcement agency or any 

other entity carrying out criminal investigations, prosecution, or adjudication activities. 

Why this condition: 

Section 534 of Division B, Title V, of the Consolidated and Further Continuing Appropriations Act, 2015 (Pub. 

L. 113-235) prohibits the use of federal funds to maintain or establish a computer network that does not 

block the viewing, downloading, and exchanging of pornography. This provision protects the public interest 

in the proper management and use of federal funds. 

What you should do: 

The recipient must not use award funds to maintain or establish a computer network unless the network 

blocks pornography. This does not limit the use of funds for criminal investigations, prosecution or 

adjudication activities.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

50

What are the specific rules regarding termination of grant funding?

The COPS Office has the right to sanction or terminate your agency’s project when there is reason to believe 

that your agency is

•	 not substantially complying with the grant requirements or other applicable provisions of federal law;

•	 failing to make satisfactory progress toward the goals or strategies outlined in its application;

•	 not adhering to grant requirements or conditions;

•	 proposing substantial plan changes to the extent that, if originally submitted, would have resulted in 

the application being denied funding;

•	 not submitting financial or programmatic reports in a timely manner;

•	 filing false statements or certifications in connection with an application, periodic report, or other 

grant-related documents;

•	 providing other good cause for sanctions or termination as determined by the COPS Office.

In these instances, the COPS Office may

•	 temporarily withhold payments pending correction of the situation by your agency;

•	 disallow all or part of the cost of the activity or action not in compliance;

•	 wholly or partly suspend or terminate your grant;

•	 require that some or all of the grant funds be remitted to the U.S. Department of Justice;

•	 condition a future grant or elect not to provide future grant funds to your agency until appropriate 

actions are taken to ensure compliance;

•	 withhold or bar your agency from obtaining future awards;

•	 recommend civil or criminal enforcement by other agencies;

•	 take other remedies that may be legally available.

In the event that sanctions are imposed or your grant is terminated, your agency will be notified in writing of 

our decision and the reason(s) for that decision.

Accepting the grant award

After you have reviewed the conditions of your TRGP award and your agency agrees with these conditions, 

you are ready to accept the award. The Director of the COPS Office has signed the award document 

indicating approval of your grant, an obligation of federal funds to your organization, and our commitment 

to the award. As stated at the beginning of this section, to officially begin your grant and draw down your 

funds, the authorized officials (see the Glossary of Terms on page 88 of this publication) of your agency must 

access www.cops.usdoj.gov and select the “Account Access” link in the upper right corner to log in, review, 

and electronically sign the award document along with all award condition pages.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

51

Who should sign the award document for our agency?

The authorized official is the government executive who has ultimate and final responsibility for all 

programmatic and financial decisions regarding this grant as the representative of the legal grantee. COPS 

Office grants require the top government executive (e.g., Tribal Chairman, President, Chief, or equivalent) 

to sign the award document. Typically, this is the same executive named on your agency’s 2015 TRGP 

application. (If this individual has changed, please complete a Change of Information form online at www.cops.

usdoj.gov through the “Account Access” option.) If you have any questions as to who should sign the award, 

please contact your jurisdiction’s local legal advisor.

By when must the award document be signed?

Please electronically sign the award document and all award condition pages within 90 days of the date 

on the award congratulatory letter. Grant funds will not be released until we have received your agency’s 

signed award document, your budget has received final clearance, and any other relevant grant conditions 

particular to your agency have been satisfied. Failure to submit your signed award document within the 90-

day award acceptance period may result in your TRGP award being withdrawn and the funds deobligated 

without additional notification. If your agency requires an extension for accepting the award beyond the 

90-day acceptance timeframe, please submit a written request to your COPS Office Grant Program Specialist. 

Be sure to explain the circumstances that prevent your agency from signing the award document within the 

90-day period and identify the date by which the award document will be electronically signed. The COPS 

Office will review such requests on a case-by-case basis. The COPS Office reserves the right to deny requests 

to extend the 90-day award acceptance period.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

52

II. Procurement Process (for TRGP-Equipment/Training grants 

only)

In general, grant recipients are required to procure funded items through open and free competition when 

feasible. For the purchase of equipment, technology, or services under a COPS Office grant award, grant 

recipients must follow their own policies and procedures on procurement as long as those requirements 

conform to the federal procurement requirements set forth in the Uniform Administrative Requirements, 

Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.318, as adopted by the U.S. 

Department of Justice in 2 C.F.R. § 2800.101 (as applicable). 

As described in grant condition #21 on page 44, grantees are required to submit a sole source justification 

(SSJ) request for sole source procurements in excess of $150,000 prior to purchasing equipment, technology, 

or services; obligating funding for a contract; or entering into a contract with grant funds. For the purchase 

of equipment, technology, or services under a COPS Office grant or award, recipients must use their own 

documented procurement procedures that reflect applicable state and local laws and regulations, as long 

as those requirements conform to the federal procurement requirements set forth in 2 C.F.R. § 200.320 as 

adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101. A sole source justification request should be 

submitted if a recipient determines that the award of a contract through a competitive process is infeasible. 

The COPS Office may authorize a noncompetitive proposal if one or more of the following circumstances 

apply: 

•	 The item/service is available only from one source. 

•	 The public exigency or emergency for the requirement will not permit a delay resulting from 

competitive solicitation. 

•	 Competition is determined inadequate after solicitation of a number of sources. 

What documentation must be submitted to the COPS Office for sole source review? 

Requests for sole source procurements of equipment, technology, or services in excess of $150,000 must 

be submitted to the COPS Office in writing certifying that the award of the contract through full and open 

competition is infeasible. 

The outline below may be helpful in preparing your agency’s sole source request and ensuring that all of the 

necessary information is included. 

A grant recipient must request written approval from the COPS Office for sole source procurements in excess 

of $150,000 prior to purchasing equipment, technology, or services; obligating funding for a contract; or 

entering into a contract with grant funds. 

Letterhead. The sole source request must be signed and submitted on grantee department letterhead and 

must include the agency’s ORI number and the grant number for which the approval is being sought. The 

request should also include the following information: 

• Section I. A brief description of the project, the amount to be designated for the sole source procurement,

and the purpose of the contract

• Section II. (a) An explanation as to why it is necessary to contract in a noncompetitive manner and (b)

Which one (or more) of the three circumstances identified below applies to the procurement transaction 

(include supporting information as identified below under the applicable section(s)):
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

53

1. If the item or service is available only from one source, please include the following:

•	 Uniqueness of items or services to be procured from the proposed contractor or vendor 

(compatibility, patent issues, etc.)

•	 How the agency determined that the item or service is only available from one source (e.g., 

market survey results, independent agency research, patented or proprietary system, etc.)

•	 Explanation of need for contractor’s expertise linked to the current project (e.g., knowledge of 

project management, responsiveness, experience of contractor personnel, prior work on earlier 

phases of project)

•	 Any additional information that would support the case

2. If the public exigency or emergency for the requirement will not permit a delay resulting from 

competitive solicitation, please include the following:

•	 When the contractual coverage is required by your department and why

•	 Impact on project if deadline/dates are not met

•	 How long it would take an alternate contractor to reach the same required level of competence 

(equate to dollar amounts, if desired)

•	 Any additional information that would support the case

3. If competition is determined inadequate after solicitation of a number of sources, please include the 

following:

•	 Results of a market survey to determine competition availability; if no survey is conducted, please 

explain why not

•	 Any additional information that would support the case

• Section III. A declaration that this action/choice is in the best interest of the agency

Failure to provide all of the necessary information will delay the processing of your request. Your agency 

will be contacted if any of the identified information is missing or if additional supporting information is 

required. If the COPS Office determines that the request does not meet the standards set forth above, the 

request will be denied. Please be advised that conflicts of interest are prohibited under the procurement 

standards set forth in 2 C.F.R. § 200.318 as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101. 

In addition, the grant recipient agrees not to award federal funds under this program to any party that is 

debarred or suspended from participation in federal assistance programs.

Contact the COPS Office

If you have any questions regarding the federal requirements that guide procurement procedures, please 

contact your COPS Office Grant Program Specialist or program point of contact.

For more information about COPS Office programs and resources, please call the COPS Office Response 

Center at 800-421-6770 or visit the COPS Office online at www.cops.usdoj.gov.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

54

III. Accessing Grant Funds

This section provides answers to payment-related questions, including all the information needed to set 

up your payments. For assistance with financial management and grant administration, please contact the 

COPS Office Response Center at 800-421-6770 or visit our website at www.cops.usdoj.gov.

Payment method

What method of payment is used?

There is currently one method of payment available for accessing federal grant funds—the Grant Payment 

Request System (GPRS). GPRS is a web-based system that enables grantees to use a secure Internet 

connection to request funds. Approved payment requests will automatically be scheduled for payment by 

the U.S. Department of the Treasury. A grantee will be able to review previous requests made since July 2009. 

For more information on the GPRS, please go to www.ojp.usdoj.gov/about/offices/ocfogprs.htm to view the 

user guide.

Setting up your account

How do we set up a GPRS account?

If you are a new grantee to the COPS Office, your law enforcement executive or government executive 

should receive notification about GPRS shortly after the COPS Office receives your original signed award 

document. This notification will contain all of the information that your agency needs to set up the GPRS 

payment method. If your law enforcement executive or government executive does not perform drawdown 

requests for your agency, your grant administrator will need to go online to https://grants.ojp.usdoj.gov/

gprs/welcome to log in and register to become a Drawdown Specialist. Once you are approved, you will 

receive an e-mail containing a temporary password and information on how to use GPRS. Please note that 

part of the verification process may involve outreach to your law enforcement executive or government 

executive or other financial points of contact to validate information provided by the Drawdown Specialist.

If you are already registered for a COPS Office grant username in GPRS, and would like to add a newly 

awarded COPS Office grant to the existing COPS Office grant username, contact the COPS Office GPRS 

registration team via e-mail at COPSGPRSRegistration@usdoj.gov and provide the following information:

•	 User name (for COPS Office grants)

•	 First and last name

•	 Vendor number

•	 Grant number(s) to be added

How do we fill out the payment enrollment forms?

If you are a new grantee to the COPS Office, your agency will need to complete an Automated 

Clearinghouse (ACH) Vendor/Miscellaneous Payment (SF-3881) enrollment form. This form can be found on 

the COPS Office website at the following address: www.cops.usdoj.gov/Default.asp?Item=100.

Prior to accessing your grant funds, your agency must mail the original signed form to:

Office of Justice Programs

Office of the Chief Financial Officer 

810 Seventh Street NW

Attn: Control Desk, Fifth Floor

Washington, DC 20001
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

55

Your agency must complete the “Payee/Company Information” section following the directions on the 

back of the form and also provide the grant number (printed on the award document). Next, your financial 

institution must complete the “Financial Institution Information” section and have the appropriate financial 

official sign the form.

If you are already a COPS Office grantee, you should already have filled out an ACH enrollment form. 

Therefore, your agency will not be required to submit a new ACH enrollment form for the newly awarded 

grant as long as your OJP vendor number has not changed. If you have any questions, or wish to verify your 

ACH enrollment form information, please call the COPS Office Response Center at 800-421-6770.

When should Federal Financial Reports be filed?

After your agency returns the signed award document to the COPS Office, under current regulations, you are 

required to submit quarterly Federal Financial Reports (FFRs) using a Standard Form 425 (SF-425). This report 

reflects the actual monies spent and unliquidated obligations incurred by your agency. You will not be able 

to make drawdowns from your grant account if the SF-425 for the most recent reporting quarter is not on 

file with the COPS Office by the deadline date. Grantees are encouraged to submit their SF-425 reports via 

the Internet at www.cops.usdoj.gov.

For more information on how to complete and where to submit your quarterly SF-425, see Section VI of this 

manual, titled “Reports,” on page 64.

Filing the FFR (SF-425) identifies your federal and local expenditures made during that calendar quarter. However, 

to receive actual payment, you must request it through GPRS.

Additional payment questions

Can we receive advances?

Yes. If you receive funds through electronic transfer, the period allowed is 10 days in advance. In general, the 

concept of minimum cash on hand applies to COPS Office grants. This concept requires that your agency 

request funds based upon immediate cash disbursement needs. You should time your request for payment 

to ensure that federal cash on hand is the minimum that you need.

There should be no excess federal grant funds on hand, except for advances not exceeding 10 days, as noted 

above.

The Federal Government has four basic rules regarding advances. Advances can be terminated if the grantee

•	 is unwilling or unable to attain project goals;

•	 maintains excess cash on hand;

•	 does not adhere to the terms and conditions of the grant;

•	 fails to submit reliable or timely reports.

How often can we request reimbursement of costs?

There are no limitations on how often your agency may request reimbursements. However, reimbursement 

is only for costs that were approved in the FCM. As a general guideline, most agencies request 

reimbursement on a monthly or quarterly basis. Also, please note that a date range can only be used once.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

56

Can we earn interest on our grant funds?

Your agency should minimize the time between your drawdown of grant funds and your payment of grant 

costs to avoid earning excess interest on your grant funds. You must account for interest earned on advances 

of federal funds as follows:

•	 COPS grant award recipients must adhere to the standards set forth in the applicable Office of 

Management and Budget (OMB) uniform guidance 2 C.F.R. § 200.305(b)(9) that states that interest 

earned on federal advance payments deposited in interest-bearing accounts up to $500 per year may 

be retained by the grantee for administrative expense. Interest earned on Federal advance payments 

deposited in interest-bearing accounts in excess of $500 must be remitted annually to the U.S. 

Department of Health and Human Services. Make check payable to “The Department of Health and 

Human Services” and mail check to Treasury-approved lockbox: HHS Program Support Center, P.O. Box 

530231, Atlanta, GA 30353-0231. (Please allow 4–6 weeks for processing of a payment by check to be 

applied to the appropriate Payment Management System (PMS) account).

•	 Please notify your COPS Office Staff Accountant in the COPS Office Financial Division when any interest 

that is earned is remitted to U.S. Department of Health and Human Services, Payment Management 

Systems, P.O. Box 6021, Rockville, MD 20852.

•	 For states, payments are governed by Treasury-State CMIA agreements and default procedures codified 

at 31 C.F.R. Part 205 “Rules and Procedures for Efficient Federal-State Funds Transfers” and TFM 4A–2000 

Overall Disbursing Rules for All Federal Agencies.

Matching funds

Under the 2015 COPS Office TRGP Programs, no local match is required. The COPS Office is funding 100 

percent of the allowable items approved in your FCM. (Any salary and benefit costs higher than entrylevel must be paid by your agency with local funds.) Please note: If the total cost exceeds the approved 

budget, then the addition expenditures are encouraged to be reported on the SF-425 as recipient share of 

expenditures.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

57

IV. Financial Record Maintenance

Your agency is required to establish and maintain accounting systems and financial records to accurately 

account for grant funds awarded and disbursed. These records must include both federal funds and any 

local funds contributed to this project.

Accounting systems and records

What accounting systems are required?

Your agency needs to establish and maintain accounting systems and financial records to accurately 

account for the funds awarded.

As stated in 2 C.F.R. 200.62 (Internal Control over Compliance Requirements for Federal Awards), your 

accounting system should

•	 present and itemize actual expenditures of funded items;

•	 demonstrate that funds are spent in compliance with your grant conditions;

•	 be able to provide the necessary information for periodic financial review and audit.

What records must be kept?

Your agency’s fiscal control and accounting systems should enable you to make accurate, current, and 

complete disclosure of the financial activity under your grant. Your accounting records should contain 

information showing expenditures under the grant and must be supported by items such as cancelled 

checks, purchase orders, or similar documents.

Your agency must adequately safeguard grant funds and make sure that they are used for authorized 

purposes only. Your agency will be responsible for refunding any unallowable expenses.

How long must documents be kept?

All financial records, including payroll, time and attendance records, canceled checks, purchase orders, and 

similar documents associated with your CPD award should be kept for at least three years from the date 

the COPS Office officially closes the award. Your agency should maintain records so that you can identify 

them by grant year or by fiscal year, whichever you find more convenient. If any litigation, claim, negotiation, 

audit or other action involving these records has been started before the end of the three-year period, the 

records should be kept until completion of the action. These records should be easily located and should 

be properly protected against fire or other damage. Failure to maintain adequate records to document award 

expenditures may result in a requirement to repay all federal funds that cannot be supported with appropriate 

records.

Your agency should maintain records so that you can identify them by grant year or by fiscal year, whichever 

you find more convenient. 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

58

What if we have more than one grant?

If your agency has more than one COPS Office grant or a grant from another federal agency, funds received 

under one project may not be used to support another project without specific written authorization 

from the COPS Office, or, in the case of a grant from another agency, from both awarding agencies. Your 

accounting systems and financial records must reflect expenditures for each project separately.

Who may access our records?

Authorized federal representatives, including representatives from the U.S. Department of Justice, the 

Comptroller General of the United States, the COPS Office, and any entity designated by the COPS Office 

may access these records for the purposes of conducting audits, site visits, or other examinations.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

59

V. Federal Audit Requirements

In addition to oversight by the COPS Office, your grant may be subject to an audit by independent 

examiners. The two primary types of audit are Single Audit Act (SAA) audits and U.S. Department of Justice 

(DOJ) Office of the Inspector General (OIG) audits.

Requirements and audits

What are the regulations governing SAA requirements?

The Single Audit Act of 1984 established uniform guidelines for state and local governments receiving 

federal financial assistance. The 1984 Act was amended in July 1996, was revised June 27, 2003 and again 

June 26, 2007, and is effective for fiscal years after December 31, 2003 to reflect revised audit criteria and 

reporting requirements. The new Office of Management and Budget (OMB) 2 C.F.R. Part 200 — Uniform 

Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform 

Guidance) was effective on December 26, 2013, was implemented by federal agencies on the required 

effective date of December 26, 2014, and provides additional guidelines regarding the implementation of 

SAA requirements. 

Who must have an SAA audit?

A nonfederal entity that expends $750,000 or more during the nonfederal entity’s fiscal year in federal 

awards must have a single audit conducted in accordance with §200.514 Scope of audit except when it 

elects to have a program-specific audit conducted in accordance with paragraph (c) of this section. An 

auditee may be a recipient, a subrecipient, or a vendor. Specifically, “Federal awards expended as a recipient 

or a subrecipient are subject to audit under §200.501, Subpart F.” 

SAA audits are conducted annually unless a state or local government is required by constitution or statute 

in effect on January 1, 1987 to undergo audits less frequently than annually. The primary objective of an SAA 

audit is to express opinions on the grantee’s financial statements, internal controls, major and non-major 

grant programs, and compliance with government laws and regulations. Single Audits may also address 

specific compliance issues with respect to COPS Office grant requirements.

In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, 

federal agencies and pass-through entities must take appropriate action as provided in §200.338 “Remedies 

for noncompliance.” These sanctions under §200.338 “Remedies for noncompliance” could include the 

following: 

•	 Temporarily withhold cash payments pending correction of the deficiency by the nonfederal entity or 

more severe enforcement action by the federal awarding agency or pass-through entity.

•	 Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost 

of the activity or action not in compliance.

•	 Wholly or partly suspend or terminate the federal award.

•	 Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and federal 

awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding 

be initiated by a federal awarding agency).

•	 Withhold further federal awards for the project or program.

•	 Take other remedies that may be legally available.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

60

Your Single Audit Act reports should not be sent to the COPS Office. If the U.S. Department of Justice is your 

cognizant federal agency (see the Glossary of Terms on page 88), they should be sent to the Federal Audit 

Clearinghouse at:

Federal Audit Clearinghouse 

Bureau of Census

1201 East 10th Street

Jeffersonville, IN 47132

The U.S. Department of Justice, Office of Justice Programs (OJP) serves as the liaison between grantees and 

auditors in the conduct of SAA audits. Questions and comments regarding SAA audits may be directed to 

the COPS Office Response Center at 800-421-6770.

What is the role of the Office of the Inspector General (OIG)? 

The OIG is a separate component of the U.S. Department of Justice and is independent of the COPS Office. 

The primary objective of OIG audits is to assess compliance with grant conditions. OIG audits are designed to 

promote economy, efficiency, and effectiveness in the administration of grants by evaluating compliance with 

laws, regulations, policies, and procedures governing the operations encompassed in the scope of the audit.

How are COPS Office grants selected for an OIG audit?

The OIG may conduct a COPS Office grant audit in response to a referral that the OIG believes warrants 

further evaluation. The OIG also surveys DOJ agencies on an annual basis to solicit input on suggested audit 

areas for the upcoming fiscal year. In most instances, however, the OIG selects grants based on a number of 

factors, including the geographical distribution of grants awarded, award amount, population served, and 

type of grant (both active and expired). As such, the fact that your grant has been selected for an OIG audit is 

not necessarily indicative of a suspected concern or problem area.

The COPS Office Grant Monitoring Division serves as the liaison between grantees and the OIG’s Audit 

Division, which conducts the audit. After the OIG notifies the COPS Office of upcoming audits to be 

conducted, the COPS Office Audit Liaison Division will send out a notification letter to the grantee outlining 

the scope of each audit and the anticipated audit timeframe. This notification letter also advises grantees 

of the supporting documentation required and information necessary for the OIG during their scheduled 

field work and provides a COPS Office point of contact to address questions and concerns. If you have any 

questions regarding an OIG audit, please contact the COPS Office Grant Monitoring Division at 800-421-

6770. Questions and comments regarding the administration of your COPS Office grant not specifically 

related to an audit should be referred to your COPS Office Grant Program Specialist.

Typical audit findings

The OIG has typically reported the following audit findings pertaining to grants as a result of lack of proper 

documentation, poor business practices, or inadequate accounting and record keeping systems:

•	 unallowable costs. Grantee incurred costs which were not approved in the original budget, were in 

excess of the approved budget, or were charged to the grant after the expiration date and a grant 

extension was not obtained.

•	 unsupported costs. Specific grant expenditures and reimbursements could not be supported by 

adequate documentation, or grant expenditures were in excess of actual grant costs.

•	 lack of complete/timely programmatic and financial reporting. Grantee failed to submit required 

programmatic and financial reports in a timely manner and/or had inadequate record keeping systems.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

61

•	 failure to retain. Grantee lacked documentation to support retention planning efforts during the grant 

period or failed to demonstrate an increase in the baseline of locally funded sworn officer positions 

at the conclusion of the 36 months of federal funding, over and above what the grantee would have 

funded in absence of the grant.

•	 supplanting. Grantee could not document efforts to backfill vacant local sworn officer positions, or 

grantee could not explain reductions in local law enforcement budget during the grant award period.

•	 lack of adequate community policing. Grantee had difficulty demonstrating community policing 

activities.

•	 funds to better use. Funds could be used more efficiently based on management actions such as

•	 reductions in outlays;

•	 deobligation of funds;

•	 withdrawal;

•	 costs not incurred by implementing recommended improvements;

•	 any other savings which are specifically identified.

•	 questioned costs. Costs that are questioned by the auditor because of an audit finding which resulted 

from a violation or possible violation of a provision of law, regulation, grant terms and conditions, or 

other document governing the use of federal funds; or because costs incurred appear unreasonable 

and do not reflect the actions a prudent person would take under the same circumstances; or because 

costs at the time of the audit are not supported by adequate documentation.

After the final OIG audit report has been issued, the COPS Office Audit Liaison Division will continue working 

as the liaison between your agency and the OIG to obtain closure on any audit findings. The COPS Office 

will issue a closure letter once all audit recommendations have been closed by the OIG. You must keep all 

documentation related to the audit for a period of three years following the audit’s closure.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

62

VI. Reports

As part of the TRGP, your agency will be required to submit quarterly Federal Financial Reports as well as 

quarterly Program Progress Reports. Awarded agencies should be prepared to track and report TRGP funding 

separately from other funding sources (including other COPS Office and federal grants) to ensure accurate 

financial and programmatic reporting on a timely basis. Your agency should ensure that you have financial 

internal controls in place to monitor the use of TRGP funding and ensure that its use is consistent with the 

grant terms and conditions. Good practices in this area include written accounting practices, an accounting 

system that tracks all drawdowns and grant expenditures, and the ability to track when each TRGP position 

is filled or vacant (including if the position was for a new hire or a rehire). Failure to submit complete reports, 

or submit them in a timely manner, may result in the suspension and possible termination of your agency’s COPS 

Office grant funding or other remedial actions.

Federal Financial Reports

Your agency is required to submit quarterly Federal Financial Reports using Standard Form 425 (SF-425) 

within 30 days after the end of each calendar quarter. A final SF-425 will be due within 90 days after the 

end of the grant period. This report reflects the actual cumulative federal expenditures incurred during the 

funding period, and the remaining unobligated balance of federal funds. Under federal regulations, your 

agency is not permitted to draw down federal funding for costs incurred after the official grant end date; 

however, you will have a 90-day grace period after the grant award end date during which you can draw 

down funds for eligible expenditures incurred before the grant end date.

How do we file a Federal Financial Report?

All COPS Office grantees are required to submit quarterly Federal Financial Reports using the SF-425. 

Grantees are strongly encouraged to submit the quarterly SF-425 online. Visit the COPS Office website 

at www.cops.usdoj.gov and select the “Account Access” link in the upper right corner to log in; once you 

are logged in, select “Applications” from the agency portal menu, click on the “SF-425” icon, and follow 

the instructions to complete and submit your reports. The online SF-425 requires the same reporting 

information as the paper version. The use of this online application enables authorized users to view past 

SF-425s, and allows them to file or amend the SF-425 for the current quarter. 

When are Federal Financial Reports due?

SF-425s for COPS Office grants must be submitted every quarter and no later than 30 days after the last day 

of each reporting quarter, as detailed below:

Table 1. Due dates of SF-425s by quarter

Reporting Quarters SF-425 Due Date

January 1–March 31 April 30

April 1–June 30 July 30

July 1–September 30 October 30

October 1–December 31 January 30

For your first SF-425 submission, determine when the most recent SF-425 reporting quarter ended and 

complete an SF-425 to cover the period from the award start date of your grant to that particular end date. 

You are required to submit an SF-425 even if you have not spent any money or incurred any costs during a 

reporting period. The due dates for online filing of SF-425s are the same as for the submission of paper copies.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

63

Example:

If your award start date is 02-01-13 and the current date is 04-15-13, then your first SF-425 would be due no 

later than 04-30-13 and would cover the period 02-01-13 (award start date) through 03-31-13 (end of the 

most recent reporting quarter). This SF-425 must be on file with the COPS Office so that you can successfully 

complete a drawdown of funds through GPRS.

Grantees who do not submit SF-425s by the due date will be unable to draw down funds. The payment 

system contains a function which checks for SF-425 delinquency and will reject a drawdown attempt if the 

SF-425 is not up to date. Subsequent e-mail, fax, or hard copy reminders may be sent to the grantee if the 

SF-425 is delinquent.

For general information concerning online filing of SF-425 reports, go to www.cops.usdoj.gov/Default.

asp?Item=740 or contact the COPS Office Response Center by phone at 800-421-6770 or by e-mail at 

AskCopsRC@usdoj.gov.

If you need assistance in completing the SF-425, please contact the COPS Office Response Center at 800-

421-6770 or by e-mail at AskCopsRC@usdoj.gov or review the “Helpful Hints Guide for Completing the 

Federal Financial Report (SF-425)” at www.cops.usdoj.gov/pdf/SF-425_Helpful_Hints_Guide_5.9.13.pdf.

How will grant funds be monitored?

The COPS Office and designated representatives from the Office of the Chief Financial Officer, Office of 

Justice Programs monitor the financial aspects of your agency’s grant through financial reports, on-site visits, 

office-based grant reviews, meetings, telephone contacts, reports, audits, reviews of grant change requests, 

and special request submissions.

Program Progress Reports

Quarterly Program Progress Reports and a Final Program Progress (Closeout) Report are required to be submitted 

directly to the COPS Office through the “Account Access” link of the COPS Office website at www.cops.usdoj.gov.

How do we file a Program Progress Report?

Please access the COPS Office website at www.cops.usdoj.gov and click on the “Account Access” link at the 

top right-hand side of the page. Once you are logged in, select “Applications” from the agency portal menu, 

click on the “Progress Report” icon, and follow the instructions to complete your report.

How do we obtain online access to complete the Program Progress Report?

If you do not have login access, you should contact your agency portal administrator to set up an account 

for you. 

If you have a registered account, but do not remember your password, you may reset your password by 

going to the agency portal homepage in “Account Access”, entering your e-mail address, and clicking on 

the “Forgot Password” link. If you do not have your user name or password, please contact the COPS Office 

Response Center by phone at 800-421-6770 (from Monday through Friday between 9:00 AM and 5:00 PM 

Eastern time) or by e-mail at AskCopsRC@usdoj.gov.

Do we need to request a Program Progress Report? 

No. The COPS Office will notify your agency directly when the report is due. A notification for submitting 

your quarterly Program Progress Report will be sent electronically in January, April, July, and October, 

covering activities for the preceding calendar quarter. Notification for submitting your Final Program 

Progress (Closeout) Report will be sent to your agency in the month following your grant end date.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

64

When are Program Progress Reports due?

Program Progress Reports for COPS Office grants must be submitted every quarter and no later than 30 days 

after the last day of each reporting quarter, as detailed below:

Table 2. Due dates of Program Progress Reports by quarter

Reporting Quarters Program Progress Report Due Date

January 1–March 31 April 30

April 1–June 30 July 30

July 1–September 30 October 30

October 1–December 31 January 30

What kind of information will these reports require? 

They will request information about the status of your agency’s hiring or rehiring of additional career law 

enforcement officers and your grant-related community policing activities.

What if we make a mistake or need to modify the report after it is submitted? 

Grantees may need to make a change or may be asked by a subsequent COPS Office reviewer to make 

a correction to a submission. The recipient can update the submission by logging on to the COPS Office 

website or by calling the COPS Office Progress Report Team at 800-659-7379.

Will the data that we submit be publicly available? 

Program Progress Reports submitted to the COPS Office may be reported publicly in response to a Freedom 

of Information Act (FOIA) request. 

If your agency has any questions regarding the submission of these required reports, please call the COPS 

Office Progress Report Team at 800-659-7379.

Contact points to obtain technical assistance and report violations

Any alleged violations, serious irregularities, or acts that may result in the use of public funds in a manner 

inconsistent with the Public Safety Partnership and Community Policing Act of 1994 or the purposes of 

this grant may be reported to the U.S. Department of Justice. Furthermore, the COPS Office welcomes 

the opportunity to provide assistance regarding the implementation of grant provisions to help ensure 

that federal grant funds are spent responsibly. As such, the following contacts are provided to address 

noncompliance and technical assistance issues:

•	 If you suspect violations of a criminal nature, please contact the U.S. Department of Justice, Office of 

the Inspector General (OIG) at www.justice.gov/oig/FOIA/hotline.htm, OIG.hotline@usdoj.gov, or 800-

869-4499. 

•	 If you suspect grant violations (not criminal in nature) related to the grant conditions listed in this 

manual, please contact the COPS Office Grant Monitoring Division at 202-514-9202.

•	 If you have any questions or need assistance regarding your grant, please contact your COPS Office 

Grant Program Specialist at 800-421-6770.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

65

VII. When the Grant Period Has Ended

At the end of your agency’s TRGP grant period, the COPS Office is responsible for the closeout of your grant. 

As part of this process, the COPS Office requires documentation demonstrating that your agency has met all 

of the programmatic and financial requirements of the grant.

After the end of the grant period, your agency will be asked to submit a final FFR and any applicable final 

program reports.

Final Federal Financial Report (SF-425)

The final FFR (SF-425) for your grant is due to the COPS Office no later than 90 days after the end date of the 

grant. The final report should reflect the total amount of allowable federal expenditures that were incurred 

during the life of the grant, as well as the amount of unobligated funds remaining, if any. In addition, once 

you have completed your final drawdown, this report should reconcile with the total amount of funds 

drawn down by your agency.

When should all of the grant monies be spent? 

Grant funds reflecting allowable project costs must be obligated before the end of the grant period. 

Obligated funds cover monies spent and expenses for all approved items in the FCM that your agency 

has incurred but not yet paid. Your agency has up to 90 days after the end of the grant period to request 

reimbursement for funds obligated.

Please be advised that 2 C.F.R. Part 200.343(a) requires grantees to submit final SF-425s and 2 C.F.R. Part 200.343(b) 

requires grantees to draw down the final reimbursement for expended funds within 90 days after the expiration 

of the grant. In addition, be advised that failure to complete the drawdown of funds within the 90-day period 

following award expiration will result in the forfeiture of the remaining eligible balance.

It is possible that your agency may have excess grant funds remaining in your account following the grant 

period due to an overestimate of item costs during the grant period. Your agency should review its records 

carefully to ensure that it draws down and expends only the amount required for actual costs incurred 

during the grant period. Any excess unobligated or unspent funds should remain in your account, and will 

be deobligated during the closeout process.

Final Program Progress (Closeout) Report

After your grant period has ended, your agency may be sent a final progress or closeout report from the 

COPS Office and asked to complete it. This report will serve as your agency’s final programmatic report on 

the grant, and the information your agency provides in this report will be used to make a final assessment of 

your grant progress.

Equipment disposition 

Each grantee must use any equipment funded through a COPS Office award for approved grant-related 

purposes and must retain the equipment for the life of the grant. After the conclusion of the grant period, 

property records must be maintained by the grantee. The records should include a description of the 

property; a serial number or other identification number; the source of the property; the name of the 

person or entity that holds the title; the acquisition date and cost of the property; the percentage of federal 

participation in the cost of the property; the location, use, and condition of the property; and any ultimate 

disposition data, including the date of disposal and sale price of the property. A control system must be 

developed to ensure adequate safeguards to prevent loss, damage, or theft of the property.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

66

When the grant has expired and original or replacement equipment obtained under the grant is no longer 

needed for the original project or for other activities currently or previously supported by a federal agency, 

disposition of the equipment shall be made as follows:

Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or 

otherwise disposed of with no further obligation to the awarding agency.

Items of equipment with a current per-unit fair market value in excess of $5,000 may be retained or sold 

and the awarding agency is entitled to an amount calculated by multiplying the current market value or 

proceeds from sale by the awarding agency’s federal share in the cost of the original purchase.

For more information, please see 2 C.F.R. § 200.313 as adopted by the U.S. Department of Justice in 2 C.F.R. § 

2800.101.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

67

VIII. Conclusion

We hope that this manual has assisted you and your agency with your grant questions. We welcome and 

encourage any comments you have regarding the COPS Office TRGP and the materials we have developed 

for its administration. If you have specific comments regarding this manual, please send them to:

U.S. Department of Justice

Office of Community Oriented Policing Services 

Attn: TRGP/CTAS Control Desk

145 N Street NE

Washington, DC 20530

If you have any questions about your grant, please call your COPS Office Grant Program Specialist or the 

COPS Office Response Center at 800-421-6770.

Pursuant to Executive Order 13513, “Federal Leadership on Reducing Text Messaging While Driving,” the 

COPS Office encourages recipients of U.S. Department of Justice funds to adopt and enforce policies that 

ban text messaging while driving and to establish workplace safety policies to decrease crashes caused by 

distracted drivers.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

68

Appendices

Appendix A. List of source documents

A. Primary sources

Public Safety Partnership and Community Policing Act of 1994, 42 U.S.C.

B. Secondary sources

Code of Federal Regulations (CFR)/Office of Management and Budget (OMB):

2 C.F.R. Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards) as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101

2 C.F.R. Part 200.305(b)(9), “Payment-Remittance of Interest Earned”

4 C.F.R. Parts 101-105, U.S. Department of Justice/Government Accountability Office, “Joint Federal Claims 

Collections Standards”

5 C.F.R. Part 1320, “Controlling the Paperwork Burden on the Public”

5 C.F.R. Part 151, “Political Activities of State and Local Officials or Employees”

28 C.F.R. Part 23, “Criminal Intelligence Systems Operating Policies”

28 C.F.R. Part 61, “Procedures for Implementing the National Environmental Policy Act”

28 C.F.R. Part 67, “Government-wide Requirements for Drug-Free Workplaces (Grants)”

28 C.F.R. Part 69, “Government-wide New Restrictions on Lobbying”

31 C.F.R. Part 205, “Treasury Department Regulations Implementing for Cash Management Improvement Act 

of 1990”

OMB Circular A-129, “Managing Federal Credit Programs”

48 C.F.R. Part 31.000, et seq. (FAR-31.2), “Cost Principles for Commercial Organizations”

Executive Orders

Executive Order 12291, “Regulations”

Executive Order 12372, 28 C.F.R. Part 30, “Intergovernmental Review of Federal Programs”

Executive Order 12547, “Non-Procurement Debarments and Suspension”
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

69

Appendix B. Assurances and Certifications

Assurances

The Applicant hereby assures and certifies compliance with all applicable Federal statutes, regulations, 

policies, guidelines, and requirements, including OMB Circulars A-21, A-87, A-102, A-110, A-122, A- 133; 

Ex. Order 12372 (intergovernmental review of federal programs); and 28 C.F.R. pts. 66 or 70 (administrative 

requirements for grants and cooperative agreements). The applicant also specifically assures and certifies that: 

1. It has the legal authority to apply for federal assistance and the institutional, managerial, and financial 

capability (including funds sufficient to pay any required nonfederal share of project cost) to ensure 

proper planning, management, and completion of the project described in this application. 

2. It will establish safeguards to prohibit employees from using their positions for a purpose that 

constitutes or presents the appearance of personal or organizational conflict of interest, or personal 

gain. 

3. It will give the awarding agency or the General Accounting Office, through any authorized 

representative, access to and the right to examine all paper or electronic records related to the financial 

assistance. 

4. It will comply with all lawful requirements imposed by the awarding agency, specifically including any 

applicable regulations, such as 28 C.F.R. pts. 18, 22, 23, 30, 35, 38, 42, 61, and 63, and the award term in 2 

C.F.R. § 175.15(b). 

5. It will assist the awarding agency (if necessary) in assuring compliance with section 106 of the National 

Historic Preservation Act of 1966 (16 U.S.C. § 470), Ex. Order 11593 (identification and protection of 

historic properties), the Archeological and Historical Preservation Act of 1974 (16 U.S.C.§ 469 a-1 et seq.), 

and the National Environmental Policy Act of 1969 (42 U.S.C. § 4321). 

6. It will comply (and will require any subgrantees or contractors to comply) with any applicable statutorily 

imposed nondiscrimination requirements, which may include the Omnibus Crime Control and Safe 

Streets Act of 1968 (42 U.S.C. § 3789d); the Victims of Crime Act (42 U.S.C. §10604(e)); The Juvenile Justice 

and Delinquency Prevention Act of 2002 (42 U.S.C. § 5672(b)); the Civil Rights Act of 1964 (42 U.S.C. § 

2000d); the Rehabilitation Act of 1973 (29 U.S.C. §7 94); the Americans with Disabilities Act of 1990 (42 

U.S.C.§ 12131-34); the Education Amendments of 1972 (20 U.S.C. §§1681, 1683, 1685-86); and the Age 

Discrimination Act of 1975 (42 U.S.C. §§ 6101-07); see Ex. Order 13279 (equal protection of the laws for 

faith-based and community organizations). 

7. If a governmental entity– 

A. it will comply with the requirements of the Uniform Relocation Assistance and Real Property 

Acquisitions Act of 1970 (42 U.S.C.§ 4601 et seq.), which govern the treatment of persons displaced 

as a result of federal and federally-assisted programs; and 

B. it will comply with requirements of 5 U.S.C.§§ 1501-08 and §§7324-28, which limit certain political 

activities of State or local government employees whose principal employment is in connection 

with an activity financed in whole or in part by federal assistance. 

__________________________________ __________________ 

Signature Date

Certifications

Applicants should refer to the regulations cited below to determine the certification to which they are 

required to attest. Applicants should also review the instructions for certification included in the regulations 

before completing this form. Signature of this form provides for compliance with certification requirements 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

70

under 28 CFR Part 69, “New Restrictions on Lobbying” and 28 CFR Part 67, “Government-wide Debarment and 

Suspension (Nonprocurement) and Government-wide Requirements for Drug-Free Workplace (Grants).” The 

certifications shall be treated as a material representation of fact upon which reliance will be placed when 

the Department of Justice determines to award the covered transaction, grant, or cooperative agreement.

1. Lobbying

As required by Section 1352, Title 31 of the U.S. Code, and implemented at 28 CFR Part 69, for persons 

entering into a grant or cooperative agreement over $100,000, as defined at 28 CFR Part 69, the 

applicant certifies that:

A. No federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, 

to any person for influencing or attempting to influence an officer or employee of any agency, 

a member of Congress, an officer or employee of Congress, or an employee of a member of 

Congress in connection with the making of any Federal grant, the entering into of any cooperative 

agreement, and the extension, continuation, renewal, amendment, or modification of any federal 

grant or cooperative agreement;

B. If any funds other than federal appropriated funds have been paid or will be paid to any person 

for influencing or attempting to influence an officer or employee of any agency, a member 

of Congress, an officer or employee of Congress, or an employee of a member of Congress in 

connection with this Federal grant or cooperative agreement, the undersigned shall complete and 

submit Standard Form - LLL, “Disclosure of Lobbying Activities,” in accordance with its instructions;

C. The undersigned shall require that the language of this certification be included in the award 

documents for all subawards at all tiers (including subgrants, contracts under grants and 

cooperative agreements, and subcontracts) and that all sub-recipients shall certify and disclose 

accordingly.

2. Debarment, suspension, and other responsibility matters (direct recipient)

As required by Executive Order 12549, Debarment and Suspension, and implemented at 28 CFR Part 

67, for prospective participants in primary covered transactions, as defined at 28 CFR Part 67, Section 

67.510

A. The applicant certifies that it and its principals:

a. Are not presently debarred, suspended, proposed for debarment, declared ineligible, 

sentenced to a denial of federal benefits by a state or federal court, or voluntarily excluded 

from covered transactions by any federal department or agency;

b. Have not within a three-year period preceding this application been convicted of or had 

a civil judgment rendered against them for commission of fraud or a criminal offense in 

connection with obtaining, attempting to obtain, or performing a public (federal, state, 

or local) transaction or contract under a public transaction; violation of federal or state 

antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or 

destruction of records, making false statements, or receiving stolen property;

c. Are not presently indicted for or otherwise criminally or civilly charged by a governmental 

entity (federal, state, or local) with commission of any of the offenses enumerated in 

paragraph (1)(b) of this certification; and

d. Have not within a three-year period preceding this application had one or more public 

transactions (federal, State, or local) terminated for cause or default; and
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

71

B. Where the applicant is unable to certify to any of the statements in this certification, he or she shall 

attach an explanation to this application.

3. Drug-free workplace (grantees other than individuals)

As required by the Drug-Free Workplace Act of 1988, and implemented at 28 CFR Part 67, Subpart F, for 

grantees, as defined at 28 CFR Part 67 Sections 67.615 and 67.620

A. The applicant certifies that it will or will continue to provide a drug-free workplace by:

a. Publishing a statement notifying employees that the unlawful manufacture, distribution, 

dispensing, possession, or use of a controlled substance is prohibited in the grantee’s 

workplace and specifying the actions that will be taken against employees for violation of such 

prohibition;

b. Establishing an ongoing drug-free awareness program to inform employees about

1. The dangers of drug abuse in the workplace;

2. The grantee’s policy of maintaining a drug-free workplace;

3. Any available drug counseling, rehabilitation, and employee assistance programs; and

4. The penalties that may be imposed upon employees for drug abuse violations occurring 

in the workplace;

c. Making it a requirement that each employee to be engaged in the performance of the grant 

be given a copy of the statement required by paragraph (a);

d. Notifying the employee in the statement required by paragraph (a) that, as a condition of 

employment under the grant, the employee will

1. Abide by the terms of the statement; and

2. Notify the employer in writing of his or her conviction for a violation of a criminal drug 

statute occurring in the workplace no later than five calendar days after such conviction;

e. Notifying the agency, in writing, within 10 calendar days after receiving notice under 

subparagraph (d)(2) from an employee or otherwise receiving actual notice of such conviction. 

Employers of convicted employees must provide notice, including position title, to:

U.S. Department of Justice

Office of Justice Programs

ATTN: Control Desk

810 Seventh Street, NW

Washington, D.C. 20531

Notice shall include the identification number(s) of each affected grant;

f. Taking one of the following actions, within 30 calendar days of receiving notice under 

subparagraph (d)(2), with respect to any employee who is so convicted

1. Taking appropriate personnel action against such an employee, up to and including 

termination, consistent with the requirements of the Rehabilitation Act of 1973, as 

amended; or
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

72

2. Requiring such employee to participate satisfactorily in a drug abuse assistance or 

rehabilitation program approved for such purposes by a federal, state, or local health, law 

enforcement, or other appropriate agency;

g. Making a good faith effort to continue to maintain a drug-free workplace through 

implementation of paragraphs (a), (b), (c), (d), (e), and (f ).

B. The grantee may insert in the space provided below the site(s) for the performance of work done in 

connection with the specific grant:

Place of Performance (Street address, city, county, state, zip code)

Check ___ if there are workplaces on file that are not identified here.

Section 67, 630 of the regulations provides that a grantee that is a state may elect to make one 

certification in each federal fiscal year. A copy of which should be included with each application 

for U.S. Department of Justice funding. States and state agencies may elect to use OJP Form 4061/7.

Check ___ if the state has elected to complete OJP Form 4061/7.

Drug-free workplace (grantees who are individuals)

As required by the Drug-Free Workplace Act of 1988, and implemented at 28 CFR Part 67, Subpart F, for 

grantees, as defined at 28 CFR Part 67; Sections 67.615 and 67.620

A. As a condition of the grant, I certify that I will not engage in the unlawful manufacture, distribution, 

dispensing, possession, or use of a controlled substance in conducting any activity with the grant; 

and

B. If convicted of a criminal drug offense resulting from a violation occurring during the conduct of 

any grant activity, I will report the conviction, in writing, within 10 calendar days of the conviction, 

to:

U.S. Department of Justice

Office of Justice Programs

ATTN: Control Desk

810 Seventh Street, NW

Washington, D.C. 20531

As the duly authorized representative of the applicant, I hereby certify that the applicant will comply with 

the above certifications.

1. Grantee Name and Address:

2. Application Number and/or Project Name:

3. Grantee IRS/Vendor Number __________________________________________

4. Type/Print Name and Title of Authorized Representative

5. Signature

6. Date
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

73

Appendix C. Community policing defined

Community policing is a philosophy that promotes organizational strategies that support the systematic use 

of partnerships and problem-solving techniques, to proactively address the immediate conditions that give 

rise to public safety issues such as crime, social disorder, and fear of crime. 

Community policing comprises three key components:

1. Community partnerships

2. Organizational transformation

3. Problem solving

Community partnerships

Community partnerships are collaborative partnerships between the law enforcement agency and the 

individuals and organizations they serve to develop solutions to problems and increase trust in police.

Community policing, recognizing that police rarely can solve public safety problems alone, encourages 

interactive partnerships with relevant stakeholders. The range of potential partners is large and these 

partnerships can be used to accomplish the two interrelated goals of developing solutions to problems 

through collaborative problem solving and improving public trust. The public should play a role in 

prioritizing and addressing public safety problems.

Other government agencies

Law enforcement organizations can partner with a number of other government agencies to identify 

community concerns and offer alternative solutions. Examples of agencies include legislative bodies, 

prosecutors, probation and parole departments, public works departments, neighboring law enforcement 

agencies, health and human services departments, child support services, ordinance enforcement, and 

schools.

Community members or groups

Individuals who live, work, or otherwise have an interest in the community—volunteers, activists, formal 

and informal community leaders, residents, visitors and tourists, and commuters—are a valuable resource 

for identifying community concerns. These factions of the community can be engaged in achieving specific 

goals at town hall meetings, neighborhood association meetings, decentralized offices or storefronts in the 

community, and team beat assignments.

Nonprofits or service providers

Advocacy and community-based organizations that provide services to the community and advocate on its 

behalf can be powerful partners. These groups often work with or are composed of individuals who share 

common interests and can include such entities as victims groups, service clubs, support groups, issue 

groups, advocacy groups, community development corporations, and the faith community.

Private businesses

For-profit businesses also have a great stake in the health of the community and can be key partners 

because they often bring considerable resources to bear in addressing problems of mutual concern. 

Businesses can help identify problems and provide resources for responses, often including their own 

security technology and community outreach. The local chamber of commerce and visitor centers can 

also assist in disseminating information about police and business partnerships and initiatives, and crime 

prevention practices.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

74

Media

The media represent a powerful mechanism by which to communicate with the community. They can 

assist with publicizing community concerns and available solutions, such as services from government 

or community agencies or new laws or codes that will be enforced. In addition, the media can have a 

significant impact on public perceptions of the police, crime problems, and fear of crime.

Organizational transformation 

Organizational transformation is the alignment of organizational management, structure, personnel, and 

information systems to support community partnerships and proactive problem-solving efforts.

The community policing philosophy focuses on the way departments are organized and managed and 

how the infrastructure can be changed to support the philosophical shift behind community policing. It 

encourages the application of modern management practices to increase efficiency and effectiveness. 

Community policing emphasizes changes in organizational structures to institutionalize its adoption and 

infuse it throughout the entire department, including the way it is managed and organized, its personnel, 

and its technology.

Agency management

Under the community policing model, police management diffuses community policing ideals throughout 

the agency by making a number of critical changes in climate and culture, leadership, formal labor 

relations, decentralized decision making and accountability, strategic planning, policies and procedures, 

organizational evaluations, and increased transparency.

Climate and culture Changing the climate and culture means supporting a proactive orientation that values 

systematic problem solving and partnerships. Formal organizational changes should support the informal 

networks and communication that take place within agencies to support this orientation.

Leadership Leaders serve as role models for taking risks and building collaborative relationships to 

implement community policing and they use their position to influence and educate others about it. 

Leaders, therefore, must constantly emphasize and reinforce community policing’s vision, values, and 

mission within their organization and support and articulate a commitment to community policing as the 

predominant way of doing business.

Labor relations If community policing is going to be effective, police unions and similar forms of organized 

labor must be a part of the process and function as partners in the adoption of the community policing 

philosophy. Including labor groups in agency changes can ensure support for the changes that are 

imperative to community policing implementation.

Decision making Community policing calls for decentralization both in command structure and decisionmaking. Decentralized decision-making allows front-line officers to take responsibility for their role in 

community policing. When an officer is able to create solutions to problems and take risks, he or she 

ultimately feels accountable for those solutions and assumes a greater responsibility for the well-being of 

the community. Decentralized decision-making involves flattening the hierarchy of the agency, increasing 

tolerance for risk-taking in problem-solving efforts, and allowing officers discretion in handling calls. In 

addition, providing sufficient authority to coordinate various resources to attack a problem and allowing 

officers the autonomy to establish relationships with the community will help define problems and develop 

possible solutions.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

75

Strategic planning The department should have a written statement reflecting a department-wide 

commitment to community policing and a plan that matches operational needs to available resources and 

expertise. If a strategic plan is to have value, the members of the organization should be well-versed in it 

and be able to give examples of their efforts supporting the plan. Components such as the organization’s 

mission and values statement should be simple and communicated widely. 

Policies Community policing affects the nature and development of department policies and procedures to 

ensure that community policing principles and practices have an effect on activities on the street. Problem 

solving and partnerships, therefore, should become institutionalized in policies, along with corresponding 

sets of procedures, where appropriate.

Organizational evaluations In addition to the typical measures of police performance (arrests, response 

times, tickets issued, and crime rates), community policing calls for a broadening of police outcome 

measures to include such things as greater community satisfaction, less fear of crime, the alleviation of 

problems, and improvement in quality of life. Community policing calls for a more sophisticated approach to 

evaluation—one that looks at how feedback information is used, not only how outcomes are measured.

Transparency Community policing involves decision-making processes that are more open than traditional 

policing. If the community is to be a full partner, the department needs mechanisms for readily sharing 

relevant information on crime and social disorder problems and police operations with the community.

Organizational structure It is important that the organizational structure of the agency ensure that local 

patrol officers have decision-making authority and are accountable for their actions. This can be achieved 

through long-term assignments, the development of officers who are generalists and using special units 

appropriately.

Geographic assignment of officers With community policing, there is a shift to the long-term assignment 

of officers to specific neighborhoods or areas. Geographic deployment plans can help enhance customer 

service and facilitate more contact between police and citizens, thus establishing a strong relationship 

and mutual accountability. Beat boundaries should correspond to neighborhood boundaries and other 

government services should recognize these boundaries when coordinating government public-service 

activities.

Despecialization To achieve community policing goals, officers have to be able to handle multiple 

responsibilities and take a team approach to collaborative problem solving and partnering with the 

community. Community policing encourages its adoption agency-wide, not just in special units, although 

there may be a need for some specialist units that are tasked with identifying and solving particularly 

complex problems or managing complex partnerships.

Resources and finances Agencies have to devote the necessary human and financial resources to support 

community policing to ensure that problem-solving efforts are robust and that partnerships are sustained 

and effective.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

76

Personnel

The principles of community policing need to be diffused throughout the entire personnel system of an 

agency including recruitment, hiring, selection, and retention of all law enforcement agency staff, from 

sworn officers to civilians and volunteers. Personnel evaluations, supervision, and training must also be 

aligned with the agencies’ community policing values.

Recruitment, hiring, and selection Agencies need a systematic means of incorporating community 

policing elements into their recruitment, selection, and hiring processes. Job descriptions should recognize 

community policing and problem-solving responsibilities and encourage the recruitment of officers 

who have a spirit of service, instead of only a spirit of adventure. A community policing agency must also 

thoughtfully examine where it is seeking recruits, whom it is recruiting and hiring, and what is being tested. 

Agencies are also encouraged to seek community involvement in this process through the identification of 

competencies and participation in review boards.

Personnel supervision/evaluations Supervisors must tie performance evaluations to community policing 

principles and activities that are incorporated into job descriptions. Performance, reward, and promotional 

procedures should support sound problem-solving activities, proactive policing, community collaboration, 

and citizen satisfaction with police services.

Training Training at all levels—academy, field, and in-service—must support community policing principles 

and tactics. It also needs to encourage creative thinking, a proactive orientation, communication and 

analytical skills, and techniques for dealing with quality-of-life concerns and maintaining order. Officers 

can be trained to identify and correct conditions that could lead to crime, to raise public awareness, and 

to engage the community in finding solutions to problems. Field training officers and supervisors need to 

learn how to encourage problem solving and help officers learn from other problem-solving initiatives. Until 

community policing is institutionalized in the organization, training in its fundamental principles will need to 

take place regularly.

Information systems (technology) 

Community policing is information-intensive, and technology plays a central role in helping to provide ready 

access to quality information. Accurate and timely information makes problem-solving efforts more effective 

and ensures that officers are informed about the crime and community conditions of their beat. In addition, 

technological enhancements can greatly assist with improving two-way communication with citizens and in 

developing agency accountability systems and performance outcome measures.

Communication/access to data Technology provides agencies with an important forum by which to 

communicate externally with the public and internally with their own staff. To communicate with the 

public, community policing encourages agencies to develop two-way communication systems through 

the Internet that allow for online reports, reverse 911 and e-mail alerts, discussion forums, and feedback on 

interactive applications (surveys, maps), thereby creating ongoing dialogues and increasing transparency.

Technology encourages effective internal communication through memoranda, reports, newsletters, 

e-mail and enhanced incident reporting, dispatch functions, and communications interoperability with 

other entities for more efficient operations. Community policing also encourages the use of technology to 

develop accountability and performance measurement systems that are timely and contain accurate metrics 

and a broad array of measures and information.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

77

Community policing encourages the use of technology to provide officers with ready access to timely 

information on crime and community characteristics within their beats, either through laptop computers 

in their patrol cars or through personal data devices. In addition, technology can support crime/problem 

analysis functions by enabling agencies to gather more detailed information about offenders, victims, crime 

locations, and quality-of-life concerns, and to further enhance analysis.

SAFECOM Guidance The U.S. Department of Homeland Security Office of Emergency Communications, in 

coordination with various stakeholder groups, develops the annual SAFECOM Guidance on Emergency 

Communications Grants. The guidance provides recommendations to grantees seeking funding for 

interoperable emergency communications projects, including allowable costs, items to consider when 

funding emergency communications projects, grants management best practices for emergency 

communications grants, and information on standards that ensure greater interoperability. The guidance 

is intended to ensure that federally funded investments are compatible and support national goals and 

objectives for improving interoperability nationwide. Grantees (including sub-grantees) that are using 

TRGP funds to support emergency communications activities should comply with the latest version of 

SAFECOM Guidance, including provisions on technical standards that ensure and enhance interoperable 

communications. The most recent version of SAFECOM Guidance is available at: www.safecomprogram.

gov/grant/Default.aspx.

Quality and accuracy of data Information is only as good as its source, and therefore it is not useful if it is of 

questionable quality and accuracy. Community policing encourages agencies to put safeguards in place to 

ensure that information from various sources is collected in a systematic fashion and entered into central 

systems that are linked to one another and checked for accuracy so that it can be used effectively for 

strategic planning, problem solving, and performance measurement.

Problem solving

Problem solving is the process of engaging in the proactive and systematic examination of identified 

problems to develop and evaluate effective responses.

Community policing emphasizes proactive problem solving in a systematic and routine fashion. Rather than 

responding to crime only after it occurs, community policing encourages agencies to proactively develop 

solutions to the immediate underlying conditions contributing to public safety problems. Problem solving 

must be infused into all police operations and guide decision-making efforts. Agencies are encouraged to 

think innovatively about their responses and view making arrests as only one of a wide array of potential 

responses. A major conceptual vehicle for helping officers to think about problem solving in a structured 

and disciplined way is the SARA (Scanning, Analysis, Response, and Assessment) problem-solving model.

Scanning: Identifying and prioritizing problems

The objectives of scanning are to identify a basic problem, determine the nature of that problem, determine 

the scope of seriousness of the problem, and establish baseline measures. An inclusive list of stakeholders 

for the selected problem is typically identified in this phase. A problem can be thought of as two or more 

incidents that are similar in one or more ways and that are of concern to the police and the community. 

Problems can be a type of behavior, a place, a person or persons, a special event or time, or a combination of 

any of these. The police, with input from the community, should identify and prioritize concerns.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

78

Analysis: Researching what is known about the problem

Analysis is the heart of the problem-solving process. The objectives of analysis are to develop an 

understanding of the dynamics of the problem, develop an understanding of the limits of current responses, 

establish correlation, and develop an understanding of cause and effect. As part of the analysis phase, it is 

important to find out as much as possible about each aspect of the crime triangle by asking who?, what?, 

when?, where?, how?, why?, and why not? about the victim, offender, and crime location.

Response: Developing solutions to bring about lasting reductions in the number and extent of 

problems

The response phase of the SARA model involves developing and implementing strategies to address an 

identified problem by searching for strategic responses that are both broad and uninhibited. The response 

should follow logically from the knowledge learned during the analysis and should be tailored to the specific 

problem. The goals of the response can range from totally eliminating the problem through substantially 

reducing the problem or reducing the amount of harm caused by the problem to improving the quality of 

community cohesion.

Assessment: Evaluating the success of the responses

Assessment attempts to determine if the response strategies were successful by understanding if the 

problem declined and if the response contributed to the decline. This information not only assists the 

current effort but also gathers data that build knowledge for the future. Strategies and programs can be 

assessed for process, outcomes, or both. If the responses implemented are not effective, the information 

gathered during analysis should be reviewed. New information may have to be collected before new 

solutions can be developed and tested. The entire process should be viewed as circular rather than linear, 

meaning that additional scanning, analysis, or responses may be required.

Using the crime triangle to focus on immediate conditions (victim/offender/ location)

To understand a problem, many problem solvers have found it useful to visualize links among the victim, 

offender, and location (the crime triangle) and those factors that could have an impact on them, for 

example, capable guardians for victims (e.g., security guards, teachers, and neighbors), handlers for offenders 

(e.g., parents, friends, and probation officers), and managers for locations (e.g., business merchants, park 

employees, and motel clerks). Rather than focusing primarily on addressing the root causes of a problem, the 

police focus on the factors that are within their reach, such as limiting criminal opportunities and access to 

victims, increasing guardianship, and associating risk with unwanted behavior.

Appendix D. National Institute of Justice (NIJ) bulletproof vest standards

The following information was adapted from NIJ Guide 100-98, “Selection and Application Guide to Police 

Body Armor.” The publication in its entirety may be requested from:

National Law Enforcement and Corrections Technology Center (NLECTC) 

2277 Research Boulevard

Rockville, MD 20850

800-248-2742

The publication may also be downloaded from the Center’s website: www.justnet.org/Pages/home.aspx.

“NIJ’s policy on body armor has always been that preserving the life of the police officer 

is the sole criteria on which to judge body armor effectiveness. At present, an officer may 

select a garment that corresponds to an appropriate threat level and be confident that 

armor in compliance with NIJ’s standard will defeat the stated threat level.”
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

79

Type I (.22 LR; .38 Special)

Type I body armor is light. This is the minimum level of protection every officer should have, and the armor 

should be routinely worn at all times while on duty. Type I body armor was the armor issued during the NIJ 

demonstration project in the mid-1970s. Most agencies today, however, because of increasing threats, opt 

for a higher level of protection.

This armor protects against .22 long rifle high-velocity lead bullets, with nominal masses of 2.6 g (40 gr), 

impacting at a velocity of 320 m/s (1,050 ft/s) or less, and against .38 special round-nose lead bullets, with 

nominal masses of 10.2 g (158 gr), impacting at a velocity of 259 m/s (850 ft/s) or less. It also provides 

protection against most other .25 and .32 caliber handgun rounds.

Type II-A (lower velocity .357 Magnum; 9mm)

Type II-A body armor is well suited for full-time use by police departments, particularly those seeking 

protection for their officers from lower velocity .357 Magnum and 9mm ammunition.

This armor protects against .357 Magnum jacketed soft-point bullets, with nominal masses of 10.2 g (158 

gr), impacting at a velocity of 381 m/s (1,250 ft/s) or less, and against 9mm full-metal jacketed bullets, with 

nominal masses of 8.0 g (124 gr), impacting at a velocity of 332 m/s (1,175 ft/s). It also protects against such 

threats as .45 auto., .38 special +P, and some other factory loads in caliber .357 Magnum and 9mm as well as 

the Type I threats.

Type II (higher velocity .357 Magnum; 9mm)

Type II body armor is heavier and bulkier than either Types I or II-A. It is worn full-time by officers seeking 

protection against higher velocity .357 Magnum and 9mm ammunition.

This armor protects against .357 Magnum jacketed soft-point bullets, with nominal masses of 10.2 g (158 gr), 

impacting at a velocity of 425 m/s (1,395 ft/s) or less, and against 9mm full-jacketed bullets, with nominal 

velocities of 358 m/s (1,175 ft/s). It also protects against most other factory loads in caliber .357 Magnum and 

9mm as well as the Type I and II-A threats.

Type III-A (.44 Magnum; submachine gun 9mm)

Type III-A body armor provides the highest level of protection currently available from concealable body 

armor and is generally suitable for routine wear in many situations. However, departments located in hot, 

humid climates may need to evaluate the use of Type III-A armor carefully.

This armor protects against .44 Magnum lead semi-wadcutter bullets with gas checks, nominal masses of 

15.55 g (240 gr), impacting at a velocity of 426 m/s (1,400 ft/s) or less. It also provides protection against 

most handgun threats as well as the Type I, II-A, and II threats.

Type III (high-powered rifle)

Type III body armor is clearly intended only for tactical situations when the threat warrants such protection, 

such as barricade confrontations involving sporting rifles.

This armor, normally of hard or semi-rigid construction, protects against 7.62 mm full-metal jacketed bullets 

(U.S. military designation M80), with nominal masses of 9.7 g (150 gr), impacting at a velocity of 838 m/s 

(2,750 ft/s) or less. It also provides protection against threats such as 223 Remington (5.56 mm FMJ), 30 

Carbine FMJ, and 12-gauge rifled slug, as well as the Type I through III-A threats.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

80

Type IV (armor-piercing rifle)

Type IV body armor provides the highest level of protection currently available. Because this armor is intended 

to resist armor piercing bullets, it often uses ceramic materials. Such materials are brittle in nature and may 

provide only single-shot protection, since the ceramic tends to break up when struck. As with Type III armor, 

Type IV armor is clearly intended only for tactical situations when the threats warrant such protection.

This armor protects against .30-06 caliber armor-piercing bullets (U.S. military designation AMP2), with 

nominal masses of 10.8 g (166 gr), impacting at a velocity of 868 m/s (2,850 ft/s) or less. It also provides at 

least single-hit protection against the Type I through III threats.

Special type

A purchaser who has a special requirement for a level of protection other than one of the above standard 

threat levels should specify the exact test rounds and minimum impact velocities to be used and indicate 

that this standard shall govern in all other respects.

Appendix E. Whistleblower protection (41 U.S.C. 4712)

41 U.S.C. 4712. Pilot program for enhancement of contractor protection from reprisal for disclosure of certain 

information

(a). Prohibition of reprisals.—

(1). In general.—An employee of a contractor, subcontractor, or grantee may not be discharged, 

demoted, or otherwise discriminated against as a reprisal for disclosing to a person or body described in 

paragraph (2) information that the employee reasonably believes is evidence of gross mismanagement 

of a Federal contract or grant, a gross waste of Federal funds, an abuse of authority relating to a Federal 

contract or grant, a substantial and specific danger to public health or safety, or a violation of law, rule, 

or regulation related to a Federal contract (including the competition for or negotiation of a contract) or 

grant.

(2). Persons and bodies covered.—The persons and bodies described in this paragraph are the persons 

and bodies as follows:

(A). A Member of Congress or a representative of a committee of Congress.

(B). An Inspector General.

(C). The Government Accountability Office.

(D). A Federal employee responsible for contract or grant oversight or management at the relevant 

agency.

(E). An authorized official of the U.S. Department of Justice or other law enforcement agency.

(F). A court or grand jury.

(G). A management official or other employee of the contractor, subcontractor, or grantee who has 

the responsibility to investigate, discover, or address misconduct.

(3). Rules of construction.—For the purposes of paragraph (1)—

(A). an employee who initiates or provides evidence of contractor, subcontractor, or grantee 

misconduct in any judicial or administrative proceeding relating to waste, fraud, or abuse on a 

Federal contract or grant shall be deemed to have made a disclosure covered by such paragraph; 

and
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

81

(B). a reprisal described in paragraph (1) is prohibited even if it is undertaken at the request of an 

executive branch official, unless the request takes the form of a non-discretionary directive and is 

within the authority of the executive branch official making the request.

(b). Investigation of complaints.—

(1). Submission of complaint.—A person who believes that the person has been subjected to a reprisal 

prohibited by subsection (a) may submit a complaint to the Inspector General of the executive agency 

involved. Unless the Inspector General determines that the complaint is frivolous, fails to allege a 

violation of the prohibition in subsection (a), or has previously been addressed in another Federal or 

State judicial or administrative proceeding initiated by the complainant, the Inspector General shall 

investigate the complaint and, upon completion of such investigation, submit a report of the findings of 

the investigation to the person, the contractor or grantee concerned, and the head of the agency.

(2). Inspector General action.—

(A). Determination or submission of report on findings.—Except as provided under subparagraph 

(B), the Inspector General shall make a determination that a complaint is frivolous, fails to allege a 

violation of the prohibition in subsection (a), or has previously been addressed in another Federal 

or State judicial or administrative proceeding initiated by the complainant or submit a report under 

paragraph (1) within 180 days after receiving the complaint.

(B). Extension of time.—If the Inspector General is unable to complete an investigation in time to 

submit a report within the 180-day period specified in subparagraph (A) and the person submitting 

the complaint agrees to an extension of time, the Inspector General shall submit a report under 

paragraph (1) within such additional period of time, up to 180 days, as shall be agreed upon 

between the Inspector General and the person submitting the complaint.

(3). Prohibition on disclosure.—The Inspector General may not respond to any inquiry or 

disclose any information from or about any person alleging the reprisal, except to the extent that such 

response or disclosure is—

(A). made with the consent of the person alleging the reprisal;

(B). made in accordance with the provisions of section 552a of title 5 or as required by any other 

applicable Federal law; or

(C). necessary to conduct an investigation of the alleged reprisal.

(4). Time limitation.—A complaint may not be brought under this subsection more than three years 

after the date on which the alleged reprisal took place.

(c). Remedy and enforcement authority.—

(1). In general.—Not later than 30 days after receiving an Inspector General report pursuant to 

subsection (b), the head of the executive agency concerned shall determine whether there is sufficient 

basis to conclude that the contractor or grantee concerned has subjected the complainant to a reprisal 

prohibited by subsection (a) and shall either issue an order denying relief or shall take one or more of 

the following actions:

(A). Order the contractor or grantee to take affirmative action to abate the reprisal.

(B). Order the contractor or grantee to reinstate the person to the position that the person held 

before the reprisal, together with compensatory damages (including back pay), employment 

benefits, and other terms and conditions of employment that would apply to the person in that 

position if the reprisal had not been taken.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

82

(C). Order the contractor or grantee to pay the complainant an amount equal to the aggregate 

amount of all costs and expenses (including attorneys’ fees and expert witnesses’ fees) that 

were reasonably incurred by the complainant for, or in connection with, bringing the complaint 

regarding the reprisal, as determined by the head of the executive agency.

(2). Exhaustion of remedies.—If the head of an executive agency issues an order denying relief under 

paragraph (1) or has not issued an order within 210 days after the submission of a complaint under 

subsection (b), or in the case of an extension of time under paragraph (b)(2)(B), not later than 30 days 

after the expiration of the extension of time, and there is no showing that such delay is due to the 

bad faith of the complainant, the complainant shall be deemed to have exhausted all administrative 

remedies with respect to the complaint, and the complainant may bring a de novo action at law or 

equity against the contractor or grantee to seek compensatory damages and other relief available 

under this section in the appropriate district court of the United States, which shall have jurisdiction 

over such an action without regard to the amount in controversy. Such an action shall, at the request of 

either party to the action, be tried by the court with a jury. An action under this paragraph may not be 

brought more than two years after the date on which remedies are deemed to have been exhausted.

(3). Admissibility of evidence.—An Inspector General determination and an agency head order 

denying relief under paragraph (2) shall be admissible in evidence in any de novo action at law or equity 

brought pursuant to this subsection.

(4). Enforcement of orders.—Whenever a person fails to comply with an order issued under paragraph 

(1), the head of the executive agency concerned shall file an action for enforcement of such order in 

the United States district court for a district in which the reprisal was found to have occurred. In any 

action brought under this paragraph, the court may grant appropriate relief, including injunctive relief, 

compensatory and exemplary damages, and attorney fees and costs. The person upon whose behalf 

an order was issued may also file such an action or join in an action filed by the head of the executive 

agency.

(5). Judicial review.—Any person adversely affected or aggrieved by an order issued under paragraph 

(1) may obtain review of the order’s conformance with this subsection, and any regulations issued to 

carry out this section, in the United States court of appeals for a circuit in which the reprisal is alleged 

in the order to have occurred. No petition seeking such review may be filed more than 60 days after 

issuance of the order by the head of the executive agency. Review shall conform to chapter 7 of title 

5. Filing such an appeal shall not act to stay the enforcement of the order of the head of an executive 

agency, unless a stay is specifically entered by the court.

(6). Burdens of proof.—The legal burdens of proof specified in section 1221(e) of title 5 shall be 

controlling for the purposes of any investigation conducted by an Inspector General, decision by 

the head of an executive agency, or judicial or administrative proceeding to determine whether 

discrimination prohibited under this section has occurred.

(7). Rights and remedies not waivable.—The rights and remedies provided for in this section may not 

be waived by any agreement, policy, form, or condition of employment.

(d). Notification of employees.—The head of each executive agency shall ensure that contractors, 

subcontractors, and grantees of the agency inform their employees in writing of the rights and remedies 

provided under this section, in the predominant native language of the workforce.

(e). Construction.—Nothing in this section may be construed to authorize the discharge of, demotion of, or 

discrimination against an employee for a disclosure other than a disclosure protected by subsection (a) or to 

modify or derogate from a right or remedy otherwise available to the employee.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

83

(f ). Exceptions.—

(1). This section shall not apply to any element of the intelligence community, as defined in section 3(4) 

of the National Security Act of 1947 (50 U.S.C. 401a(4)).

(2). This section shall not apply to any disclosure made by an employee of a contractor, subcontractor, 

or grantee of an element of the intelligence community if such disclosure—

(A). relates to an activity of an element of the intelligence community; or

(B). was discovered during contract, subcontract, or grantee services provided to an element of 

the intelligence community.

(g). Definitions.—In this section:

(1). The term “abuse of authority” means an arbitrary and capricious exercise of authority that is 

inconsistent with the mission of the executive agency concerned or the successful performance of a 

contract or grant of such agency.

(2). The term “Inspector General” means an Inspector General appointed under the Inspector General 

Act of 1978 and any Inspector General that receives funding from, or has oversight over contracts or 

grants awarded for or on behalf of, the executive agency concerned.

(h). Construction.—Nothing in this section, or the amendments made by this section, shall be construed to 

provide any rights to disclose classified information not otherwise provided by law.

(i). Duration of section.—This section shall be in effect for the four-year period beginning on the date that 

is 180 days after the date of the enactment of this section.

Appendix F. 2 CFR Appendix II to Part 200: Contract provisions for 

nonfederal entity contracts under federal awards 

In addition to other provisions required by the federal agency or nonfederal entity, all contracts made by the 

nonfederal entity under the federal award must contain provisions covering the following, as applicable. 

(A) Contracts for more than the simplified acquisition threshold currently set at $150,000, which is the 

inflation adjusted amount determined by the Civilian Agency Acquisition Council and the Defense 

Acquisition Regulations Council (Councils) as authorized by 41 U.S.C. 1908, must address administrative, 

contractual, or legal remedies in instances where contractors violate or breach contract terms and provide 

for such sanctions and penalties as appropriate. 

(B) All contracts in excess of $10,000 must address termination for cause and for convenience by the 

nonfederal entity, including the manner by which it will be effected and the basis for settlement. 

(C) Equal employment opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that 

meet the definition of “federally assisted construction contract” in 41 CFR Part 60–1.3 must include the 

equal opportunity clause provided under 41 CFR 60–1.4(b), in accordance with Executive Order 11246, 

“Equal Employment Opportunity” (30 FR 12319, 12935, 3 CFR Part, 1964–1965 Comp., p. 339), as amended 

by Executive Order 11375, “Amending Executive Order 11246 Relating to Equal Employment Opportunity” 

and implementing regulations at 41 CFR part 60, “Office of Federal Contract Compliance Programs, Equal 

Employment Opportunity, U.S. Department of Labor.” 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

84

(D) Davis-Bacon Act, as amended (40 U.S.C. 3141–3148). When required by federal program legislation, all 

prime construction contracts in excess of $2,000 awarded by nonfederal entities must include a provision 

for compliance with the Davis-Bacon Act (40 U.S.C. 3141–3144, and 3146–3148) as supplemented by 

U.S. Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts 

Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must 

be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified 

in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay 

wages not less than once a week. The nonfederal entity must place a copy of the current prevailing wage 

determination issued by the U.S. Department of Labor in each solicitation. The decision to award a contract 

or subcontract must be conditioned upon the acceptance of the wage determination. The nonfederal entity 

must report all suspected or reported violations to the federal awarding agency. The contracts must also 

include a provision for compliance with the Copeland “Anti-Kickback” Act (40 U.S.C. 3145) as supplemented 

by U.S. Department of Labor regulations (29 CFR Part 3, “Contractors and Subcontractors on Public Building 

or Public Work Financed in Whole or in Part by Loans or Grants from the United States”). The Act provides 

that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed 

in the construction, completion, or repair of public work to give up any part of the compensation to which 

he or she is otherwise entitled. The nonfederal entity must report all suspected or reported violations to the 

federal awarding agency.

(E) Contract Work Hours and Safety Standards Act (40 U.S.C. 3701–3708). Where applicable, all contracts 

awarded by the nonfederal entity in excess of $100,000 that involve the employment of mechanics or 

laborers must include a provision for compliance with 40 U.S.C. 3702 and 3704 as supplemented by U.S. 

Department of Labor regulations (29 CFR Part 5). Under 40 U.S.C. 3702 of the Act, each contractor must be 

required to compute the wages of every mechanic and laborer on the basis of a standard work week of 40 

hours. Work in excess of the standard work week is permissible provided that the worker is compensated at 

a rate of not less than one and a half times the basic rate of pay for all hours worked in excess of 40 hours 

in the work week. The requirements of 40 U.S.C. 3704 are applicable to construction work and provide that 

no laborer or mechanic must be required to work in surroundings or under working conditions which 

are unsanitary, hazardous, or dangerous. These requirements do not apply to the purchases of supplies or 

materials or articles ordinarily available on the open market or contracts for transportation or transmission of 

intelligence.

(F) Rights to Inventions Made Under a Contract or Agreement. If the federal award meets the definition 

of “funding agreement” under 37 CFR § 401.2 (a) and the recipient or subrecipient wishes to enter into 

a contract with a small business firm or nonprofit organization regarding the substitution of parties, 

assignment, or performance of experimental, developmental, or research work under that “funding 

agreement,” the recipient or subrecipient must comply with the requirements of 37 CFR Part 401, “Rights to 

Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts 

and Cooperative Agreements” and any implementing regulations issued by the awarding agency.

(G) Clean Air Act (42 U.S.C. 7401–7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251–1387), 

as amended. Contracts and subgrants of amounts in excess of $150,000 must contain a provision that 

requires the nonfederal award to agree to comply with all applicable standards, orders, or regulations 

issued pursuant to the Clean Air Act (42 U.S.C. 7401–7671q) and the Federal Water Pollution Control Act 

as amended (33 U.S.C. 1251–1387). Violations must be reported to the federal awarding agency and the 

Regional Office of the Environmental Protection Agency (EPA).
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

85

(H) Mandatory standards and policies relating to energy efficiency which are contained in the state energy 

conservation plan issued in compliance with the Energy Policy and Conservation Act (42 U.S.C. 6201). 

(I) Debarment and Suspension (Executive Orders 12549 and 12689). A contract award (see 2 CFR 180.220) 

must not be made to parties listed on the governmentwide Excluded Parties List System in the System for 

Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive 

Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), “Debarment and 

Suspension.” The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or 

otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority 

other than Executive Order 12549.

(J) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352). Contractors that apply or bid for an award of $150,000 

or more must file the required certification. Each tier certifies to the tier above that it will not use and has 

not used federal appropriated funds to pay any person or organization for influencing or attempting to 

influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, 

or an employee of a member of Congress in connection with obtaining any federal contract, grant, or any 

other award covered by 31 U.S.C. 1352. Each tier must also disclose any lobbying with nonfederal funds that 

takes place in connection with obtaining any federal award. Such disclosures are forwarded from tier to tier 

up to the nonfederal award.

(K) See § 200.322 Procurement of recovered materials.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

86

Glossary of Terms

allowable costs. TRGP-Equipment/Training – Allowable costs are expenses that may be funded by this grant 

program. COPS Office TRGP provides funding for equipment, services, and technology purchased on or after 

the award start date. Upon review of your submitted budget, any unallowable costs were removed. The FCM 

that was included in your award package outlined your allowable costs and noted any relevant revisions that 

were made to your original budget submission.

TRGP-Hiring – Allowable costs are costs that will be paid for by this grant program. The only allowable costs 

under TRGP-Hiring are the approved full-time, entry-level salaries and fringe benefits of sworn career law 

enforcement officers hired or rehired on or after the grant award start date. TRGP-Hiring grant funds may 

be used to hire or rehire experienced officers, but any costs higher than entry-level must be paid by your 

agency with local funds. Grant funding must be limited to your agency’s entry-level sworn officer salary and 

benefits. Upon review of your submitted budget, any unallowable costs were removed. The FCM, which was 

included in your award package, specifies the amount of TRGP-Hiring funds awarded to your agency for 

officer salaries and approved benefits, and it identifies the final officer salary and fringe benefit categories 

and amounts for which your agency was approved. Approved entry-level salaries and benefits paid during 

basic academy training are allowable when it is the agency’s policy to pay all newly hired officers during this 

training.

audit. Work done by auditors, including both the OIG and state or local auditors, to examine financial 

statements and to review

•	 compliance with laws and regulations;

•	 economy and efficiency of operations;

•	 effectiveness in achieving program results;

•	 allowability of costs claimed against the award.

authorized official. The authorized official is the individual in your organization who has final authority and 

responsibility for all programmatic and financial decisions regarding this grant award. At the time of grant 

application, your agency listed the government executive (usually the Tribal Chief, Chairman, President, etc.) 

for your agency. This executive is listed on your award document and is understood to be your authorized 

official. If any of the executive information is incorrect, please submit the correct information to the COPS 

Office by completing an official Change of Information form available online at www.cops.usdoj.gov.

automated booking system. An automated booking system captures arrestee fingerprints and photographic 

information electronically and often has the ability to transfer that information to a departmental or statewide database.

Automated Fingerprint Identification System (AFIS). An AFIS system is a highly specialized biometrics system 

that compares a single fingerprint image with a database of fingerprint images. Fingerprint images are 

collected from crime scenes or are taken from criminal suspects when they are arrested. Fingerprint images 

may be captured by placing a finger on a scanner or by electronically scanning inked impressions on paper.

award package. The award package includes your TRGP award document, Financial Clearance Memorandum 

(FCM), and award congratulatory letter; it may be accessed through the “Account Access” link on the COPS 

Office website (www.cops.usdoj.gov). Your agency’s TRGP award document will list your grant number, 

government executive, award amount, number and hiring category of positions awarded, award start 

and end dates, and all terms and conditions (including any special conditions placed on your agency’s 
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

87

TRGP grant). Your law enforcement and government executives have 90 days from the date on your award 

congratulatory letter to log on to their accounts in “Account Access” and electronically sign the award 

document and submit it to the COPS Office. Your agency’s FCM will specify the final amount of TRGP funds 

awarded to your agency for officer salaries and approved fringe benefits.

award start date. This is the date on or after which your agency is authorized to purchase any allowable 

equipment, services, or other costs that were approved by the COPS Office. The award start date is found on 

your grant award document. Grantees may not expend funds prior to this date without written approval from the 

COPS Office.

career law enforcement officer. The COPS Office statute defines a career law enforcement officer as a person 

hired on a permanent basis who is authorized by law, or by a state or local public agency, to engage in or 

oversee the prevention, detection, or investigation of violations of criminal laws.

Catalog of Federal Domestic Assistance (CFDA). The CFDA is an annual government-wide publication that 

contains a description and index of all forms of federal assistance. Each program is assigned a CFDA number, 

which is used by auditors to track grant revenues under the Single Audit Act. It is also used in participating 

states by state single points of contact in conducting the required intergovernmental reviews under 

Executive Order 12372. The CFDA number for the COPS Office TRGP grant is 16.710.

closeout. This is the process in which the awarding agency, the COPS Office, determines that all applicable 

administrative actions and all required work and conditions of the award have been completed and met by 

the recipient and awarding agency.

cognizant federal agency. Your cognizant federal agency is generally the federal agency that provides your 

agency with the most federal money. The Office of Management and Budget (OMB) may have already 

assigned your cognizant federal agency to you. If this is the first federal grant that your organization has 

received, the U.S. Department of Justice (DOJ) is your cognizant federal agency.

community policing. Community policing is a philosophy that promotes organizational strategies that 

support the systematic use of partnerships and problem-solving techniques to proactively address the 

immediate conditions that give rise to public safety issues such as crime, social disorder, and fear of crime. All 

newly hired, additional, or rehired officers (or an equal number of redeployed veteran officers) funded under 

COPS Office programs must engage in community policing activities and in the implementation of your 

community policing plan.

Computer Aided Dispatch (CAD) system. Computer database that can track calls for service, maintain status 

of units available, provide various reports, produce address histories, and support electronic mail. With the 

installation of integrated CAD systems, officers are able to receive calls for service on their mobile data 

terminals rather than over the radio. Radios can then be used only for serious emergencies.

consortium. A consortium is a group of two or more governmental entities that agree to form a partnership 

to provide law enforcement services to their constituent communities.

COPS Office finance staff. The COPS Office finance staff handles your agency’s financial and budgetary 

needs related to this grant. A staff accountant has been assigned to your state and is available to answer 

any questions that you may have concerning the financial aspects of your grant. To identify your staff 

accountant, please call the COPS Office Response Center at 800-421-6770 or visit the COPS Office website at 

www.cops.usdoj.gov.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

88

COPS Office. The Office of Community Oriented Policing Services (COPS Office) is the division of the U.S. 

Department of Justice that is the grantor agency for your grant. The COPS Office is responsible for assisting 

your agency with the administration and maintenance of your grant for the entire grant period. You can 

reach the COPS Office at 800-421-6770.

Data Universal Numbering System (DUNS) number. Since FY 2004, the Office of Management and Budget 

(OMB) has required all agencies applying for federal funding to obtain this number prior to application. The 

DUNS number is a unique nine- or thirteen-digit identification number that is assigned upon request to 

agencies by Dun & Bradstreet (D&B). This number will be used by the Federal Government to better track 

grant recipient information throughout the grant cycle and to provide consistent name and address data for 

electronic grant application systems. To obtain a DUNS number, visit the Dun & Bradstreet website at www.

dnb.com or call 866-705-5711.

Employer Identification Number (EIN)/OJP Vendor Number. This number is usually your agency’s nine-digit 

federal tax identification number as assigned to you by the Internal Revenue Service (IRS). Your accounting/

bookkeeping department should have this number. In some cases, the EIN has been previously assigned 

to another agency within your jurisdiction. In this instance, a new vendor number will be assigned to you 

by the Office of the Chief Financial Officer. The newly assigned number is to be used for the COPS Office 

administrative purposes only and should not be used for IRS purposes.

federally recognized tribe. Tribal entities that are recognized and eligible for funding and services from the 

BIA by virtue of their status as Indian tribes. They are acknowledged to have the immunities and privileges 

available to other federally acknowledged Indian tribes by virtue of their government-to-government 

relationship with the United States as well as the responsibilities, power, limitation, and obligations of 

such tribes. Only federally recognized tribes are eligible to apply for COPS Office grant funds. For further 

information, contact: BIA, Division of Tribal Government Services, MS-4631-MIB, 1849 C Street NW, 

Washington, DC 20240, 202-208-2475.

gas mask. A gas mask is connected to a chemical air filter and is used to protect the face and lungs from 

toxic gases.

Global Positioning System (GPS). Global Positioning Systems are a series of 24 geosynchronous satellites that 

continuously transmit their positions. Each system is used in personal tracking, navigation, and automatic 

vehicle location technologies.

Grant Monitoring Specialist. COPS Office Grant Monitoring Specialists are trained and available to assist you 

in addressing any compliance-related questions regarding your grant. Grant Monitoring Specialists plan 

and conduct site visits and office-based grant reviews. During the life of your grant, you may be selected 

for a monitoring site visit to assess your compliance with the terms and agreements of the grant program, 

to review your community policing initiatives, and to provide technical and administrative support for your 

grant award. Please contact the COPS Office Response Center at 800-421-6770 if you have any compliancerelated questions.

grant number. The grant number identifies your agency’s specific TRGP grant, and can be found on your 

grant Award Document. This number should be used as a reference when corresponding with the COPS 

Office. Your grant number is in the following format: 2015-HE-WX-0000 for TRGP-E/T grants and 2015-HHWX-0000 for TRGP-Hiring grants awarded in FY 2015. The COPS Office tracks grant information based upon 

this number.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

89

Grant Program Specialist. COPS Office Grant Program Specialists are trained to assist you with implementing 

and maintaining your grant. A Grant Program Specialist is assigned to your state and is available to answer 

any questions that you may have concerning the administrative aspects of your grant. Your Grant Program 

Specialist can assist you with such matters as requesting an extension on your grant or modifying the grant 

award. To obtain the name and phone number of your Grant Program Specialist, please contact the COPS 

Office Response Center at 800-421-6770 or refer to the COPS Office website, www.cops.usdoj.gov.

indirect costs. Indirect (F&A) costs are those costs incurred for a common or joint purpose benefiting more 

than one cost objective. They are not readily attributable to the cost objectives that are being benefited. 

To facilitate equitable distribution of indirect expenses to the specific cost objectives, it may be necessary 

to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools must be distributed to 

benefited cost objectives on bases that will produce equitable results in consideration of relative benefits 

derived. See 2 C.F.R. § 200.56 in the Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards, as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101. See the 

COPS Office website for a fact sheet on indirect costs: http://www.cops.usdoj.gov/pdf/2015AwardDocs/cpd/

Indirect_Cost_Rate_Fact_Sheet.pdf.

interoperable communications. Communications interoperability refers to the ability of emergency response 

officials to share information via voice and data signals on demand, in real time, when needed, and as 

authorized. Interoperable communications policies, procedures, and technology are used to increase voice 

and data information sharing among the law enforcement, fire service, and emergency medical service 

communities.

local budget cycle. Your agency’s fiscal year: some common examples include January 1 to December 31, 

October 1 to September 30, and July 1 to June 30. Some local budget cycles may extend up to 24 months.

matching funds. What a locality must contribute as a cash match toward total allowable project costs over 

the life of the program. There is no matching fund requirement for the TRGP program (although higher than 

entry-level costs for hired or rehired officers must be paid with local funds).

mobile data computer / laptop. A mobile data computer (MDC) is a computer terminal mounted in a vehicle 

that is linked via wireless communication to a network that is often integrated with a CAD system. MDCs 

enable officers to complete previously handwritten reports on a computer. This often eliminates the need to 

enter duplicate information on multiple reports.

National Incident-Based Reporting System (NIBRS). A comprehensive reporting database where agencies 

provide individual records for eight index crimes and 38 other offenses.

obligation of funds. The COPS Office obligates federal funds when the grant award document is signed by 

the COPS Office Director or his or her designated official. For the grantee, grant funds are obligated when 

monies are spent or orders are placed for approved items under your grant. The term encumbrance is often 

used at the local and state levels to describe this type of transaction. Liquidated obligations are considered 

cash outlays or monies actually spent. Unliquidated obligations are obligations incurred and recorded but 

not yet paid (accrual basis of accounting) or not yet recorded and not yet paid (cash basis of accounting).
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

90

Originating Agency Identifier (ORI) number. This number is assigned by the FBI, and it is your agency’s 

unique identifier. The first two letters are your state abbreviation, the next three numbers are your county’s 

code, and the final two numbers identify your jurisdiction within your county. If your agency does not have 

an ORI number assigned by the FBI, the COPS Office assigns a non-official ORI code to use as an agency 

identifier (in such cases, the last two characters will be “ZZ”). It can be found on your grant award document. 

When you contact the COPS Office with a question, please reference your ORI number (or your grant 

number).

primary law enforcement authority. An agency with primary law enforcement authority is the agency that is 

the first responder to calls for service and has ultimate and final responsibility for the prevention, detection, 

or investigation of violations of criminal laws within its jurisdiction.

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

•	 increase the number of community policing officers on the beat;

•	 provide additional and more effective training to law enforcement officers to enhance their problemsolving, service, and other skills needed in 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;

•	 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.

retention period. After 36 months of COPS Office funding, TRGP-Hiring grantees are required to retain each 

additional COPS Office-funded position awarded using local, state, or other sources of non-COPS Office 

funds. Each awarded position must be retained for at least 12 months following the conclusion of the 36 

months of federal funding for that position. This time span is referred to as the retention period.

System for Award Management (SAM). The SAM database is the repository for standard information about 

federal financial assistance applicants, recipients, and subrecipients. Organizations that have previously 

submitted applications via Grants.gov are already registered with SAM, as it is a requirement for Grants.gov

registration. Please note, however, that applicants must update or renew their SAM at least once per year to 

maintain an active status. Information about registration procedures can be accessed at www.sam.gov.

supplanting. For the purposes of your COPS Office grant, supplanting means replacing state, local, or BIA 

funds that otherwise would have been spent on law enforcement purposes with federal COPS Office funds. 

State, local, and tribal governments are prohibited from supplanting throughout the grant period. This 

means that your agency may not use COPS Office funds to pay for any equipment/technology, services, 

or other items which, in the absence of the COPS Office program, would otherwise have been funded 

with state or local funds or funds supplied by the BIA. The COPS Office funds must instead be used to 

supplement, or increase, your law enforcement budget. For additional information on supplanting, please 

review TRGP-Hiring grant condition #4 on page 8 or TRGP-E/T grant condition #5 on page 32 of this manual.
2015 COPS Office Tribal Resources Grant Program (TRGP) Grant Owner’s Manual

91

2015 COPS Office Tribal Resources Grant Program

Grant Owner’s Manual

This manual was created to assist COPS Office Tribal Resources Grant Program (TRGP) grantees with the administrative and 

financial matters associated with their grant.

For more information about your TRGP grant, please contact your COPS Office Grant Program Specialist. If you do not 

know the name or telephone number of your Grant Program Specialist, please contact the COPS Office Response Center 

at 800-421-6770.

U.S. Department of Justice

Office of Community Oriented Policing Services

145 N Street NE

Washington, DC 20530

Visit the COPS Office online: www.cops.usdoj.gov

Published 2015