2017 COPS Office Preparing for Active Shooter Situations 

(PASS) Program 

Award Owner’s Manual 

US Department of Justice, Office of Community Oriented Policing Services

www.cops.usdoj.gov
 

 

 

 

2017 COPS Office Preparing for Active Shooter Situations (PASS) Program Award Owner’s Manual 

2017 COPS Office Preparing for Active Shooter Situations 

(PASS) Program Award Owner’s Manual 

This manual was created to assist COPS Office Preparing for Active Shooter Situations (PASS) Program recipients 

with the administrative and financial matters associated with their award. 

For more information about your PASS award, please contact your COPS Office Program Manager. If you do not 

know the name or telephone number of your COPS Office Program Manager, please contact the COPS Office 

Response Center at 800-421-6770. 

US Department of Justice 

Office of Community Oriented Policing Services 

145 N Street NE 

Washington, D.C. 20530 

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

Published October 2017 

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2017 COPS Office Preparing for Active Shooter Situations (PASS) Program Award Owner’s Manual 

Contents 

Getting Started ..............................................................................................................................................................

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I. Award Acceptance, Terms, and Conditions 2
 

The award document ................................................................................................................................................

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Award terms and conditions 3
 

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

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35
 

Accepting the award 36
 

Who should sign the award document for our agency? 36
 

By when must the award document be signed? 37
 

II. The Cooperative Agreement 38
 

III. Procurement Process 51
 

IV. Accessing Award Funds 52
 

Payment method 52
 

Setting up your account 52
 

Additional payment questions 53
 

V. Financial Record Maintenance 55
 

Accounting systems and records 55
 

VI. Federal Audit Requirements 57
 

Single Audit Act (SAA) requirements 57
 

Office of Inspector General (OIG) recipient audits 58
 

Typical Audit Recommendations (“Findings”) 59
 

VII. Reports Requirement 61
 

Federal Financial Reports 61
 

Program Progress Reports 62
 

Contact points to obtain technical assistance and report violations 64
 

VIII. When the Award Period Has Ended 65
 

Final Federal Financial Report (SF-425) 65
 

Final Program Progress (Closeout) Report 65
 

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2017 COPS Office Preparing for Active Shooter Situations (PASS) Program Award Owner’s Manual 

IX. Conclusion ..............................................................................................................................................................

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67
 

Appendices 68
 

Appendix A. List of source documents 68
 

Appendix B. Assurances and Certifications 69
 

Appendix C. Community policing defined 75
 

Appendix D. Training and Conference Fact Sheets 83
 

Appendix E. Conference and Event Guidance 84
 

Appendix F. Financial/Budget Fact Sheets 102
 

Appendix G. Whistleblower protection 115
 

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

awards ...................................................................................................................................................................118
 

Appendix I. Remittance of Interest Earned Amounts............................................................................................

......................................................................................................................................................

120
 

Glossary of Terms 121
 

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2017 COPS Office Preparing for Active Shooter Situations (PASS) Program Award Owner’s Manual 

Getting Started 

Congratulations on receiving an award from the US Department of Justice (DOJ), Office of Community Oriented 

Policing Services (COPS Office). The 2017 COPS Office Preparing for Active Shooter Situations (PASS) Program 

awards provide funding to be used to advance the practice of community policing in law enforcement agencies 

through nationally recognized, scenario –based training that prepares officers and other first responders to safely 

and effectively handle active shooter and other violent threats. According to the COPS Office, 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. For a complete definition, please see the appendices in this 

manual addressing “Community policing defined.” 

This PASS Award Owner’s Manual will assist your agency with the administrative and financial matters associated 

with your award. It was developed to ensure that all PASS award recipients are able to clearly understand and 

meet the requirements of their award. Please review this manual carefully because failure to follow award 

requirements can have serious ramifications. Please do not hesitate to call your COPS Office Program Manager 

through the COPS Office Response Center at 800-421-6770 if you need assistance with the implementation of your 

award. 

Thank you for providing us with the opportunity to work in partnership with you on this important project. 

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I. Award Acceptance, Terms, and Conditions 

To officially accept and begin your COPS Office PASS Program award, your agency must access 

https://portal.cops.usdoj.gov, to log in, review, and electronically sign the award document with the award terms 

and conditions; the financial clearance memorandum and, if applicable, the cooperative agreement that is 

incorporated by reference into the award document; and, if applicable, the special award conditions or high risk 

conditions in the award document supplement within 90 days of the date shown on the award congratulatory 

letter. 

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

document. For more information on drawing down award funds, please see the section titled “Accessing Award 

Funds” in this manual. 

The award document 

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

award terms and conditions, and the award start and end dates. Please note that if your award includes a 

cooperative agreement, it is incorporated by reference into the award document and that by signing the award 

document, your agency has entered into the cooperative agreement with the COPS Office and agrees to abide by 

all the requirements in the cooperative agreement. 

The award document is preprinted with your agency’s law enforcement and government executives’ names and 

addresses. For non-law enforcement agencies (institutions of higher education, private organizations, etc.), the 

authorized officials are the programmatic and financial officials who have the ultimate signatory authority to sign 

contracts on behalf of your organization. If this information is incorrect or has changed, please update your 

“Agency Contacts” online at https://portal.cops.usdoj.gov. 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 sign the award document. Be sure to familiarize yourself with all terms, conditions, and 

requirements of your award before signing the award document. To officially accept your award, please 

electronically sign the award document within 90 days of the date shown on the award congratulatory letter. Print 

and retain a copy of all pages of the award document, award terms and conditions, the Financial Clearance 

Memorandum (FCM), and, if applicable, the cooperative agreement and the award document supplement for your 

records. 

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 PASS award is listed on your award document. 

Your award number is in the following format: 2017-XXXX-XXXX for Fiscal Year (FY) 2017 awards. The COPS Office 

tracks award information based upon this number. Therefore, it is important to have your agency’s award 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 award information based 

upon this ORI number. If your agency does not have an ORI number assigned by the FBI, the COPS Office assigns a 

2 
nonofficial 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 award, please refer to your award 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 thirteendigit 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 program, and should not be used for IRS purposes. 

Award terms and conditions 

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

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

comply with these terms and conditions (and, if applicable, any additional special or high risk 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 award conditions, please contact your COPS Office Program Manager or call the COPS Office Response 

Center at 800-421-6770. 

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

down or accessing award funds until the special conditions are satisfied as determined by the COPS Office. Any 

special or high risk conditions will be included in the award document supplement. However, if you have questions 

about the special or high risk conditions, please contact your assigned COPS Office Program Manager. 

Reasons for award terms and conditions 

The requirements of your PASS award are established within 

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

•	 the applicable rules, regulations and policies issued by the US Department of Justice, Office of Management 

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

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

A list of source documents for this manual is provided in the appendices. 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 by calling your COPS Office 

Program Manager. 

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Review of award terms and conditions 

By signing the Award Document to accept this Preparing for Active Shooter Situations (PASS) Program award, your 

agency agrees to abide by the following award terms and conditions: 

1. Award Owner’s Manual 

Condition: 

The recipient agrees to comply with the terms and conditions in the applicable 2017 COPS Office Program Award 

Owner's Manual; COPS Office statute (42 U.S.C. §. 3796dd, et seq.); the requirements of 2 C.F.R. Part 200 (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by the US 

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

and Procedures); the Cooperative Agreement as applicable; representations made in the 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 award. Your agency will be responsible for the information and rules contained in this manual and for 

implementing your award in compliance with the applicable terms, conditions, and regulations. Please note that in 

accordance with 2 C.F.R. § 200.101(c), the COPS Office applies 2 C.F.R. Subparts A through E to for-profit (or 

commercial) entities. More detailed guidance regarding any particular award requirement or your agency’s specific 

circumstances can be requested through your COPS Office Program Manager. 

What you should do: 

Please read the entire PASS Award Owner’s Manual carefully prior to signing the award document. If you have any 

questions, please contact your COPS Office Program Manager. When accepting your award, you should ensure that 

the proper reporting and financial systems are in place to satisfy the award requirements. 

2. Assurances and Certifications 

Condition: 

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

as part of its application. 

Why this condition: 

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

several provisions of federal law require us to obtain the recipient’s Assurances and Certifications regarding certain 

matters. Most of the Assurances and Certifications apply to all federal award programs. 

What you should do: 

Applicants to COPS Office award 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 

award terms and conditions outlined in the Assurances and Certifications. Please read these documents carefully, 

4 
 

 

because signatures on these documents are treated as a material representation of fact upon which reliance will 

be placed when the US Department of Justice determines whether to fund the covered award. Additional copies of 

the Assurances and Certifications forms are contained in the appendices of this manual. If you have any questions 

about the Assurances and Certifications, please contact your assigned COPS Office Program Manager via the COPS 

Office Response Center at 800-421-6770. 

3. Allowable Costs 

Condition: 

The funding under this award is for the payment of approved costs for PASS purposes. The allowable costs 

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

is included in your agency’s award package. The FCM specifies the costs that your agency is allowed to fund with 

your award. It also describes any costs that were disallowed after review of your proposed budget. The recipient 

may not earn or keep any profit resulting from this award unless expressly authorized in writing by the COPS Office. 

Your agency may not use award funds for any costs not identified as allowable in the FCM. 

Why this condition: 

PASS funding may only be used to pay for items and services approved by the COPS Office as reflected in the 

Financial Clearance Memorandum (FCM). FY2017 PASS funding must be used to advance the practice of 

community policing in law enforcement agencies through nationally recognized, scenario –based training that 

prepares officers and other first responders to safely and effectively handle active shooter and other violent 

threats. For the scenario based training to be realistic and of the experiential quality, simulations weapons, 

proactive gear, range maintenance and other associated costs are allowable. For additional information, please 

contact your Program Manager. 

To be eligible for payment under this award, the purchase of approved items must be made on or after the award 

start date and comply with the guidelines described in the section “Accessing Award Funds” in this manual. The 

section “Financial Record Maintenance” outlines the types of records you must keep to document that you 

followed this award condition. Purchases must also reflect the costs that were approved in the FCM. 

What you should do: 

Refer to your FCM for the list of approved allowable cost categories. Listed below are the budget categories that 

may appear on your FCM. If your agency’s operating budget categories differ from those approved in the FCM, 

your agency should maintain a cross-reference to clearly identify where the funds were budgeted. As long as funds 

are spent during the award period on project costs that were documented in your application’s budget summary 

and approved by the COPS Office through the issuance of the FCM, this award condition will be satisfied. The 

award number should be indicated on all budgetary documentation including purchase orders, receipts, and other 

documentation. All recipients should keep and maintain the most recent, approved version of their 2017 PASS 

application for future reference. 

Personnel (salaries and benefits) 

Personnel expenses may be reimbursed for project activities that take place on or after the award start date. In 

addition, a position’s salary must be reasonable for the services rendered and must be paid to a person appointed 

under the law or rules governing hiring by your agency. Salary payments must be based on payroll records. Time 

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and attendance records or the equivalent must support payroll records. For recipients that are state, local, or tribal 

government entities, award-funded salary and benefit costs must supplement, not supplant (replace), locally 

funded personnel costs that would have been funded even in the absence of this award. If any civilian personnel 

are employed on a part-time or temporary basis, your agency must specify the percentage of time that each 

person is working solely on the project identified in your agency’s PASS proposal. Fringe benefits may be paid if 

they are part of a reasonable compensation package offered to your employees. Particular items of fringe benefits 

must fall within the categories authorized by the COPS Office. Authorized fringe benefits include FICA, Social 

Security, health insurance, life insurance, vacation, sick leave, retirement, worker’s compensation, and 

unemployment insurance. 

Equipment/Technology 

To be eligible for payment under this award, 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 they must 

meet the guidelines described in 2 C.F.R. Part 200, Subpart E – Cost Principles. For recipients that are state, local, 

or tribal government entities, award-funded equipment and technology must supplement, not supplant (replace), 

locally funded items that would have been funded even in the absence of this award. Funds currently budgeted or 

obligated for the purchase of equipment and technology may not be reallocated to other purposes or reimbursed 

upon receiving the PASS award. Agencies should establish practices to receive, label, inventory and track the 

location of all purchases made for award-funded equipment and/or technology. 

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, Subpart E – Cost Principles. 

Travel/Training 

Travel costs for transportation, lodging, subsistence, temporary dependent care, and related items are allowable 

under the PASS program with prior approval from 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 recipient’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 US 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. 

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. 

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The PASS program will fund award-related travel costs for the recipient agency or other (nonrecipient) individuals 

to attend training and technical assistance conferences, seminars, or classes or to visit a site specified in the 

application. Allowable award-related travel costs that were included in the application have been approved by the 

COPS Office as part of the PASS 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 Program 

Manager. 

Contracts/Consultants 

Compensation for individual consultant services procured under a COPS Office award must be reasonable, 

allocable in accordance with 2 C.F.R. Part 200, Subpart E—Cost Principles, and consistent with rates 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 $650 per day. For consultant or 

contractor rates which exceed $650 per day, the COPS Office requires written justification if the consultants or 

contractors are hired through a noncompetitive bidding process, and recipients must receive COPS Office approval 

of those rates before drawing down award funds. Determinations of approval will be made on a case-by-case basis. 

Other costs 

Project-related expenditures that do not conform to any of the category descriptions specified above are included 

in the “other costs” section of your FCM. In addition, items that have a direct correlation to the overall success of a 

recipient’s project objectives and are necessary for the project to reach full implementation will be considered on 

a case-by-case basis by the COPS Office. 

For recipients that are state, local, or tribal government entities, requests may be made only for items or positions 

that are not otherwise budgeted with state, local, or Bureau of Indian Affairs (BIA) funds and would not be funded 

in the absence of the PASS award. 

If at any time you are unsure if an item is considered allowable or unallowable, please contact your COPS Office 

Program Manager for further assistance. 

Indirect costs 

Indirect (facilities and administrative, or F&A) costs are costs incurred for a common or joint purpose that are not 

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

the project. Indirect costs are allowable for this program, but must adhere to the standards set forth in the 

applicable Office of Management and Budget (OMB) guidance as stated in 2 C.F.R. Part 200 (Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by the US 

Department of Justice in 2 C.F.R. § 2800.101. Examples of indirect costs include those incurred for facility 

operation and maintenance, depreciation, and administrative salaries. 

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

expenses 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 award period. 

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The recipient 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 for 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 award period, a current approved rate must be 

submitted to the COPS Office in order to continue to draw down award funding for indirect costs. Your expired 

rate must be renegotiated or extended by your cognizant federal agency. An approved indirect cost rate may be 

extended one time for up to four years, and once the cognizant federal agency has approved your extension, you 

must abide by that rate for the agreed-upon time period. At the end of the extension period, you must renegotiate 

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

indirect cost rate during the 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 a de minimis indirect cost 

rate of 10 percent of modified total direct costs (MTDC). See 2 C.F.R. § 200.414(f). 

In addition, if a provisional indirect cost rate is in effect at award closeout, your agency shall proceed with 

closeout, but you will need to complete an expenditure analysis upon receipt of the approved final indirect cost 

rate to determine if an adjustment is necessary. If your agency drew down excess COPS Office funding for indirect 

costs, then your agency must return the overpayment to the COPS Office and submit a revised Federal Financial 

Report (SF-425). If your agency incurred additional indirect costs, then your agency may request a budget 

modification if the award is still open and award funds are available. If your agency returns or draws down COPS 

Office funding, then your agency will need to submit a revised final Federal Financial Report (SF-425). 

See the COPS Office website for a fact sheet on indirect costs: 

https://cops.usdoj.gov/pdf/2017AwardDocs/cpd/Indirect_Cost_Rate_Fact_Sheet.pdf 

Please be advised that recipients may not use COPS Office funding for the same item or service also funded by 

another US Department of Justice award. 

See also award condition on “Duplicative Funding.” 

4. Supplementing, Not Supplanting 

Condition: 

State, local, and tribal government recipients must use award funds to supplement, and not supplant, state, local, 

or Bureau of Indian Affairs (BIA) funds that are already committed or otherwise would have been committed for 

award purposes (hiring, training, purchases, and/or activities) during the award period. In other words, state, local, 

and tribal government recipients 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 award (42 U.S.C. § 

3796dd-3(a)). 

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Why this condition: 

The COPS Office statutory nonsupplanting requirement mandates that award funds not be used to replace state or 

local funds (or, for tribal recipients, BIA funds) that would, in the absence of federal aid, be made available for the 

award purposes. 

What you should do: 

For state, local, and tribal recipients, PASS funds may not be used to pay for any item or cost funded under the 

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

funds. In addition, recipients may not reallocate state, local, or BIA funds from one area within the recipient’s 

operating budget to another as a result of receiving PASS award funds. If you have questions concerning this award 

term and how it pertains to your project budget, please contact your COPS Office Program Manager. 

5. Extensions 

Condition: 

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

program. Such extensions do not provide additional funding. Only those recipients that can provide a reasonable 

justification for delays will be granted no-cost extensions. Extension requests must be received prior to the end date 

of the award. 

Why this condition: 

Under federal regulations, requests to extend the 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 award end date. When justified, the COPS Office will seek to accommodate reasonable 

requests for no-cost time extensions to fully implement the COPS Office award. 

What you should do: 

The COPS Office will contact your agency during the last quarter of the award period to determine whether a nocost time extension is needed. Requests to extend the award period must be received by the COPS Office before 

the official award end date. Failure to submit a request for a no-cost time extension before the award end date 

may result in the immediate deobligation of any remaining award funds. Please note that the project period of 

performance will be extended, if necessary, until the deliverable is considered final. If the award is set to expire, 

prior to the final approval of the deliverable, a no-cost extension will be executed for a reasonable amount of time 

for the recipient to complete the final deliverable. 

6. Modifications 

Condition: 

Award modifications under the PASS program are evaluated on a case-by-case basis in accordance with 2 C.F.R. § 

200.308. For federal awards in excess of $150,000, any modification request involving the reallocation of funding 

between budget categories that exceed or are expected to exceed 10 percent (10%) of the total approved budget 

9 
 

requires prior written approval by the COPS Office. Regardless of the federal award amount or budget modification 

percentage, any reallocation of funding is limited to approved budget categories. In addition, any budget 

modification that changes the scope of the project requires prior written approval by the COPS Office. 

Why this condition: 

The COPS Office realizes that agencies may need to reprogram award 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 are required to expend federal 

funds only as approved in the FCM. Requests to change or alter an award that meet certain threshold 

requirements must be submitted to the COPS Office for written approval, prior to their purchase or 

implementation. Without prior written approval, you must continue to implement your award as it was originally 

outlined and accepted by your agency. Reprogrammed funds must be allocated for items covered within the 

original scope of the award. Please be advised that reprogramming requests for unallowable costs will not be 

approved. 

Your agency may reprogram its budget up to an aggregate (over the course of your project) of 10 percent of the 

total project cost without prior written approval from the COPS Office. However, you should notify your COPS 

Office Program Manager of any reprogramming that falls below the 10 percent threshold as well. For awards in 

excess of $150,000, any reprogramming of funds that totals an aggregate of 10 percent or more of the approved 

budget requires prior written approval from the COPS Office. 

What you should do: 

You are required to notify your COPS Office Program Manager if you determine that your agency will need to 

reprogram award funds. If your modification exceeds an aggregated (over the course of your project) 10 percent of 

your overall award, your agency must access https://portal.cops.usdoj.gov 

Please contact your COPS Office Program Manager for further direction on any additional requirements that may 

apply to your modification request. The COPS Office will then evaluate your request and notify your agency of our 

decision in writing. Implementation of the modified award budget may begin following written approval from the 

COPS Office. Please note that modification approvals for active awards will be accompanied by a modified FCM 

reflecting the approved changes. 

7. Evaluations 

Condition: 

The COPS Office may conduct monitoring or sponsor national evaluations of its award programs. The recipient 

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 PASS award. 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 

10 
 

 

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 award activities. You should fully comply with any requests made regarding these evaluations. 

8. Reports/Performance Goals 

Condition: 

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 must 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 recipients. 

What you should do: 

This award condition is designed to make your agency aware of reporting requirements associated with PASS 

awards. Quarterly programmatic progress reports and a final programmatic closeout report must be submitted 

directly to the COPS Office through the “Account Access” tab on the COPS Office website at 

https://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 award 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 award end date, however 

you will have a 90-day grace period after the award end date during which you can drawdown funds for eligible 

expenditures incurred before the award 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 the section titled “Reports” in this manual. All reports should be submitted within 

the deadlines given to avoid suspension or possible termination of award funds or other remedial actions; failure 

to submit required reports may also impact future funding opportunities. 

11 
9. Award Monitoring Activities 

 

 

 

 

 

Condition: 

Federal law requires that recipients receiving federal funding from the COPS Office must be monitored to ensure 

compliance with their award 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 

award implementation—compliance and programmatic benefits—are part of the monitoring process coordinated 

by the US Department of Justice. Award 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 award recipient, you agree to cooperate with and respond to any requests for 

information pertaining to your award. 

Why this condition: 

The Public Safety Partnership and Community Policing Act of 1994 states that each award program must contain a 

monitoring component. The COPS Office actively monitors how recipients are complying with COPS Office award 

requirements. In addition, the monitoring component provides customer service and technical assistance to help 

ensure recipients understand how to remain in compliance while implementing their awards. 

What you should do: 

Your agency may be required to accommodate routine and nonroutine 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 four primary means of ensuring recipients’ compliance with the terms and conditions of their 

awards are as follows: 

1.	 Site visits. The COPS Office strategically selects award recipients based on a variety of risk factors to 

conduct site visits to ensure compliance with award terms and conditions. The purpose of site visits is 

threefold: 

i.	 To review for compliance with the terms and conditions of the award 

ii.	 To review the recipient’s community policing strategies 

iii. To provide customer service and technical assistance 

If selected, recipients will be notified in writing in advance with detailed instructions for how to prepare for 

the review of their COPS Office awards. This review is generally performed over a period of one or more days. 

Recipients will have an opportunity to resolve any identified noncompliance issues while on-site or, if 

necessary, following the site visit. In addition, recipients will also have an opportunity to seek customer 

service and/or technical assistance on the implementation of their award. 

2.	 Enhanced Office-Based Grant Reviews (EOBGR). In lieu of a site visit, awards may be selected for an 

EOBGR conducted at the COPS Office via teleconference or video conference. EOBGRs serve as an 

alternative for conducting award monitoring reviews in support of the COPS Office’s overall award 

monitoring strategy. The purpose of the EOBGR is threefold: 

i.	 To review for compliance with the terms and conditions of the award 

ii.	 To review the recipient’s community policing strategies 

iii.	 To provide customer service and technical assistance 

12 
 

 

 

If selected, the recipient will be notified in writing in advance of any EOBGR of its COPS Office awards. This 

review is generally performed over a one- to two-day period. Recipients will have an opportunity to resolve 

any identified noncompliance issues, if necessary, following the EOBGR interview. In addition, award 

recipients will also have an opportunity to seek customer service and/or technical assistance on the 

implementation of their award. 

3.	 Alleged Noncompliance Referral (ANCR). An ANCR is an allegation of suspected noncompliance that 

originates from an internal source within the COPS Office or an external referral from one of many 

sources. Internal ANCRs generally originate from COPS Office Grants Administration Division, COPS Office 

Finance Division, or the COPS Office Legal Division, although any COPS Office component may refer a 

noncompliance issue to the ANCR. External noncompliance referrals may be received from anonymous 

complainants, media, citizens, law enforcement agencies, other Federal agencies, or other outside 

sources. On a case-by-case basis, COPS Office ANCR 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 OIG. Each ANCR referral is resolved as a violation or 

nonviolation based upon the preponderance of the supporting documentation or other facts to determine 

if the award recipient is in compliance or noncompliance. 

4.	 Audit liaison. The OIG may conduct a random audit for any recipient of a COPS Office award. In the event 

your agency has undergone an OIG audit and there are audit recommendations (findings) resulting from 

noncompliance or poor accountability 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 award funds, providing adequate documentation to demonstrate compliance, or providing 

proof of policies or procedures that were created or revised to directly address the causes for the 

noncompliance as a proactive preventative measure to avoid future noncompliance. 

Recipients are responsible for remedying any award noncompliance that is identified during site visits, EOBGRs, 

and/or ANCRs. In addition, recipients are responsible for remedying noncompliance stemming from audit 

recommendations identified in audits of COPS Office awards conducted by the OIG and the Office of the Chief 

Financial Officer (OCFO). Remedies for noncompliance may include but are not limited to repayment of award 

funds for unallowable or unsupported costs, providing adequate documentation to demonstrate compliance, 

suspending active award funding, voluntary withdrawal from or involuntary termination of remaining award funds, 

or a restriction from receiving future COPS Office awards for a period of time. Under certain conditions, additional 

actions may include referral and placement on the US 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 awards while on the list. In the event of criminal misuse of award 

funds, recipients may also be subject to fines and imprisonment. To avoid findings of noncompliance, recipients 

are strongly encouraged to become familiar with the COPS Office Grant Monitoring Division’s Grant Monitoring 

Standards and Guidelines and Award Owner’s Manual for the year in which the award was made. Recipients 

should also contact their COPS Office Program Manager at any time during the life of a COPS Office award with 

questions concerning award conditions, terms, or requirements to seek guidance to avoid noncompliance. It is 

necessary for recipients to maintain all relevant documentation (administrative, financial, and programmatic) used 

to develop the application and implement the award that may be necessary or required to demonstrate award 

compliance. For more information, please contact the COPS Office Response Center at 800-421-6770 or at 

AskCopsRC@usdoj.gov. 

13 
10. Federal Civil Rights 

 

 

Condition: 

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

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

religion, national origin, sex, or disability 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. You will also not discriminate in the delivery of benefits or services 

based on age. 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, as amended (42 U.S.C. § 6101); Title IX of the Education Amendments of 1972, as 

amended (20 U.S.C. § 1681); and the corresponding U.S. Department of Justice 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, as 

amended by Executive Order 13559, and the implementing regulations at 28 C.F.R Part 38, Partnerships With FaithBased and Other Neighborhood Organizations, which requires equal treatment of religious organizations in the 

funding process and prohibits religious discrimination against beneficiaries. 

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, recipients 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 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 award until you comply with federal civil rights laws or cooperate with any ongoing 

federal civil rights investigation. 

What you should do: 

Included with your award package is a memorandum from the Office for Civil Rights, Office of Justice Programs, US 

Department of Justice, which addresses the federal civil rights statutes and regulations applicable to your award. 

You should review this memorandum to understand your agency’s civil rights responsibilities. 

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 (EEOP) 

Condition: 

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). 

14 
 

Why this condition: 

It is the experience of the US 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 is a government agency or private 

business and has received a single award for $25,000 or more and has fifty or more employees (counting both fulland part-time employees but excluding political appointees), then it has to prepare a Utilization Report and submit 

it to the Office for Civil Rights (OCR) within 120 days from the date of the award. Although the OCR has discretion 

to review all submitted Utilization Reports, it will review the Utilization Reports from recipients that receive an 

award of $500,000 or more. 

To begin developing a Utilization Report, please consult the OCR's website at 

https://www.ojp.usdoj.gov/about/ocr/eeop.htm and click EEOP Reporting Tool Login. Additional assistance can 

be found online at the bottom of the same webpage by clicking the EEO Reporting Tool Job Aid and Frequently 

Asked Questions. 

If your organization has less than fifty 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, however, your organization must certify that it is exempt by logging into the 

EEO Reporting Tool on the OCR website at https://www.ojp.usdoj.gov/about/ocr/eeop.htm, providing the 

contact and organizational profile information, and then submitting a Certificate of Exemption. 

If you have further questions regarding the EEOP requirements, you may contact an EEOP specialist at the OCR by 

telephone at 202-307-0690, by TTY at 202-307-2027, or by e-mail at EEOPforms@usdoj.gov. 

12. False Statements 

Condition: 

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

debarment from participating in federal awards 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 award documents. 

What you should do: 

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

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

15 
13. Duplicative Funding 

 

 

Condition: 

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 award was made to your agency for approved project costs 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 Program Manager or call the COPS Office Response Center 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 award program. 

14. Additional High-Risk Recipient Requirements 

Condition: 

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

performance period if the awarding agency determines that the recipient is a high-risk recipient (2 C.F.R. § 

200.207). 

Why this condition: 

In accordance with 2 C.F.R. § 200.207, the 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 DOJ 

may impose special conditions or restrictions that may include requiring the production of documentation, 

financial award 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 award, recipients must agree to comply with any additional requirements that 

may be imposed during the award performance period if the awarding agency determines that the recipient is a 

high-risk recipient. 

16 
15. System for Award Management (SAM) and Universal Identifier Requirements 

 

Condition: 

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

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

I. SYSTEM FOR AWARD MANAGEMENT AND UNIVERSAL IDENTIFIER REQUIREMENTS 

A.	 Requirement for System for Award Management 

Unless you are exempted from this requirement under 2 C.F.R. 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 unique entity identifier
 

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 unique entity identifier to you. 

2.	 May not make a subaward to an entity unless the entity has provided its unique entity identifier 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 (currently at http://www.sam.gov). 

2.	 Unique entity identifier means the identifier required for SAM registration to uniquely identify 

business entities. 

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 nonprofit 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 2 C.F.R. 200.330). 

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. 

17 
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 award 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 award 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 

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. 

16. Reporting Subawards and Executive Compensation 

Condition: 

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

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

I. Reporting Subawards and Executive Compensation. 

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 

http://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 http://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; 

18 
 

 

 

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 CFR 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 CFR 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 

http://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 https://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 CFR 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 

http://www.sec.gov/answers/execomp.htm.) 

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: 

19 
i.	 Subawards,
 

and
 

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

E.	 e. Definitions. For purposes of this award term: 

1.	 Entity means all of the following, as defined in 2 CFR 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 nonprofit organization; 

iv.	 A domestic or foreign for-profit organization; 

v.	 A Federal agency, but only as a subrecipient under an award or subaward 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 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 subrecipient's preceding fiscal year and includes the following (for more information see 

17 CFR 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. 

20 
 

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. 

Recipients are responsible for reporting their applicable executive compensation and subaward information, and 

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

What you should do: 

At the time of award 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. 

17. Debarment and Suspension 

Condition: 

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 for $25,000 or more or any subaward, 

you must verify that the vendor or subrecipient 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 subrecipient 

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). 

21 
18. Employment Eligibility 

 

Condition: 

The recipient 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. 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. 

19. Whistleblower Protection 

Condition: 

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

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

federal contract or award, a gross waste of federal funds, an abuse of authority relating to a federal contract or 

award, 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 award. 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 appendices in the Award Owner’s Manual for a full text of 

the statute. 

Why this condition: 

Under “Enhancement of contractor protection from reprisal for disclosure of certain information” (41 U.S.C. § 

4712), recipients are prohibited from taking reprisal actions against employees for certain whistleblowing activities 

in connection with federal awards and contracts. The law 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 awards to certain persons and entities. 

22 
 

 

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 award; 

•	 a gross waste of federal funds; 

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

•	 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 award.
 

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 award oversight or management at the relevant agency; 

•	 an authorized official of the US Department of Justice or other law enforcement agency; 

•	 a court or grand jury; or 

•	 a management official or other employee of the contractor, subcontractor, or recipient 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 

award. 

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 the appendices for a full text of the “Enhancement of contractor protection from reprisal for disclosure 

of certain information” (41 U.S.C. § 4712). 

20. Mandatory Disclosure 

Condition: 

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 2 C.F.R. § 200.338. 

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. 

23 
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. 

21. Conflict of Interest 

Condition: 

Recipients and subrecipients 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 2 C.F.R. § 200.112. 

Why this condition: 

Recipients and subrecipients 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 recipients and subrecipients 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 recipient or subrecipient
 

This also means that recipients and subrecipients 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. 

22. Contract Provision 

Condition: 

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

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

Awards). Please see appendices in the Award Owner’s Manual for a full text of the contract provisions. 

24 
 

 

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 under 2 C.F.R. Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under 

Federal Awards in the appendices of this manual. 

23. Restrictions on Internal Confidentiality Agreements 

Condition: 

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 VII, of the Consolidated Appropriations Act, 2017 (Pub. L. 115-31), 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: 

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. 

25 
 

 

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. 

24. Recipient Integrity and Performance Matters. 

Condition: 

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

term in all awards over $500,000 made on or after January 1, 2016: 

A.	 Reporting of Matters Related to Recipient Integrity and Performance 

1.	 General Reporting Requirement 

If the total value of your currently active awards, cooperative agreements, and procurement contracts 

from all Federal awarding agencies exceeds $10,000,000 for any period of time during the period of 

performance of this Federal award, then you as the recipient during that period of time must maintain the 

currency of information reported to the System for Award Management (SAM) that is made available in 

the designated integrity and performance system (currently the Federal Awardee Performance and 

Integrity Information System (FAPIIS)) about civil, criminal, or administrative proceedings described in 

paragraph 2. of this award term and condition. This is a statutory requirement under section 872 of Public 

Law 110-417, as amended (41 U.S.C. 2313). As required by section 3010 of Public Law 111-212, all 

information posted in the designated integrity and performance system on or after April 15, 2011, except 

past performance reviews required for Federal procurement contracts, will be publicly available. 

2.	 Proceedings About Which You Must Report 

Submit the information required about each proceeding that: 

a.	 Is in connection with the award or performance of an award, cooperative agreement, or procurement 

contract from the Federal Government; 

b.	 Reached its final disposition during the most recent five year period; and 

c.	 Is one of the following: 

(1)	 A criminal proceeding that resulted in a conviction, as defined in paragraph 5. of this award term 

and condition; 

(2)	 A civil proceeding that resulted in a finding of fault and liability and payment of a monetary fine, 

penalty, reimbursement, restitution, or damages of $5,000 or more; 

26 
 

 

(3)	 An administrative proceeding, as defined in paragraph 5. of this award term and condition, that 

resulted in a finding of fault and liability and your payment of either a monetary fine or penalty of 

$5,000 or more or reimbursement, restitution, or damages in excess of $100,000; or 

(4)	 Any other criminal, civil, or administrative proceeding if: 

i.	 It could have led to an outcome described in paragraph 2.c.(1), (2), or (3) of this award term 

and condition; 

ii.	 It had a different disposition arrived at by consent or compromise with an acknowledgment 

of fault on your part; and 

iii.	 The requirement in this award term and condition to disclose information about the 

proceeding does not conflict with applicable laws and regulations. 

3. Reporting Procedures
 

Enter in the SAM Entity Management area the information that SAM requires about each proceeding 

described in paragraph 2. of this award term and condition. You do not need to submit the information a 

second time under assistance awards that you received if you already provided the information through SAM 

because you were required to do so under Federal procurement contracts that you were awarded.
 

4. Reporting Frequency
 

During any period of time when you are subject to the requirement in paragraph 1. of this award term and 

condition, you must report proceedings information through SAM for the most recent five year period, either
 

to report new information about any proceeding(s) that you have not reported previously or affirm that there 

is no new information to report. Recipients that have Federal contract, award, and cooperative agreement
 

awards with a cumulative total value greater than $10,000,000 must disclose semiannually any information 

about the criminal, civil, and administrative proceedings.
 

5. Definitions
 

For purposes of this award term and condition:
 

a.	 Administrative proceeding means a non-judicial process that is adjudicatory in nature in order to 

make a determination of fault or liability (e.g., Securities and Exchange Commission Administrative 

proceedings, Civilian Board of Contract Appeals proceedings, and Armed Services Board of Contract 

Appeals proceedings). This includes proceedings at the Federal and State level but only in connection 

with performance of a Federal contract or award. It does not include audits, site visits, corrective 

plans, or inspection of deliverables. 

b.	 Conviction, for purposes of this award term and condition, means a judgment or conviction of a 

criminal offense by any court of competent jurisdiction, whether entered upon a verdict or a plea, and 

includes a conviction entered upon a plea of nolo contendere. 

c.	 Total value of currently active awards, cooperative agreements, and procurement contracts
 

includes—
 

(1)	 Only the Federal share of the funding under any Federal award with a recipient cost share or 

match; and 

(2)	 The value of all expected funding increments under a Federal award and options, even if not yet 

exercised. 

27 
Why this condition: 

Under 2 C.F.R. § 200.210 (b) (1) (iii), recipients of awards in excess of $500,000 are required to report certain civil, 

criminal, and administrative proceedings if they have active federal grants, cooperative agreements, or contracts 

(or any combination of these) that total more than $10,000,000 during the COPS Office award period. The purpose 

is to protect the public interest and to ensure proper management in federal activities by conducting business with 

responsible parties. 

What you should do: 

If the total value of your active grants, cooperative agreements, and contracts from all federal awarding agencies 

exceeds $10,000,000 during the COPS Office award period, then you must ensure that the proceedings described 

in paragraph 2 of this award term that are reported in the System for Award Management (SAM) are current. The 

information about the reported proceedings is made available in SAM via the designated integrity and 

performance system (currently the Federal Awardee Performance and Integrity Information System (FAPIIS)). 

During the award period, you must either report for the most recent five year period new information about any 

proceeding(s) that you have not reported previously or affirm that there is no new information to report. You must 

also disclose semiannually any information about criminal, civil, and administrative proceedings. 

25. Compliance with 8 U.S.C. 1373 

Condition: 

Authority to obligate or expend contingent on compliance with 8 U.S.C. 1373 

NOTE: This grant condition applies only to State or local government entities or to non-State or local government 

entities that make subawards with these funds to a State or local government entity. 

State or local government entity recipients of this award, and any subrecipient of this award at any tier that is an 

entity of a State or of a unit of local government, may not obligate or expend award funds if – at the time of the 

obligation or expenditure – the “program or activity” of the recipient funded in whole or in part with the award 

funds (which includes any such program or activity of any subrecipient at any tier) is subject to any prohibitions or 

restrictions on sending to, requesting or receiving from, maintaining, or exchanging information on citizenship or 

immigration status as described in 8 U.S.C. § 1373(a) or (b), including any prohibitions or restrictions imposed or 

established by a State or local government entity or official. 

A subrecipient of this award (at any tier) that is an entity of a State or of a unit of local government may not 

obligate or expend award funds if – at the time of the obligation or expenditure – the “program or activity” of the 

subrecipient (which includes any such program or activity of any subrecipient at any further tier) funded (in whole 

or in part) with award funds is subject to any prohibitions or restrictions on sending to, requesting or receiving 

from, maintaining, or exchanging information on citizenship or immigration status as described in 8 U.S.C. 1373(a) 

or (b), including any prohibitions or restrictions imposed by a State or local government entity or official. 

Any obligations or expenditures of a recipient or subrecipient that are impermissible under this condition shall be 

unallowable costs for purposes of this award. 

28 
 

 

 

Rules of Construction/ For purposes of this condition, “program or activity” means what it means under section 606 

of title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d-4a). Pursuant to 8 U.S.C. 1551 note, references to the 

Immigration and Naturalization Service in 8 U.S.C. 1373 are to be read, as a legal matter, as references to 

particular components of the U.S. Department of Homeland Security. 

Should any provision of a condition of this award be held to be invalid or unenforceable by its terms, then that 

provision shall first be applied with a limited construction so as to give it the maximum effect permitted by law (to 

any person or circumstance) under this award. Should it be held, instead, that a condition (or a provision thereof) is 

of utter invalidity or unenforceability, such condition (or such provision) shall be deemed severable from this award. 

Any questions about the meaning or scope of this condition should be directed, prior to acceptance of this award, 

to the Office of Community Oriented Policing Services Legal Division at 202-514-3750. 

Why this condition: 

All FY 2017 State or local government recipients or subrecipients of COPS Office funding must comply with 8 U.S.C. 

1373 throughout the life of the award. 

What you should do: 

State and local government entities that applied for FY 2017 COPS Office funding and non-State or local 

government entities that applied to use FY 2017 COPS Office funding to make subawards to State or local 

government entities were required to certify compliance with 8 U.S.C. 1373 to be eligible to submit an application 

for funding. Compliance with 8 U.S.C. 1373 is also required throughout the active award period. 

Any questions about the meaning or scope of this condition should be directed, prior to acceptance of this award, 

to the Office of Community Oriented Policing Services Legal Division at 202.514.3750. 

26. Computer Network Requirement 

Condition: 

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 532 of Division B, Title V, of the Consolidated Appropriations Act, 2017 (Pub. L. 115-31) 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. 

29 
27. Travel Costs 

 

 

Condition: 

Travel costs for transportation, lodging and subsistence, and related items are allowable under the PASS Program 

with prior approval from the COPS Office. Payment for allowable travel costs will be in accordance with 2 C.F.R. § 

200.474. 

Why this condition: 

PASS funding will cover award-related travel costs for the recipient agency or other (nonrecipient) individuals to 

attend training and technical assistance conferences, seminars, or classes or to visit a site specified in the original 

application. Allowable expenses for award-related lodging, meals, and incidental expenses that were included in 

the application were approved by the COPS Office as part of your agency’s PASS award and final budget. For more 

information, please refer to the award condition on “Allowable Costs.” 

What you should do: 

Your agency should refer to your FCM for a list of approved travel costs and use PASS funds only for approved 

travel costs incurred during the award 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 Program 

Manager. 

28. Sole Source Justification 

Condition: 

Recipients 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 

award funds for that item or service. 

Why this condition: 

In general, recipients are required to procure funded items through open and free competition. However, in some 

instances, recipients may have already determined that competition is not feasible. 

What you should do: 

If you have received an award for an item (or group of items) or service in excess of $150,000 and have already 

determined that the award of a contract through a competitive process is infeasible, you must provide a written 

justification that explains why it is necessary to contract noncompetitively. 

The initial determination that competition is not feasible can be made if one of the following circumstances exists: 

•	 Competition is determined inadequate after solicitation of a number of sources. 

•	 The COPS Office authorizes noncompetitive proposals in response to a written request from the recipient. 

•	 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.
 

30 
 

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 made to the general rule regarding competition. If 

submitting a sole source justification request to the COPS Office, please use the format described in the Sole 

Source Justification fact sheet in the appendices of this manual. 

29. Public Release Information 

Condition: 

The recipient agrees to submit one copy of all reports and proposed publications resulting from this award ninety 

(90) days prior to public release. Any publications (written, curricula, visual, sound, reports, or websites) or 

computer programs, whether or not published at government expense, shall contain the following statement: 

“This project was supported, in whole or in part, by Cooperative Agreement Number 2017-XX-XX-XXXX 

awarded by the US Department of Justice, Office of Community Oriented Policing Services. The opinions 

contained herein are those of the author(s) or contributor(s) and do not necessarily represent the official 

position or policies of the US Department of Justice. References to specific individuals, agencies, 

companies, products, or services should not be considered an endorsement by the author(s) or the US 

Department of Justice. Rather, the references are illustrations to supplement discussion of the issues. 

The internet references cited in this publication were valid as of the date of publication. Given that URLs 

and websites are in constant flux, neither the author(s) nor the COPS Office can vouch for their current 

validity.” 

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 works of authorship by 

the Federal Government and should not be construed to reflect the official policy or position of the US Department 

of Justice. 

What you should do: 

Ensure that all publications developed under your award contain the required statement listed above. 

30. Criminal Intelligence Systems 

Condition: 

Recipients using award funds to operate an interjurisdictional criminal intelligence system must comply with the 

operating principles of 28 C.F.R. Part 23. By signing the Certification of Review and Representation of Compliance 

with Requirements in the application, the recipient assured the COPS Office that it will comply with the 

requirements of 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 in 28 C.F.R. Part 23. An 

“interjurisdictional criminal intelligence system” is generally defined as a system that receives, stores, analyzes, 

31 
 

 

 

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 information systems that protect individual 

privacy and constitutional rights. 

If your agency will use award funds 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 your 

award. 

What you should do: 

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 award funds to operate an 

interjurisdictional criminal intelligence system, you should have indicated this in your application and certified your 

agency’s agreement to comply with the operating principles found at 28 C.F.R. Part 23. Your agency now must 

comply with 28 C.F.R. Part 23 in operating the interjurisdictional criminal intelligence system funded through your 

PASS award. 

31. State Information Technology Point of Contact 

Condition: 

The recipient agrees to ensure that the appropriate State Information Technology Point of Contact receives written 

notification regarding any technology or information-sharing project funded by this award during the obligation 

and expenditure period. This is to facilitate communication among local and state governmental entities regarding 

various information technology projects being conducted with these award funds. In addition, the recipient agrees 

to maintain an administrative file documenting the meeting of this requirement. For a list of State Information 

Technology Points of Contact, go to https://it.ojp.gov/technology-contacts. 

Why this condition: 

The COPS Office is committed to promoting communication between state and local law enforcement. 

What you should do: 

If applicable, upon receiving the award, your agency should contact your state information technology point of 

contact for further guidance. Please visit the Justice Information Sharing homepage at 

https://it.ojp.gov/default.aspx?area=policyAndPractice&page=1046 and search keywords “State and Territory 

Technology Points of Contact.” 

The COPS Office is committed to avoiding duplication of existing law enforcement information-sharing networks or 

IT systems that involve interagency connectivity between jurisdictions. Therefore, such COPS Office–funded 

systems should employ, to the extent possible, existing systems such as Law Enforcement Online (LEO), Regional 

Information Sharing Systems (RISS), Joint Regional Information Exchange System (JRIES), etc., to achieve interstate 

connectivity. 

32 
32. News Media 

 

Condition: 

The recipient agrees to comply with the COPS Office policy on contact with the news media. The policy establishes 

the COPS Office Communications Division as the principal point of contact for the news media for issues relevant to 

the COPS Office or parameters of this award. The recipient agrees to refer all media inquiries on these topics 

directly to the COPS Office Communications Division at 202-514-9079. 

Why this condition: 

The COPS Office Communications Division will coordinate contacts with the news media, provide supplemental 

information that may be helpful to you and the media outlet, and make the appropriate US Department of Justice 

offices and personnel aware of pending articles and interviews. 

What you should do: 

If you are contacted by a media outlet seeking information, an interview, or other support related to your COPS 

Office project, please refer the requesting outlet to the COPS Office Communications Division at 202-514-9079. 

33. Paperwork Reduction Act (PWRA) 

Condition: 

The recipient agrees, if required, to submit all surveys, interview protocols, and other information collections 

funded by this award to the COPS Office for submission to the Office of Management and Budget (OMB) for 

clearance under the Paperwork Reduction Act (PWRA) of 1995. 

Why this condition: 

The purpose of the Paperwork Reduction Act is to reduce, minimize, and control paperwork burdens on the public 

while maximizing the practical utility and public benefit of information created, collected, disclosed, maintained, 

used, shared, and disseminated by or for the Federal Government. See 5 C.F.R. § 1320.1. 

A collection of information undertaken by a recipient is considered to be conducted or sponsored by a federal 

agency only if (1) the recipient is conducting the collection of information at the specific request of the agency, or 

(2) the terms and conditions of the award require specific approval by the agency of the collection of information 

or the collection procedures. See 5 C.F.R. § 1320.3(d). 

What you should do: 

When you undertake surveys, interviews, and other methods of information collection in furtherance of the 

objectives of the award, you should contact your COPS Office Program Manager. The COPS Office Program 

Manager will inform you whether Office of Management and Budget (OMB) approval of the information collection 

method is required and of the procedures necessary to obtain this approval. OMB approval may take several 

months to receive, so recipients are advised to allow ample time for the processing of this request. 

33 
34. Human Subjects Research 

 

 

 

 

Condition: 

The recipient agrees to comply with the provisions of the US Department of Justice’s common rule regarding 

Protection of Human Subjects, 28 C.F.R. Part 46, prior to the expenditure of Federal funds to perform such activities, 

if applicable. The recipient also agrees to comply with 28 C.F.R. Part 22 regarding the safeguarding of individually 

identifiable information collected from research participants. 

Why this condition: 

Protections for human subjects of research are required under US Department of Justice regulations at 28 C.F.R. 

Part 46. This regulation constitutes the Federal Policy (Common Rule) for the Protection of Human Subjects. Each 

institution engaged in (nonexempt) COPS Office–supported human subjects research must provide a written 

assurance of compliance, satisfactory to the COPS Office, that it will comply with the US Department of Justice 

human subjects regulations. 

What you should do: 

If any part of your PASS project contains research or statistical activities which involve human subjects that are not 

covered by an exemption set forth in 28 C.F.R. Part 46.101(b), you must comply with the requirements in the US 

Department of Justice’s common rule regarding the Protection of Human Subjects, 28 C.F.R. Part 46, including, but 

not limited to Institutional Review Board (IRB) approval and the appropriate assurances prior to the expenditure of 

federal funds to perform such activities. By signing the award document, you also agree to comply with 28 C.F.R. 

Part 22 regarding the safeguarding of individually identifiable information collected from research participants. 

35. Copyright 

Condition: 

If applicable, the recipient may copyright any work that is subject to copyright and was developed, or for which 

ownership was acquired, under this award in accordance with 2 C.F.R. § 200.315(b). The COPS Office reserves a 

royalty-free, nonexclusive and irrevocable license to reproduce, publish, or otherwise use the work, in whole or in 

part (including create derivative works), for Federal Government purposes, and to authorize others to do so. The 

COPS Office also reserves the right, at its discretion, not to publish deliverables and other materials developed 

under this award as a US Department of Justice resource. 

When appropriate, US Department of Justice publications and other deliverables developed with award funds 

should contain the following copyright notice: 

“Copyright © [year work was published] [name of copyright owner]. The US Department of Justice 

reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use, and 

authorize others to use, this resource for Federal Government purposes. This resource may be freely 

distributed and used for noncommercial and educational purposes only.” 

34 
 

 

Why this condition: 

US Department of Justice regulations allow the recipient of a PASS award to copyright any work that is subject to 

copyright and was developed, or for which ownership was purchased, under an award. 

As a Federal Government agency whose activities include producing and disseminating law enforcement materials 

to advance public safety through community policing across the nation, the COPS Office has an interest in making 

your deliverables and products widely available and accessible to the public. The COPS Office may make any work 

that was developed or purchased under this award publically available by any means without restriction, including 

a US Department of Justice website, social media account, a hard copy, or in electronic form. The COPS Office also 

reserves the right, at its discretion, to not publish deliverables and other materials (e.g., reports, publications, 

manuals, and training curricula) developed under this award as a US Department of Justice resource. 

What you should do: 

The recipient is responsible for acquiring the rights, and ensuring that its subrecipients/contractors/authors 

acquire the rights, including the payment of required fees, to use copyrighted material for inclusion in deliverables 

that are developed under this award. All licensing, publishing, or similar agreements with a copyright holder, 

publisher, or other relevant party must include provisions giving the COPS Office a royalty-free, nonexclusive, and 

irrevocable license to reproduce, publish, or otherwise use the work in whole or in part (including create derivative 

works) for Federal Government purposes and to authorize others to do so. If the recipient retains a contractor or 

consultant to author or coauthor a work under this award, the recipient must ensure that there is a written 

agreement with the contractor or consultant that explicitly (1) assigns and transfers all rights to the copyright in 

the work to the recipient for the full term of copyright andr, if a copyright transfer is not feasible, (2) awards the 

COPS Office the same royalty-free, nonexclusive, and irrevocable license to use, and authorize others to use, the 

work for Federal Government purposes. 

The US Department of Justice is a nonexclusive licensee to copyrighted work that was developed, or for which 

ownership was purchased, under this award. Only the legal or beneficial owner of an exclusive right under a 

copyright is entitled to institute an infringement action. The recipient should therefore consult its own legal 

counsel with any copyright infringement questions. For more information about registering a copyright, please visit 

the US Copyright Office at www.copyright.gov. 

To help protect against unauthorized use, COPS Office–funded publications and other deliverables should contain 

the above-referenced copyright notice when appropriate. 

What are the specific rules regarding termination of award 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 award 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 award requirements or conditions; 

•	 proposing substantial plan changes to the extent that, if originally submitted, would have resulted in the
 

application being denied funding;
 

35 
 

 

 

•	 not submitting financial or programmatic reports in a timely manner; 

•	 filing false statements or certifications in connection with an application, periodic report, or other awardrelated 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 award; 

•	 require that some or all of the award funds be remitted to the US Department of Justice; 

•	 condition a future award or elect not to provide future award funds to your agency until appropriate actions 

are taken to ensure compliance; 

•	 withhold or restrict 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 award is terminated, your agency will be notified in writing of our 

decision and the reason(s) for that decision. 

Awards terminated due to noncompliance with the federal statutes, regulations, or award terms and conditions 

will be reported to the integrity and performance system accessible through SAM (currently FAPIIS). 

Accepting the award 

After you have reviewed the conditions of your COPS Office PASS Program award and your agency agrees with 

these conditions, you are ready to accept the award. The Director (or Acting Director) of the COPS Office has 

signed the award document indicating approval of your award, 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 award and 

draw down your funds, the authorized officials (see the Glossary of Terms in this manual) must access 

https://portal.cops.usdoj.gov to log in, review, and electronically sign the award document with the award terms 

and conditions; the Financial Clearance Memorandum and, if applicable, the cooperative agreement that is 

incorporated by reference into the award document; and, if applicable, the special award conditions and high risk 

conditions in the award document supplement within 90 days of the date shown on the award congratulatory 

letter. 

Who should sign the award document for our agency? 

The authorized officials are the law enforcement and government executives who have ultimate and final 

responsibility for all programmatic and financial decisions regarding this award as representatives of the legal 

recipient. COPS Office awards require that both the top law enforcement executive (e.g., chief of police, sheriff, or 

equivalent) and the top government executive (e.g., mayor, board chairman, or equivalent) sign the award 

document. For non–law enforcement agencies (institutions of higher education, private organizations, etc.), the 

authorized officials are the programmatic and financial officials who have the ultimate signatory authority to sign 

contracts on behalf of your organization. Typically, these are the same executives who signed the forms in your 

36 
 

 

 

PASS application package. If one or both of these individuals have changed, please complete a Change of 

Information (COI) form online at https://portal.cops.usdoj.gov. If you have any questions as to who should sign 

the award, please contact your organization’s legal counsel. 

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. Award 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 award conditions particular to your 

agency have been satisfied. Failure to electronically sign your original award document within the 90-day award 

acceptance period may result in your PASS 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, you will be able to request an extension through the online system. Be sure to explain the 

circumstances that prevent your agency from electronically signing the award document within the 90-day period, 

and identify the date by which the award document will be 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. If you have any questions, please contact your COPS Office Program Manager via or the COPS Office 

Response Center at 800-421-6770. 

37 
 

 

 

II. The Cooperative Agreement 

If your project requires substantial involvement on the part of the COPS Office, a multi-page cooperative 

agreement document will accompany your award document. Please note that, if applicable to your award, the 

cooperative agreement is incorporated by reference into the award document and by signing the award 

document, your agency has entered into the cooperative agreement with the COPS Office and agrees to abide by 

all the requirements in the cooperative agreement. 

Under the Federal Grant and Cooperative Agreement Act of 1977, a cooperative agreement is the legal instrument 

used by a federal agency to enter into a relationship with a state, local government, or other recipient when the 

principal purpose of assistance is to carry out a public purpose of support or stimulation authorized by federal law 

and substantial involvement is expected between the federal agency and the recipient. See 31 U.S.C. § 6305. 

To officially accept and begin your PASS award, your agency and the assigned COPS Office Program Manager will 

develop a CA based on the award objective(s), deliverables and timeline proposed in the application. Your agency 

will approved the cooperative agreement document along with the award document and electronically sign for all 

documents within 90 days of the date shown on the award congratulatory letter. 

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

document. 

Below is a sample 2017 cooperative agreement template that will be customized for your specific COPS Officefunded project. If you have any additional questions concerning your cooperative agreement, please contact your 

designated COPS Office Program Manager. 

I. Statement of authority 

This cooperative agreement between the [Insert Agency Name] (“recipient”) and the US Department of 

Justice Office of Community Oriented Policing Services (“COPS Office”) is hereby entered into under the 

authority of 42 U.S.C. § 3796dd et seq. The purposes of this cooperative agreement are described below. 

II. Statement of background and purpose 

A. Background: 

[Insert background – should set the stage for the CA including why this effort is needed, history of effort
 

to date and reasons why the effort is required now]
 

[Insert project purpose – should clearly state rationale for the work]
 

B. Primary objective: 

[Insert project objective – should include what we hope to accomplish – could be a number of small 

objectives] 

38 
 

 

III. Scope of Work 

For a period hereinafter set forth, the COPS Office and the recipient will cooperatively furnish the necessary 

personnel, travel, supplies, and otherwise perform all things necessary for, or incident to, the performance of 

work (the accomplishment of functional objectives) as set forth below: 

A.	 Specifically, the COPS Office will do the following: 

1.	 Designate a Program Manager to participate in the planning and management of this cooperative 

agreement and to coordinate project activities. 

2.	 Provide information and technical assistance from government sources within available 

resources and as determined appropriate by the Program Manager. 

3.	 Provide guidance to the recipient in the planning and development of strategies used in the 

project and in the coordination of the project with law enforcement agencies and organizations 

interested in contributing their support. 

4.	 Work with the recipient to meet the designated project tasks and timelines. 

5.	 Review and approve required reports specific to each cooperative agreement, which may include 

periodic progress and financial reports, deliverables, evaluations, and other documentation 

requiring COPS Office approval for successful award administration. 

6.	 Review and approve all training processes and deliverables including, but not limited to, inperson and/or online training, pre-existing in-person and/or online training, all supplemental and 

additional resources, all trainers, and all marketing efforts. 

7.	 Review and approve all project deliverables including, but not limited to, innovation and pilot 

program publications, microgrant project publications, and partnerships project publications. In 

addition, all multimedia deliverables and marketing efforts. 

8.	 Review and approve all proposed changes in key staff assignments to the project and any 

significant changes in the partner’s role or responsibilities. 

9.	 Review and approve all proposed writers of any project deliverables. 

10. Review and approve all subject matter experts and their assignments to any project deliverable. 

11. Permit the recipient to copyright any work that is subject to copyright and was developed, or for 

which ownership was acquired, under this cooperative agreement in accordance with 2 C.F.R. § 

200.315(b). The COPS Office reserves a royalty-free, nonexclusive and irrevocable license to 

reproduce, publish, or otherwise use the work, in whole or in part (including create derivative 

works), for Federal Government purposes, and to authorize others to do so. The COPS Office 

license applies to (1) the copyright in any work developed under this cooperative agreement 

including any related subaward or contract and (2) any rights of copyright to which the recipient, 

including its subrecipient or contractor, purchases ownership with support from this cooperative 

agreement. In addition, the COPS Office may make any work that was developed or purchased 

under this cooperative agreement publically available by any means without restriction, including 

a US Department of Justice website or social media account, a hard copy, or in electronic form. 

The COPS Office also reserves the right, at its discretion, to not publish deliverables and other 

materials (e.g., reports, publications, manuals, and training curricula) developed under this 

cooperative agreement as a US Department of Justice resource. 

39 
 

 

 

 

B.	 Specifically, the recipient will do the following: 

1.	 Designate a project officer to work closely with the COPS Office and its designated Program 

Manager to achieve the tasks specified in this cooperative agreement. The project officer must 

be an employee of the recipient organization, and have the authority to propose and approve 

modifications pursuant to Section VIII. of this cooperative agreement. 

2.	 Be responsible for acquiring the rights, and ensuring that its 

subrecipients/contractors/consultants/authors acquire the rights, including the payment of 

required fees, to use copyrighted material for inclusion in deliverables that are developed under 

this cooperative agreement. All licensing, publishing or similar agreements with a copyright 

holder, publisher or other relevant party must include provisions giving the COPS Office a royaltyfree, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use the work, in 

whole or in part (including create derivative works), for Federal Government purposes, and to 

authorize others to do so. If recipient retains a contractor or consultant to author or co-author a 

work under this cooperative agreement, the recipient must ensure that there is a written 

agreement with the contractor or consultant that either explicitly: (1) assigns and transfers all 

rights to the copyright in the work to the recipient for the full term of copyright or, if a copyright 

transfer is not feasible, (2) awards the COPS Office the same royalty-free, nonexclusive and 

irrevocable license to use, and authorize others to use, the work for Federal Government 

purposes as outlined in this cooperative agreement. 

3.	 Represent and warrant that all deliverables under this cooperative agreement were produced in 

a manner that does not knowingly infringe or misappropriate the intellectual property rights, or 

violate the right to privacy, of any third party. The recipient will be responsible for defending or 

settling at its own expense any and all third party claims and liabilities arising out of or in 

connection with any infringement action related to work that was developed, or for which 

ownership was acquired, under this cooperative agreement. 

4.	 Provide further detail on project plans as requested by the COPS Office Program Manager. 

5.	 Adhere to the requirements or tasks specified in this cooperative agreement and not deviate 

from them unless requested adjustments are first presented to and approved by the COPS Office 

Program Manager. 

6.	 Submit for prior approval or disapproval to the COPS Office Program Manager any proposed 

changes in key staff assignments to this project and any significant changes in any partner’s role 

or responsibilities. 

7.	 Submit for prior approval to the COPS Office Program Manager proposed writers of any project 

deliverables. The Program Manager will need to review each writer’s resume and writing sample 

before approving the writer. 

8.	 Submit for prior approval to the COPS Office Program Manager proposed subject matter experts 

to be used on the project. The COPS Office Program Manager will review each subject matter 

expert’s resume before approving the subject matter expert. 

9.	 Obtain written approval from the COPS Office prior to obligating, expending, or drawing down 

cooperative agreement funds for the award of noncompetitive contracts for goods or services 

(including equipment purchases) in excess of $150,000. See 2 C.F.R. § 200.324(b)(2). 

10. Ensure that all proposed deliverables and publications follow and are in accordance with the 

COPS Office Editorial and Graphics Style Manual, which includes that all nonoriginal work should 

be credited as appropriate. 

40 
 

 

 

 

 

11. Submit one copy of all reports and proposed products and deliverables (written, visual, or sound; 

curricula, reports, or websites) or computer programs resulting from this cooperative agreement 

to the Program Manager at least 90 days prior to public release to allow for COPS Office review 

and feedback. 

12. All products and deliverables including those in written, visual, sound, websites or any other 

format developed under this cooperative agreement must contain the following statement: 

This project was supported, in whole or in part, by cooperative agreement number 2017-XXXX-XXXX awarded by the US Department of Justice, Office of Community Oriented Policing 

Services. The opinions contained herein are those of the author(s) or contributor(s) and do 

not necessarily represent the official position or policies of the US Department of Justice. 

References to specific individuals, agencies, companies, products, or services should not be 

considered an endorsement by the author(s) or the US Department of Justice. Rather, the 

references are illustrations to supplement discussion of the issues. 

The internet references cited in this publication were valid as of the date of publication. Given 

that URLs and websites are in constant flux, neither the author(s) nor the COPS Office can 

vouch for their current validity. 

When appropriate, US Department of Justice publications and other products and deliverables 

developed under this cooperative agreement should contain the following copyright notice: 

Copyright © [year work was published] [name of copyright owner]. The US Department of 

Justice reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, publish, or 

otherwise use, and authorize others to use, this resource for Federal Government purposes. 

This resource may be freely distributed and used for noncommercial and educational 

purposes only. 

13. Contact the COPS Office Program Manager to determine if revenue generated from your award 

constitutes program income. Program income must be used to defray program costs and reduce 

the federal share of the project. See 2 C.F.R. § 200.307. In some cases, the recipient can work 

with the COPS Office Program Manager to identify additional project-related allowable costs that 

could be supported by program income. 

14. Not earn or keep any profit resulting from this award unless expressly authorized, in writing, by 

the COPS Office. See 2 C.F.R. § 200.400(g). 

15. Ensure that all electronic and information technology deliverables (websites and web-based 

information, video and multimedia products, software applications and operating systems, and 

telecommunication products) are developed and produced in a format that is accessible and 

comply with Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d). 

Specifically, video should contain closed-captioning and audio description options. Electronic 

publications should be created in HTML, PDF fully tagged, or accessible text file format and all 

web sites must be fully compliant with Section 508 accessibility standards. For more information 

on Section 508 accessibility requirements, consult https://www.section508.gov. 

16. If developing or delivering training under this cooperative agreement, the COPS Office Curriculum 

Standards, Review, and Approval Process Guides: Online and In-Person and COPS Office and 

Instructor Quality Assurance Guide must be followed. This applies to the development and/or 

delivery of online and in-person courses. Courses already in existence that are part of this 

cooperative agreement must also comply with the two aforementioned guides. A copy of these 

41 
 

 

 

 

 

 

 

 

guides, along with supplemental training resources, will be supplied electronically to you by the 

Program Manager and are also located on the COPS Office website for download. All training 

development processes and deliverables must be reviewed and approved by the COPS Office 

prior to public release following the process indicated in the guides. For more information, 

please see the training fact sheets in this manual. 

17. Ensure that web-based courses developed through this cooperative agreement are compatible 

with the current platform used in the Community Policing Learning Portal. Prior to the 

development of the web-based course, the recipient must receive guidance and work with the 

COPS Office to ensure compatibility. Web-based courses developed through this cooperative 

agreement must be reviewed and approved by the COPS Office prior to public release. 

18. At the request of the COPS Office, submit all website(s) and web-based information that are 

developed through this cooperative agreement to the COPS Office. The information will be 

submitted in a format that will enable the COPS Office to reproduce the website(s) and webbased information on alternative web-based platforms. 

19. If required, submit all surveys, interview protocols, and other information collections to the COPS 

Office for submission to the Office of Management and Budget (OMB) for clearance under the 

Paperwork Reduction Act (PWRA) of 1995. 

20. Agree to cooperate with the monitor or evaluator if monitoring or an evaluation of this project is 

to be undertaken by the COPS Office or a third party, and in consultation with the COPS Office, 

agree to make reasonable adjustments to programs and activities in recognition of significant 

points of evaluation or feedback, and to remedy any violations of the terms and conditions of 

this award. 

21. Be responsible for the development, approval, and oversight of any subawards. See 2 C.F.R. §§ 

200.330 - 200.332. The recipient will ensure that the award terms and conditions flow down to 

its subrecipients including all applicable uniform administrative requirements, costs principles, 

and audit requirements set forth in 2 C.F.R. Part 200. See 2 C.F.R. § 200.101(b)(1). The recipient 

will also ensure that subrecipients maintain effective control and accountability over all funds, 

property and other assets covered by subawards and that each subrecipient establishes and uses 

internal fiscal and program management procedures sufficient to prevent fraud, waste, or abuse. 

22. At the request of the COPS Office, work to develop a marketing plan to increase the visibility of 

the project and any accompanying outcomes/deliverables. The recipient will coordinate any 

marketing activities with the COPS Office. 

23. Coordinate all public communication activities (in any format including website and social media 

content) related to this project or the COPS Office with the Program Manager prior to release. 

24. Work closely with the COPS Office and Program Manager to respond to peer reviewer, vetting, 

and other COPS Office staff comments within 30 days of receipt. 

25. Obtain written approval from the COPS Office prior to entering into any contract, agreement or 

other obligation for costs related to any conference, meeting, retreat, seminar, symposium, 

training activity, or similar event funded under this award. Submit the Conference Cost 

Request/Reporting Form (CCR) at least 90 days prior to event to the Conference Cost Request 

mailbox at COPS.Conferencecosts@usdoj.gov and copy your Program Manager. The CCR form is 

available at https://cops.usdoj.gov/pdf/ 2017 AwardDocs/cpd/Conference. The document will 

have you breakout each event or training deliveries and ensures that all costs comply with 

current guidelines and policies on event/training planning, food and beverages, minimizing costs. 

Training or events should not be scheduled or delivered prior to receiving notice from your 

42 
 

 

Program Manager that the CCR is approved. For more information on allowable costs for 

conferences and training, please see the current version of the DOJ Grants Financial Guide in 

effect at the time of the award available at https://ojp.gov/financialguide/DOJ/index.htm. 

26. Ensure that all conference or similar event costs comply with current and future guidelines and 

policies that you receive from the COPS Office on conference planning, food and beverages, 

minimizing costs, and conference cost reporting. 

27. Within 45 days after the end of any conference, meeting, retreat, seminar, symposium, training 

activity, or similar event funded under this award, and the total cost of which exceeds $20,000 in 

award funds, the recipient must provide the Program Manager with the following information 

and itemized costs: 

•	 Name of the event 

•	 Event dates 

•	 Location of event 

•	 Number of federal attendees 

•	 Number of nonfederal attendees 

•	 Costs of event space, including rooms for break-out sessions 

•	 Costs for audio visual services 

•	 Other equipment costs (e.g., computer fees, telephone fees) 

•	 Costs of printing and distribution 

•	 Costs of meals provided during the event 

•	 Costs of refreshments provided during the event 

•	 Costs of event planner 

•	 Costs of event facilitators 

•	 Any other direct costs associated with the event 

The recipient must also itemize and report any of the following attendee (including participants, 

presenters, speakers) costs that are paid or reimbursed with cooperative agreement funds: 

•	 Meals and incidental expenses (M&IE portion of per diem) 

•	 Lodging 

•	 Transportation to/from event location (e.g., common carrier, privately owned vehicle (POV)) 

•	 Local transportation (e.g., rental car, POV) at event location 

•	 Note that if any item is paid for with registration fees, or any other non-award funding, then 

that portion of the expense does not need to be reported. 

28. If applicable, submit by the 5th day of each month, information on all training events funded 

under this award to your Program Manager through the Agency Portal at 

https://portal.cops.usdoj.gov or through the Account Access tab on the COPS Office homepage. 

Training data includes, but is not limited to, date, location, length, title, numbers of individuals 

trained broken out by rank/title, organization, and evaluation results. For a complete list of 

training data collection and submission requirements contact your Program Manager or log into 

the Agency Portal at https://portal.cops.usdoj.gov and select the training reporting tool. The 

quarterly collection dates are as follows: (January 1–March 31 / April 1–June 30 / July 1– 

September 30 / October 1–December 31). 

43 
 

 

 

 

29. If applicable, submit all approved indirect cost rates covering the award period to the COPS 

Office within 30 days of approval from the cognizant federal agency. 

If a provisional indirect cost rate is in effect at award closeout, the recipient will proceed with 

closeout and complete an expenditure analysis upon receipt of the approved final indirect cost 

rate to determine if an adjustment is necessary. If the recipient drew down excess COPS Office 

funding for indirect costs, the recipient must return the overpayment to the COPS Office. If the 

recipient incurred additional indirect costs, the recipient may request a budget modification if 

the award is still open, and there are remaining award funds available for drawdown. If the 

recipient returns or draws down COPS Office funding, the recipient will promptly submit a 

revised final Federal Financial Report (SF-425). 

The recipient should pay particular attention to the two areas listed below to ensure that their 

application of indirect cost rate is in compliance with the existing requirements of the 

government-wide award rules set out by the Office of Management and Budget (OMB): 

a. $25,000 Subcontract/Subaward Limitation: Indirect cost rates negotiated on the basis of 

modified total direct costs may only be applied against the first $25,000 of any subcontract 

or subaward under the agreement. This limitation must be applied to all conference related 

subcontracts and subawards, including those with hotels and travel agents. See 2 C.F.R. Part 

200, Appendix III.C.2. (Indirect costs—Institutions of Higher Education); 2 C.F.R. Part 200, 

Appendix IV.B.2.c. (Indirect costs—Nonprofit Organizations); or 2 C.F.R. Part 200, Appendix 

VII.C.2.c. (Indirect costs—States, Local Governments, and Indian Tribes). 

b. Participant Support Costs: Participant support costs are generally excluded from the 

distribution base. Therefore, indirect costs may not be applied against participant support 

costs. Participant support costs are direct costs for items such as stipends or subsistence 

allowances, travel allowances, and registration fees paid to or on behalf of participants or 

trainees (but not employees) in connection with meetings, conferences, symposia, or 

training projects. See 2 C.F.R. § 200.75. This exclusion applies to the entirety of any 

subcontracts for the lodging and travel of conference participants or trainees (but not 

employees). Costs related to contractors of the recipient who are acting in the capacity of a 

“Conference Trainer/Instructor/ Presenter/Facilitator” are considered participant support 

costs. 

For more information on allowable costs for conferences and training, please see the current 

version of the DOJ Grants Financial Guide in effect at the time of the award available at 

https://ojp.gov/financialguide/DOJ/index.htm. 

Indirect costs were removed from the budget if the recipient did not provide, at the time of 

application, either a current approved federal indirect cost rate or documentation showing a 

pending request for approval by the cognizant federal agency. If the recipient has never received 

a federally approved indirect cost rate, it may elect to charge a de minimis rate of 10% of 

modified total direct costs (MTDC) in lieu of negotiating a rate with the cognizant federal agency. 

See 2 C.F.R. § 200.414(f). 

30. Notify and consult with the COPS Office prior to establishing a formal partnership with any nonfederal entity, including soliciting and accepting free goods or services, on activities under this 

cooperative agreement. 

44 
 

 

 

 

 

31. The recipient will select the site-specific subject matter experts (SMEs) in partnership with the 

COPS Office based on resumes, references, writing samples, and demonstrated subject matter 

expertise. Specific SMEs selected for each site are subject to COPS Office review and approval 

prior to commencement of work. The recipient will ensure that every SME completes a conflict of 

interest disclosure form prior to commencing work, and continually identify and manage any 

conflicts of interest between the SMEs, the recipient, and the sites. The recipient will ensure that 

the SME signs an agreement prior to commencing work on the project, which addresses: (1) the 

nondisclosure of project-related confidential information (including, but not limited to, 

nonpublic, personally identifiable, or sensitive law enforcement information collected from 

interviews, peer-to-peer exchanges, direct observation notes, data analysis, research, or working 

papers) unless authorized in writing by the recipient after receiving written approval from the 

COPS Office; (2) the proper safeguarding and disposition of all project-related records in any 

format containing confidential information during and after performance to protect against the 

unauthorized access to or disclosure of such information; (3) that any public comment requests 

or news media inquiries received by the SME regarding the project must be promptly directed to 

the recipient (who will coordinate with the COPS Office Program Manager and COPS Office 

Communications Division); and (4) that the violation of any of these provisions may result in 

termination of the SME’s involvement in project activities. 

32. Not disclose, and ensure that its subrecipients and contractors will not disclose, any projectrelated confidential information (including, but not limited to, nonpublic, personally identifiable, 

or sensitive law enforcement information collected from interviews, peer-to-peer exchanges, 

direct observation notes, data analysis, research, or working papers) unless authorized in writing 

by the COPS Office. The recipient will, and ensure that its subrecipients and contractors will, 

properly safeguard and dispose of all project-related records in any format containing 

confidential information during and after performance to protect against the unauthorized 

access to or disclosure of such information. Any unauthorized disclosure of project-related 

confidential information or records may result in termination of the recipient’s, including its 

subrecipient’s and contractor’s, involvement in project activities. 

33. Obtain written approval from the COPS Office prior to adding any new subaward or subrecipient 

that was not previously included or identified in the last approved project budget. See 2 C.F.R. § 

200.308(c)(1)(vi). If the subrecipient is a State or local government entity, access to subrecipient 

funding will be contingent upon submission by the recipient and subrecipient of all applicable 

Certification of Compliance with 8 U.S.C. § 1373 forms addressing prohibitions or restrictions on 

sending to, requesting or receiving from, maintaining, or exchanging information on citizenship 

or immigration status, including any prohibitions or restrictions imposed or established by a State 

or local government entity or official. 

C.	 The recipient acknowledges the following: 

1.	 If any part of the funded project contains research or statistical activities which involve human 

subjects that are not covered by an exemption set forth in 28 C.F.R. § 46.101(b), the recipient 

must comply with the requirements in the US Department of Justice’s common rule regarding 

the Protection of Human Subjects, 28 C.F.R. Part 46, including, but not limited to, Institutional 

Review Board (IRB) approval and the appropriate assurances prior to the expenditure of federal 

funds to perform such activities. The recipient also agrees to comply with 28 C.F.R. Part 22 

45 
 

 

 

 

 

regarding the safeguarding of individually identifiable information collected from research 

participants. For general information on Department of Justice human subjects and privacy 

protections, please visit https://www.nij.gov/funding/humansubjects/Pages/welcome.aspx. 

2.	 Implementation of this award will be subject to federal monitoring, auditing, or evaluation, 

and/or a single audit in accordance with 2 C.F.R. § 200.501. The recipient agrees to cooperate 

with such activities by providing access to and copies of, as appropriate, all project-related 

records, documents and personnel. A recipient that expends $750,000 or more in federal funds 

(from all sources) during the recipient’s fiscal year must have a single audit conducted in 

accordance with 2 C.F.R. § 200.514, except when it elects to have a program-specific audit 

conducted in accordance with 2 C.F.R. § 200.501(c). For-profit (commercial) entities should 

follow the dollar threshold in 2 C.F.R. § 200.501 in determining whether to conduct an audit in 

accordance with the Government Auditing Standards. 

3.	 Failure to comply with the terms and conditions of this award may result in legal sanctions 

including, but not limited to, suspension and termination of funds, repayment of expended 

funds, and ineligibility to receive additional COPS Office funding. 

4.	 False statements or claims made in connection with COPS Office awards may result in fines, 

imprisonment, debarment from participating in federal awards or contracts, and/or any other 

remedy available by law to the Federal Government. 

D.	 Specific requirements 

At a minimum, the following specific requirements will be fulfilled by the recipient during the 

specified timeframe. 

[Tasks should include performance indicators. How will the performance be measured? What tasks 

must be accomplished to get the desired results/outcomes?] 

Task 1. 

Task 2. 

Task 3. The recipient will produce a standalone executive summary document(s) for [specify 

document/deliverables]. This document(s) is intended for use by law enforcement executives and 

others interested in an abridged version of the resource(s) developed under this award, and it will 

summarize the recipients’ work and highlight the major findings and recommendations. This 

document(s) will be subject to COPS Office review and approval. [This task should be included in all 

CAs when it is applicable. For example, it may not be applicable to training awards or when the 

documents produced are already abridged/summarized]. 

Task 4. Work with the COPS Office and the Program Manager to address peer review, Program 

Manager, vetting, and other COPS Office staff comments regarding [specify products and 

deliverables]. 

46 
 

 

E. Performance timeline and deliverables 

The following is a performance timeline for all deliverables and their due dates (based upon an award 

date of XX/XX/XXXX) which are considered to be significant in the performance of this cooperative 

agreement. One electronic copy of deliverable items will be delivered and in accordance with the 

following schedule: 

Deliverables Date 

[List Project Deliverables]
 

All deliverable items will be furnished to the following:
 

[Insert Program Manager]
 

US Department of Justice
 

COPS Office
 

[Division]
 

145 N Street NE, 11th Floor
 

Washington, DC 20530
 

[insert contact information]
 

F. Financial status reports 

The recipient must provide a quarterly report of actual expenditures related to project activity on a 

cumulative basis. Specifically, the recipient is required to submit quarterly Federal Financial Reports 

on the Standard Form 425 (SF-425) within 30 days after the end of each quarter (January 1–March 31 

/ April 1–June 30 / July 1–September 30 / October 1–December 31). A final SF-425 is due within 90 

days after the end of the award period. Recipients must submit the quarterly SF-425 online. Visit the 

COPS Office Agency Portal Login page at https://portal.cops.usdoj.gov. 

G. Programmatic progress reports 

The recipient will provide periodic progress reports detailing project activity. Specifically, the 

recipient will submit progress reports through the COPS Office online progress reporting system in 

the frequency requested. These progress reports should be received by the COPS Office within 30 

days of the end of the reporting period. The recipient will also submit a final progress report to the 

COPS Office within 90 days of the end of the award period. 

IV. Period of performance 

The period of performance of this cooperative agreement is XXX months from the cooperative agreement 

award start date (award period XX/XX/20XX to XX/XX/20XX). 

47 
 

 

V. Financial administration 

A. Funding 

The total amount of federal funding to be provided under this cooperative agreement is stated on the 

award document, award congratulatory letter, and official Financial Clearance Memorandum (FCM). 

B. Travel 

All travel plans related to the cooperative agreement and to the development of the deliverables will be 

submitted to the Program Manager for review by the COPS Office. 

Travel costs for transportation, lodging and subsistence, and related items are allowable under the PASS 

with prior approval from the COPS Office. Payment for allowable travel costs will be in accordance with 2 

C.F.R. § 200.474. 

C. Consultant rates 

Unless otherwise approved by the COPS Office, approved consultant rates will be based on the salary a 

consultant receives from his or her primary employer, as applicable, up to $650 per day. For consultant or 

contractor rates which exceed $650 per day, the COPS Office requires written justification if the 

consultants or contractors are hired through a noncompetitive bidding process. Authorization requires 

submitting a detailed written justification of the consultant rate to the Program Manager. Specific and 

detailed written justification for each additional consultant must be submitted to, and approved by the 

COPS Office prior to obligation or expenditure of such funds. 

D. Project budget 

The approved project budget is incorporated herein and made a part of this cooperative agreement. For 

federal awards in excess of $150,000, any modification request involving the reallocation of funding 

between budget categories that exceed or are expected to exceed 10 percent (10%) of the total approved 

budget requires prior written approval by the COPS Office. See 2 C.F.R. § 200.308(e). Regardless of the 

federal award amount or budget modification percentage, any reallocation of funding is limited to 

approved budget categories. In addition, any budget modification that changes the scope of the project 

requires prior written approval by the COPS Office. See 2 C.F.R. § 200.308(c)(1)(i). 

Please be advised that if the budget modification request includes adding a new subaward to a State or 

local government entity or identifying a new State or local government entity subrecipient, the recipient 

and subrecipient must each complete and submit the applicable Certification of Compliance with 8 U.S.C. 

§ 1373 form. Access to subrecipient funding will be contingent upon submission of all required 

Certifications. 

In requesting a modification, the recipient will set forth the reasons and the basis for the proposed 

change and any other information deemed helpful for review by the COPS Office. Modifications are 

evaluated on a case-by-case basis. The COPS Office will not approve any modification request that results 

in an increase of federal funds. 

E. Payment 

All costs claimed for reimbursement and payment, including the final payment, must be submitted via the 

Grant Payment Request System (GPRS). “For more information regarding GPRS, please visit the following 

website to view the GPRS User Guide: http://www.ojp.usdoj.gov/about/offices/ocfogprs.htm. 

48 
 

F. No-cost extensions of time 

The recipient must provide a reasonable justification for delays in implementing this cooperative 

agreement to be granted a no-cost extension. A request for an extension of the award period to receive 

additional time to implement the funded program is at the discretion of the COPS Office. Such extensions 

do not provide additional funding. 

G. Employment 

The recipient acknowledges that nothing in this cooperative agreement creates an employment 

relationship with the COPS Office or with the Federal Government or to require provision of any benefits 

incident to employment. 

VI. Points of contact 

A. COPS Office Program Manager 

[Insert Program Manager]
 

US Department of Justice
 

COPS Office
 

[Division]
 

145 N Street, NE, 11th Floor
 

Washington, DC 20530
 

[insert contact information]
 

B. Recipient project officer 

[Insert contact information, including phone number] 

VII. General provisions 

The recipient of record must follow all requirements imposed by the US Department of Justice as an award 

term, condition or administrative requirement of the award, including but not limited to: the COPS Office 

Preparing for Active Shooter Situations (PASS) Program Award Owner’s Manual; the COPS Office Assurances 

and Certifications; the 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); the current 

edition of the COPS Office Grant Monitoring Standards and Guidelines; the COPS Office Editorial and Graphics 

Style Manual; and all other applicable program requirements, laws, orders, regulations, or circulars. 

Pursuant to Executive Order 13513, “Federal Leadership on Reducing Text Messaging While Driving,” the 

COPS Office encourages recipients of US Department of Justice funds to adopt and enforce policies that ban 

text messaging while driving, and to establish workplace safety policies to decrease accidents caused by 

distracted drivers. 

VIII. Modifications 

The designated COPS Office Program Manager and recipient project officer (under section VI.A. and VI.B.) for 

their respective organizations have the authority to propose and approve any modifications to this 

cooperative agreement. Modifications to this cooperative agreement may be proposed at any time during 

the period of performance by either party, and will become effective upon written approval by both parties. 

49 
IX. Incorporation by reference; effective date 

By signing the award document, the responsible parties designated below have entered into this cooperative
 

agreement, which is incorporated by reference into the award document. This cooperative agreement is
 

effective as of the date that the last responsible party signs the award document.
 

XXXXX XXXXXXXXX, Director
 

Office of Community Oriented Policing Services
 

[Insert Law Enforcement Executive/Program Official Name]
 

[Insert Agency Name]
 

[Insert Government Executive/Financial Official Name]
 

[Insert Agency Name]
 

Updated July 2017 

50 
 

 

III. Procurement Process 

In general, 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 award, recipients must follow their own 

policies and procedures on procurement as long as those requirements conform to the federal procurement 

requirements set forth in 2 C.F.R. §§ 200.317 – 200.326. 

As described in the award condition titled “Sole Source Justification”, recipients are required to submit a sole 

source justification (SSJ) request to the COPS Office for noncompetitive procurements in excess of $150,000 prior 

to purchasing equipment, technology, or services; obligating funding for a contract; or entering into a contract 

with award funds. If submitting a sole source justification request to the COPS Office, please use the format 

described in the Sole Source Justification fact sheet in the appendices of this manual. 

If you have any questions regarding the federal requirements that guide procurement procedures, please contact 

your COPS Office Program Manager. 

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. 

51 
 

 

IV. Accessing Award 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 award 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 payment system available for accessing federal award funds—the Grant Payment Request 

System (GPRS). GPRS is a web-based system that enables recipients to use a secure internet connection to request 

funds. Approved payment requests will automatically be scheduled for payment by the United States Department 

of the Treasury through electronic funds transfer (EFT). The Automated Clearing House (ACH) is the primary system 

that agencies use for EFT. An award recipient will be able to review previous payment requests made since July 

2009. For more information regarding GPRS, please visit the following website to view the GPRS User Guide: 

www.ojp.usdoj.gov/about/offices/ocfogprs.htm. 

Setting up your account 

How do we set up a new GPRS account? 

If you are a new recipient to the COPS Office, your agency should determine which authorized employee(s) will be 

responsible for requesting federal funds for your COPS Office awards through the GPRS system. The individual(s) 

selected must click on the following link and register with the GPRS system to become a drawdown specialist for 

your agency: https://grants.ojp.usdoj.gov/gprs/welcome. 

Once you have been 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 and/or government executive or other financial points of contact to validate the information that was 

provided during the registration process. All individuals that need access to GPRS must register separately and 

create their own unique GPRS username account, as these accounts are not meant to be shared. 

How do we add an award to an existing GPRS account? 

If you are currently registered for an active COPS Office award username in GPRS and would like to add a recently 

funded COPS Office award number to your existing COPS Office award 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 awards) 

• First/last name 

• Vendor number (as listed on your award document) 

• Award number(s) to be added 

52 
How do we fill out the payment enrollment forms? 

 

If you are a new award recipient 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 www.cops.usdoj.gov/pdf/ach_form_new.pdf. 

Prior to accessing your award 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 

Your agency must complete the “Payee/Company Information” section following the directions on the back of the 

form and also provide the award 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 award recipient, 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 new award 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 and ask to speak with your state 

assigned Financial Analyst. 

When should Federal Financial Reports be filed? 

Current regulations state that once you return a signed award document, your agency is required to submit a 

Federal Financial Report (FFR) using Standard Form 425 (SF-425) at the end of every calendar quarter regardless of 

award activity. This report should reflect actual expenditures and unliquidated obligations incurred by your agency 

on a cumulative basis. You will not be able to make drawdowns from your GPRS account if the SF-425 report for 

the most recent reporting quarter is not on file with the COPS Office by the deadline date. Recipients are 

encouraged to submit their SF-425 reports via the internet at https://portal.cops.usdoj.gov. 

For more information on how to complete and where to submit your quarterly SF-425, see the section in this 

manual titled “Reports.” 

Filing the Federal Financial Report (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 awards. 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. 

53 
 

 

 

There should be no excess federal award 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 recipient 

1. is unwilling or unable to attain project goals; 

2. maintains excess cash on hand; 

3. does not adhere to the terms and conditions of the award; 

4. 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, your reimbursement 

requests should cover a specific time frame and include only costs that were approved in the Financial Clearance 

Memorandum (FCM). As a general guideline, most agencies request reimbursement on a monthly or quarterly 

basis. Also, please note that a date range for a reimbursement request can only be used once. 

Can we earn interest on our award funds? 

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. 

For nonfederal entities other than states, payment methods must minimize the time between your drawdown of 

federal funds and your payment of award costs to avoid earning excess interest on your award funds. You must 

account for interest earned on advances of federal funds as follows: 

•	 The Office of Management and Budget (OMB) uniform guidance at 2 C.F.R. § 200.305(b)(9) states that
 

interest earned on federal advance payments deposited in interest-bearing accounts up to $500 per year
 

may be retained by the nonfederal entity for administrative expenses.
 

•	 Any interest earned on federal advance payments deposited in interest-bearing accounts that is in excess of 

$500 per year must be remitted annually to the Department of Health and Human Services Payment 

Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) 

network or a Fedwire Funds Service payment. For detailed information on remittance, please see appendices 

for a full text of the electronic medium remittance options. 

•	 If you do not have access to an electronic medium option, then please make a check payable to “The 

Department of Health and Human Services” and mail the 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 Finance Business Unit when any interest 

that is earned is remitted to the Department of Health and Human Services, Payment Management System. 

Matching funds 

Under the COPS Office PASS Program, no local match is required. The COPS Office is funding 100 percent of the 

allowable items approved in your FCM. Any agency desiring to contribute additional funds to this project is 

encouraged to do so and report these funds on SF-425 as a recipient share of expenditures. 

54 
 

 

 

V. Financial Record Maintenance 

Under the COPS Office PASS Program, your agency is required to establish and maintain accounting systems and 

financial records to accurately account for 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 required by 2.C.F.R. § 200.62 (Internal control over compliance requirements for federal awards), your 

accounting system should be designed to provide reasonable assurance regarding the achievement of the 

following objectives for federal awards: 

•	 Transactions are properly recorded and accounted for in order to prepare reliable financial statements and 

federal reports and to maintain accountability over assets. 

•	 Transactions are executed in compliance with all applicable federal statutes, regulations, and the award
 

terms and conditions.
 

•	 Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition. 

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 PASS award. Your accounting records should contain information 

showing expenditures under the award and must be supported by items such as payroll records, time and 

attendance records, canceled checks, purchase orders, or similar documents. 

Your agency must adequately safeguard award 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 records be kept? 

All financial records and supporting documents associated with your PASS award (including payroll, time and 

attendance records, canceled checks, and purchase orders) must be retained for a period of three years from the 

date of submission of the final expenditure report as stated in 2 C.F.R §C.F.R. § 200.333 (Retention requirements 

for records). 

Your agency should maintain records so that you can identify them by award 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. 

55 
What if we have more than one award? 

 

If your agency has more than one COPS Office award or an award 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 an award 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 US 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. 

56 
 

 

 

 

 

 

 

VI. Federal Audit Requirements 

In addition to oversight by the COPS Office, your award may be subject to an audit by independent examiners. The 

two primary types of audit are Single Audit Act (SAA) audits and US Department of Justice, Office of the Inspector 

General (OIG) audits. 

Single Audit Act (SAA) requirements 

What are the regulations governing SAA requirements? 

The Single Audit Act (SAA) of 1984 established uniform guidelines for state and local governments receiving federal 

financial assistance. The 1984 Act was amended in July 1996, was revised on June 27, 2003 and again on June 26, 

2007, and is effective for fiscal years after December 31, 2003, to reflect revised audit criteria and reporting 

requirements. The Office of Management and Budget (OMB) issued final guidance for 2 C.F.R. Part 200—Uniform 

Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) on 

December 26, 2013. This guidance applies to all federal awards or funding increments awarded on or after 

December 26, 2014, and provides additional guidelines regarding the implementation of SAA requirements. 2 

C.F.R. Part 200, Subpart F – Audit Requirements, available at www.ecfr.gov/cgi-bin/textidx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl, establishes the requirements for organizational audits 

that apply to COPS Office award recipients. Recipients must arrange for the required organization-wide (not 

award-by-award) audit in accordance with the requirements of Subpart F. 

Who must have an SAA audit? 

A recipient that expends $750,000 or more during the recipient's fiscal year in federal awards must have a single 

audit conducted in accordance with 2 C.F.R. § 200.514 (Scope of audit) except when it elects to have a programspecific audit conducted in accordance with 2 C.F.R. § 200.501(c). An auditee may be a recipient, a subrecipient, or 

a vendor. 

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 recipient’s financial statements, internal controls, major and nonmajor award 

programs, and compliance with government laws and regulations. Single Audits may also address specific 

compliance issues with respect to COPS Office award 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. See 2 C.F.R. § 200.505. 

These sanctions under 2 C.F.R. § 200.338 could include the following: 

•	 Temporarily withholding 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.
 

•	 Disallowing (that is, denying 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 suspending or terminating the federal award. 

57 
 

 

•	 Initiating suspension or debarment proceedings as authorized under 2 C.F.R. part 180 and federal awarding 

agency regulations (or in the case of a pass-through entity, recommending such a proceeding be initiated by a 

federal awarding agency). 

•	 Withholding further federal awards for the project or program. 

•	 Taking other remedies that may be legally available. 

Your SAA reports should not be sent to the COPS Office. 

If the US Department of Justice is your cognizant federal agency (see the Glossary of Terms in the appendices), 

they should be sent to the Federal Audit Clearinghouse at: 

Federal Audit Clearinghouse 

Bureau of Census 

1201 East 10th Street 

Jeffersonville, IN 47132 

The US Department of Justice, Office of Justice Programs (OJP) serves as the liaison between recipients and 

auditors in the conduct of resolving and closing SAA audits. Questions and comments regarding SAA audits may be 

directed to the COPS Office Response Center at 800-421-6770. 

Office of Inspector General (OIG) recipient audits 

What is the role of the OIG for award audits? 

The OIG is a separate component of the US Department of Justice and is independent of the COPS Office. The 

primary objective of OIG recipient audits is to assess compliance with award terms and conditions. OIG audits are 

designed to prevent fraud, waste, and abuse of federal funds. The OIG audit process promotes efficiency and 

effectiveness in the administration and implementation of awards by evaluating compliance with the terms and 

conditions of awards. 

How are COPS Office awards selected for an OIG audit? 

The OIG randomly selects awards to be audited or may conduct a COPS Office recipient audit in response to a 

referral that the OIG believes warrants further evaluation. The OIG also surveys DOJ award-making agencies on an 

annual basis to solicit input on suggested audit areas for the upcoming fiscal year. In most instances, however, the 

OIG generally selects awards to be audited based on a number of factors, including the geographical distribution of 

awards funded, award amount, population served, award status (active and expired), and type of award (hiring 

and nonhiring). As such, the fact that a recipient has been selected for an OIG audit is not necessarily indicative of 

a suspected concern or problem area. 

58 
What are the steps in an OIG audit? 

 

 

 

 

 

The COPS Office Grant Monitoring Division’s Audit Liaison Section serves as the liaison between recipients and the 

OIG’s Audit Division, which conducts the audit. The OIG steps in the audit process will determine the interactions 

between the OIG, the recipient, and the COPS Office Grant Monitoring Division’s Audit Liaison Section: 

•	 Call for award data. The OIG requests award documentation from the COPS Office. 

•	 Entrance conference. The OIG schedules to meet with the recipient to gather documentation and conduct 

audit. 

•	 Draft audit report. The OIG reviews documentation and presents initial recommendations (findings) to the 

recipient and copies the COPS Office. The COPS Office interacts with the recipient to coordinate any 

repayments and/or policy or procedure documents to be submitted to the OIG before release of the Final 

Audit Report. 

•	 Final audit report. The OIG has completed its direct interaction with the recipient. The COPS Office directs 

the recipient to formulate a Corrective Action Plan to address recommendations (findings). As each 

recommendation is successfully addressed by the recipient, the COPS Office requests closure on the 

recommendation. 

•	 Closing the audit. When all recommendations have been closed, the COPS Office requests closure on the 

audit from the OIG and notifies the recipient that the audit is closed.
 

If you have any questions regarding an OIG audit, please contact the COPS Office Grant Monitoring Division’s Audit 

Liaison Section via the COPS Office Response Center at 800-421-6770. Questions and comments regarding the 

administration of your COPS Office PASS award, not specifically related to an audit, should be referred to your 

COPS Office Program Manager. 

Typical Audit Recommendations (“Findings”) 

The OIG has typically reported the following audit recommendation pertaining to awards as a result of lack of 

proper documentation, poor business practices, or inadequate accounting and record keeping systems: 

•	 Unallowable costs. Recipient incurred costs that were not approved in the original budget or a budget 

modification, were in excess of the approved budget, or were charged to the award after the expiration date 

and an award extension was not obtained. 

•	 Unsupported costs. Specific award expenditures and reimbursements could not be supported by adequate 

documentation (including but not limited to receipts or purchase orders), that may have been allowable 

under the program, but for which no prior written approval was obtained from the COPS Office , or award 

expenditures were in excess of actual approved award costs. 

•	 Lack of complete/timely programmatic and financial reporting. Recipient failed to submit required 

programmatic and financial reports in a timely manner and/or had inadequate record keeping systems.
 

•	 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; and other identified savings. 

•	 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, award 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. 

59 
•	 Policy and procedure. Weaknesses are identified in a recipient’s accounting practices, fiscal stewardship, 

accuracy of data used in the development of the award applications, and/or inventory controls that led to the 

recommendation cited in the audit. The recipient is required to develop or revise policies and/or procedures 

consistent with their existing practices and submit to the COPS Office to forward to the OIG to close the 

recommendation. 

After the final OIG audit report has been issued, the COPS Office Grant Monitoring Division’s Audit Liaison Section 

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. 

60 
 

 

 

 

VII. Reports Requirement 

As a PASS award recipient, your agency will be required to submit quarterly Federal Financial Reports as well as 

quarterly Programmatic Progress Reports. Awarded agencies should be prepared to track and report PASS award 

funding separately from other funding sources (including other COPS Office and federal awards) 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 PASS funding and ensure that its use is consistent with the award terms and 

conditions. Good stewardship in this area includes written accounting practices, and use of an accounting system 

that tracks all award drawdowns and expenditures, and the ability to track when PASS award-funded positions are 

filled or approved purchases are made. 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 award funding or other remedial 

actions. 

Federal Financial Reports 

Your agency is required to submit a quarterly Federal Financial Report (FFR) 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 

award 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 award end date; however, you will have a 90-day 

grace period after the award end date during which you can draw down funds for eligible expenditures incurred 

before the award end date. 

How do we file Federal Financial Reports? 

All COPS Office award recipients are required to submit quarterly Federal Financial Reports using the SF-425. 

Recipients are strongly encouraged to submit the quarterly SF-425 online. Visit the COPS Office Agency Portal 

website at https://portal.cops.usdoj.gov 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 reports 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 awards must be submitted every quarter and no later than 30 days after the last day of 

each reporting quarter, as detailed in table 1: 

Table 1. Due dates of SF-425 by quarter 

Reporting quarter 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 

61 
 

 

 

For your initial 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 award to the end of that period. 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. 

Example: 

If your award start date is 02-01-17 and the current date is 04-15-17, then your first SF-425 will be due no later 

than 04-30-17 and will cover the period 02-01-17 (award start date) through 03-31-17 (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. 

Award recipients who do not submit an SF-425 report by the due date each quarter 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 current. Subsequent outreach through e-mail, fax, or hard copy reminders may be sent 

to the recipient if the SF-425 is delinquent. 

For general information concerning online filing of SF-425 reports, go to www.cops.usdoj.gov or contact the COPS 

Office Response Center by phone at 800-421-6770 or by e-mail at AskCopsRC@usdoj.gov. 

For assistance in completing the SF-425, 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 award 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 award through financial reports, on-site visits, officebased award reviews, meetings, telephone contacts, reports, audits, reviews of award 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” tab of the COPS Office website at 

https://portal.cops.usdoj.gov. 

How do we file a Program Progress Report? 

Please access the COPS Office website at https://portal.cops.usdoj.gov and click on the “Account Access” tab 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. 

62 
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 at https://portal.cops.usdoj.gov and enter your e-mail address, and click 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 award end date. 

When are Program Progress Reports due? 

Program Progress Reports for COPS Office awards must be submitted every quarter and no later than 30 days after 

the last day of each reporting quarter, as detailed in table 2: 

Table 2. Due dates of Program Progress Reports by quarter 

Reporting quarter Program Progress Report due date 

January 31–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? 

These reports will request information about the status of your award in terms of purchasing equipment, hiring 

personnel, delivering services, and progress in meeting milestones identified in the cooperative agreement, as well 

as general information about your agency. 

What if we make a mistake or need to modify the report after it is submitted? 

Recipients 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. 

63 
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 award 

may be reported to the US Department of Justice. Furthermore, the COPS Office welcomes the opportunity to 

provide assistance regarding the implementation of award provisions to help ensure that federal award 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 US Department of Justice, Office of the 

Inspector General (OIG) at www.oig.justice.gov/hotline, OIG.hotline@usdoj.gov, or 800-869-4499.
 

•	 If you suspect award violations (not criminal in nature) related to the award 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 award, please contact your COPS Office Program 

Manager via the COPS Office Response Center at 800-421-6770. 

64 
 

 

VIII. When the Award Period Has Ended 

At the end of your agency’s PASS award period, the COPS Office is responsible for the closeout of your award. 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 award. 

After the end of the award period, your agency will be asked to submit a Final Federal Financial Report (SF-425) 

and any applicable final programmatic progress reports. 

Final Federal Financial Report (SF-425) 

The final Federal Financial Report (SF-425) for your award is due to the COPS Office no later than 90 days after the 

end date of the award period. The final report should reflect the total amount of allowable federal expenditures 

that were incurred during the life of the award, as well as the amount of unobligated funds remaining, if any. The 

federal funds expended should reflect only the actual allowable costs incurred relative to the specific program 

requirements for that award. In addition, once you have completed your final drawdown, this report should 

reconcile with the total amount of federal funds drawn down by your agency. The final SF-425 should also include 

the required minimum total amount of local (recipient) cash match contributed, if applicable. 

When should all of the award monies be spent? 

Award funds reflecting allowable project costs must be obligated before the end of the award 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 award period to request reimbursement for eligible 

funds obligated. 

Please be advised that 2 C.F.R. § 200.343(a) requires recipients to submit final SF-425s and 2 C.F.R. § 200.343(b) 

requires recipients to draw down the final reimbursement for expended funds within 90 days after the expiration of 

the award. 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 unobligated and unspent award funds remaining in your account following 

the award period due to an overestimate of item costs during the application 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 award period. Any remaining unobligated or unspent funds should remain in your account, and will be 

deobligated during the closeout process. 

Final Program Progress (Closeout) Report 

After your award 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 award, 

and the information your agency provides in this report will be used to make a final assessment of your award 

progress. 

65 
Equipment disposition 

 

 

 

Each recipient must use any equipment funded through a COPS Office award for approved award-related purposes 

and must retain the equipment for the life of the award. After the conclusion of the award period, property 

records must be maintained by the recipient. 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. 

When the award has expired and original or replacement equipment obtained under the award 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. 

66 
 

IX. Conclusion 

We hope that this manual has assisted you and your agency with your award questions. We welcome and 

encourage any comments you have regarding the COPS Office PASS Program and the materials we have developed 

for its administration. If you have specific comments regarding this manual or have any questions about your 

award, please call your COPS Office Program Manager 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 US 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. 

67 
 

 

 

 

Appendices 

Appendix A. List of source documents 

A. Primary Sources
 

Public Safety Partnership and Community Policing Act of 1994, 42 U.S.C. § 3796dd et seq.
 

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 

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 Paperwork Burdens on the Public” 

5 C.F.R. Part 151, “Political Activity of State and Local Officers 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. Part83, “Government-Wide Requirements for Drug-Free Workplaces (Grants)” 

28 C.F.R. Part 69, “New Restrictions on Lobbying” 

31 C.F.R. Part 205, ”Rules and Procedures for Efficient Federal-State Funds Transfers” 

OMB Circular A-129, ”Policies for Federal Credit Programs and Non-Tax Receivables” 

48 C.F.R. Part 31 (Federal Acquisition Regulation), ”Contract Cost Principles and Procedures” 

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”
 

68 
 

 

Appendix B. Assurances and Certifications 

Assurances 

Several provisions of federal law and policy apply to all award programs. The Office of Community Oriented 

Policing Services (“COPS Office”) needs to secure your assurance that the applicant will comply with these 

provisions. If you would like further information about any of these assurances, please contact your state’s COPS 

Office Grant Program Specialist at 800-421-6770. 

By signing this form, the applicant assures that it will comply with all legal and administrative requirements that 

govern the applicant for acceptance and use of federal award funds. In particular, the applicant assures us of the 

following: 

1.	 It has been legally and officially authorized by the appropriate governing body (for example, mayor or city 

council) to apply for this award and that the persons signing the application and these assurances on its behalf 

are authorized to do so and to act on its behalf with respect to any issues that may arise during processing of 

this application. 

2.	 It will comply with the provisions of federal law, which limit certain political activities of employees whose 

principal employment is in connection with an activity financed in whole or in part with this award. These 

restrictions are set forth in 5 U.S.C. § 1501 et seq. 

3.	 It will comply with the minimum wage and maximum hours provisions of the Fair Labor Standards Act (29 

U.S.C. § 201 et seq.), if applicable. 

4.	 It will establish safeguards, if it has not done so already, to prohibit employees from using their positions for a 

purpose that is, or gives the appearance of being motivated by a desire for private gain for themselves or 

others, particularly those with whom they have family, business or other ties. In addition, it will disclose (in 

writing) to the COPS Office any potential conflict of interest arising during the course of performance of the 

award and also will require such written disclosures by any subrecipients. 

5.	 As required by 42 U.S.C. § 3796dd-6, it will give the U.S. Department of Justice or the Comptroller General 

access to and the right to examine records and documents related to the award. 

6.	 It will comply with all requirements imposed by the U.S. Department of Justice as a condition or administrative 

requirement of the award, including but not limited to: the requirements of 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); the applicable provisions of the Omnibus Crime Control and Safe Streets Act of 1968, as 

amended; 28 C.F.R. Part 38 (Partnerships With Faith-Based and Other Neighborhood Organizations); the 

applicable COPS Office application guide; the applicable COPS Office award owner’s manual; and with all other 

applicable program requirements, laws, orders, or regulations. 

7.	 As required by 42 U.S.C. § 3796dd-1(c) (11), it will, to the extent practicable and consistent with applicable 

law, seek, recruit and hire qualified members of racial and ethnic minority groups and qualified women in 

order to further effective law enforcement by increasing their ranks within the sworn positions in the agency. 

8.	 It will not (and will require any subrecipient, contractors, successors, transferees, and assignees not to), on the 

grounds of race, color, religion, national origin, sex, or disability 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. It will also not 

discriminate in the delivery of benefits or services based on age. These civil rights requirements are found in 

69 
 

 

 

 

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, as amended (42 

U.S.C. § 6101); Title IX of the Education Amendments of 1972, as amended (20 U.S.C. § 1681); and the 

corresponding U.S. Department of Justice regulations implementing those statutes at 28 C.F.R. Part 42 

(subparts C, D, E, G, and I). It will also comply with Executive Order 13279, as amended by Executive Order 

13559, and the implementing regulations at 28 C.F.R Part 38, Partnerships With Faith-Based and Other 

Neighborhood Organizations, which requires equal treatment of religious organizations in the funding process 

and prohibits religious discrimination against beneficiaries. 

A.	 In the event that any court or administrative agency makes a finding of discrimination on grounds of race, 

color, religion, national origin, or sex against the applicant after a due process hearing, it agrees to 

forward a copy of the finding to the Office for Civil Rights, Office of Justice Programs, 810 7th Street, NW, 

Washington, D.C. 20531. 

B.	 If your organization is a government agency or private business and has received a single award for 

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

excluding political appointees), then it has to prepare a Utilization Report and submit it to the Office for 

Civil Rights (OCR) within 120 days from the date of the award. Although the OCR has discretion to review 

all submitted Utilization Reports, it will review the Utilization Reports from recipients that receive an 

award of $500,000 or more. 

To begin developing a Utilization Report, please consult the OCR's website at 

https://www.ojp.usdoj.gov/about/ocr/eeop.htm and click EEOP Reporting Tool Login. Additional assistance can 

be found online at the bottom of the same webpage by clicking the EEO Reporting Tool Job Aid and Frequently 

Asked Questions. 

If your organization has less than fifty 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, however, your organization must certify that it is exempt by logging into the 

EEO Reporting Tool on the OCR website at https://www.ojp.usdoj.gov/about/ocr/eeop.htm, providing the 

contact and organizational profile information, and then submitting a Certificate of Exemption. 

If you have further questions regarding the EEOP requirements, you may contact an EEOP specialist at the OCR by 

telephone at 202-307-0690, by TTY at 202-307-2027, or by e-mail at EEOPforms@usdoj.gov. 

9.	 Pursuant to U.S. Department of Justice guidelines (June 18, 2002 Federal Register, Volume 67, Number 117, 

pages 41455-41472), under Title VI of the Civil Rights Act of 1964, it will ensure meaningful access to its 

programs and activities by persons with limited English proficiency. 

10. It will ensure that any facilities under its ownership, lease or supervision which shall be utilized in the 

accomplishment of the project are not listed on the Environmental Protection Agency’ (EPA) list of Violating 

Facilities and that it will notify us if advised by the EPA that a facility to be used in this grant is under 

consideration for such listing by the EPA. 

11. If the applicant’s state has established a review and comment procedure under Executive Order 12372 and 

has selected this program for review, it has made this application available for review by the state Single Point 

of Contact. 

12. It will submit all surveys, interview protocols, and other information collections to the COPS Office for 

submission to the Office of Management and Budget for clearance under the Paperwork Reduction Act of 

1995 if required. 

70 
 

 

 

13. It will comply with the Human Subjects Research Risk Protections requirements of 28 C.F.R. Part 46 if any part 

of the funded project contains non-exempt research or statistical activities which involve human subjects and 

also with 28 C.F.R. Part 22, requiring the safeguarding of individually identifiable information collected from 

research participants. 

14. Pursuant to Executive Order 13043, it will enforce on-the-job seat belt policies and programs for employees 

when operating agency-owned - or - rented or personally-owned vehicles. 

15. As required by 42 U.S.C. § 3796dd-3(a), it will not use COPS Office funds to supplant (replace) state, local, or 

Bureau of Indian Affairs funds that otherwise would be made available for the purposes of this award, as 

applicable. 

16. If the award contains a retention requirement, it will retain the increased officer staffing level or the increased 

officer redeployment level, as applicable, with state or local funds for a minimum of 12 months following 

expiration of the award period. 

17. It will not use any federal funding directly or indirectly to influence in any manner a Member of Congress, a 

jurisdiction, or an official of any government, to favor, adopt, or oppose, by vote or otherwise, any legislation, 

law ratification, policy or appropriation whether before or after the introduction of any bill, measure, or 

resolution proposing such legislation, law, ratification, policy or appropriation as set forth in the Anti- Lobby 

Act, 18 U.S.C. § 1913. 

18. In the event that a portion of award reimbursements are seized to pay off delinquent federal debts through 

the Treasury Offset Program or other debt collection process, it agrees to increase the nonfederal share (or, if 

the award does not contain a cost sharing requirement, contribute a nonfederal share) equal to the amount 

seized in order to fully implement the award project. 

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

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

I certify that the assurances provided are true and accurate to the best of my knowledge. 

Elections or other selections of new officials will not relieve the recipient of its obligations under this award. 

Signature of Law Enforcement Executive/Agency Executive Date 

(For your electronic signature, please type in your name) 

Signature of Government Executive/Financial Official Date 

(For your electronic signature, please type in your name) 

71 
Certifications 

Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; Federal Taxes 

and Assessments; Drug-Free Workplace Requirements; and Coordination with Affected 

Agencies. 

 

Although the U.S. Department of Justice has made every effort to simplify the application process, other provisions 

of federal law require us to seek your agency’s certification regarding certain matters. Applicants should carefully 

review the statutes and regulations cited below and the instructions for certification to understand the 

requirements and whether they apply to a particular applicant. Signing this form complies with the certification 

and notice requirements under 28 C.F.R. Part 69 “New Restrictions on Lobbying”; 2 C.F.R. Part 2867 

“Nonprocurement Debarment and Suspension”; 2 C.F.R. Part 200 “Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards”; the general provisions in the applicable Appropriations 

Act; 28 C.F.R. Part 83 “Government-Wide Requirements for Drug-Free Workplace (Grants)”; and the Public Safety 

Partnership and Community Policing Act of 1994. The certifications shall be treated as a material representation of 

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

award. 

1.	 Lobbying 

As required by 31 U.S.C. § 1352, implemented at 28 C.F.R. Part 69, for persons entering into a grant or 

cooperative agreement over $100,000, and 2 C.F.R. § 200.450 as adopted by the U.S. Department of Justice in 

2 C.F.R. § 2800.101, the applicant certifies to the following: 

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; or 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.	 If applicant is a nonprofit organization or an institution of higher education, it will comply with the 

additional lobbying restrictions set forth in 2 C.F.R. § 200.450(c) as adopted by the U.S. Department of 

Justice in 2 C.F.R. § 2800.101. 

D.	 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 subrecipients shall certify and disclose accordingly. 

72 
 

 

 

 

 

2.	 Debarment, Suspension and Other Responsibility Matters (Direct Recipient) 

Pursuant to Executive Order 12549, Debarment and Suspension, as implemented at 2 C.F.R. Part 2867, for 

prospective participants in primary covered transactions, as defined at 2 C.F.R. § 2867.20(a), and other 

requirements, 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 a felony criminal 

violation under any federal law, or been convicted 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) or private agreement or transaction; violation of federal or 

state antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or destruction 

of records, making false statements, tax evasion or receiving stolen property, making false claims, or 

obstruction of justice, or commission of any offense indicating a lack of business integrity or business 

honesty that seriously and directly affects your present responsibility; 

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 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. 

3.	 Mandatory Disclosure 

Pursuant to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards, 2 C.F.R. § 200.113 as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101, the applicant 

certifies that it: 

A.	 Has not violated any federal criminal law involving fraud, bribery, or gratuity that may potentially affect 

the federal award; 

B.	 Shall timely disclose in writing to the federal awarding agency or pass-through entity, as applicable, any 

violation of federal criminal law involving fraud, bribery, or gratuity that may potentially affect the federal 

award; and 

C.	 Shall require that the language of this certification be included in the award documents for all subawards 

(including subgrants and cooperative agreements) and shall require all subrecipients certify and disclose 

accordingly. 

4.	 Federal Taxes and Assessments 

A.	 If applicable, an applicant who receives an award in excess of $5,000,000 certifies that, to the best of its 

knowledge and belief, the applicant has filed all federal tax returns required during the three years 

preceding the certification, has not been convicted of a criminal offense under the Internal Revenue Code 

of 1986, and has not, more than 90 days prior to certification, been notified of any unpaid federal tax 

assessment for which the liability remains unsatisfied, unless the assessment is the subject of an 

installment agreement or offer in compromise that has been approved by the Internal Revenue Service 

and is not in default, or the assessment is the subject of a non-frivolous administrative or judicial 

proceeding. 

B.	 The applicant certifies that it does not have any unpaid federal tax liability that has been assessed, for 

which all judicial and administrative remedies have been exhausted or have lapsed, and that is not being 

paid in a timely manner pursuant to an agreement with the authority responsible for collecting the tax 

liability. 

73 
 

5.	 Drug-Free Workplace 

As required by the Drug-Free Workplace Act of 1988 (41 U.S.C. § 8103), implemented at 28 C.F.R. Part 83, for 

recipients other than individuals as defined at 28 C.F.R. § 83.660 – 

A.	 The applicant certifies that it will, or will continue to, provide a drug- free workplace by doing the 

following:
 

(i)	 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; 

(ii)	 Establishing an on-going drug-free awareness program to inform employees about – 

(a)	 the dangers of drug abuse in the workplace; 

(b)	 the grantee’s policy of maintaining a drug-free workplace; 

(c)	 any available drug counseling, rehabilitation and employee assistance programs; and 

(d)	 the penalties that may be imposed upon employees for drug-abuse violations occurring in the 

workplace; 

(iii) 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 (i); 

(iv) Notifying the employee in the statement required by paragraph (i) that, as a condition of 

employment under the grant, the employee will – 

(a)	 abide by the terms of the statement; and 

(b)	 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; 

(v)	 Notifying the agency in writing within 10 calendar days after receiving notice under subparagraph 

(iv)(b) from an employee or otherwise receiving actual notice of such conviction. Employers of 

convicted employees must provide notice, including position title, to: COPS Office, 145 N Street, NE, 

Washington, D.C. 20530. Notice shall include the identification number(s) of each affected grant; 

(vi) Taking one of the following actions within 30 calendar days of receiving notice under subparagraph 

(iv)(b) with respect to any employee who is so convicted – 

(a)	 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 

(b)	 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; 

(vii) Making a good faith effort to continue to maintain a drug-free workplace through implementation of 

paragraphs (i), (ii), (iii), (iv), (v), and (vi). 

B.	 The applicant further certifies that it will identify all known workplaces under each COPS Office award, 

keep the identification documents on file, and make them available for inspection upon request by the 

U.S. Department of Justice officials or their designated representatives. 

74 
 

 

6.	 Coordination 

As required by 42 U.S.C. § 3796dd-1(c)(5) of the Public Safety Partnership and Community Policing Act of 1994, 

applicants must certify that there has been appropriate coordination with all agencies that may be affected by 

the applicant’s grant proposal if approved. Affected agencies may include, among others, the Office of the 

United States Attorney, state or local prosecutors, or correctional agencies. The applicant certifies that there 

has been appropriate coordination with all affected agencies. 

 Where the applicant is unable to certify to any of the statements in this Certifications form, he or she shall attach 

an explanation to this application regarding the particular statement that cannot be certified. Please check the box 

if an explanation is attached to this application. Please note that the applicant is still required to sign the 

Certifications form to certify to all the other applicable statements. 

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

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

I certify that the assurances provided are true and accurate to the best of my knowledge. 

Elections or other selections of new officials will not relieve the recipient entity of its obligations under this award. 

Signature of Law Enforcement Executive/Agency Executive Date 

(For your electronic signature, please type in your name) 

Signature of Government Executive/Financial Official Date 

(For your electronic signature, please type in your name) 

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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 is composed of three key components: 

1. Community partnerships 

2. Organizational transformation 

3. Problem solving 

Community partnerships 

Community partnerships are collaborative partnerships between law enforcement agencies 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. 

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Institutions of Higher Education 

Institutions of higher education create communities of students, professors, and personnel that are important 

stakeholders. The institutions can also provide resources to law enforcement agencies by assisting with 

communication strategies, facilitation of community meetings, data analysis, and research. 

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. 

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. 

The community policing philosophy focuses on the way that 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 infuses 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, policing 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. 

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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 decision making. 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. 

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 that support 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 not only how 

outcomes are measured, but also at how feedback information is used. 

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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 decisionmaking 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 the community, thus establishing a strong relationships and mutual accountability. Patrol beat 

boundaries should be aligned to neighborhood boundaries to enhance officers’ understanding of communities 

within their patrol areas and to build trust within the community. Other community policing partners should 

become familiar with both the patrol officers and community policing officers assigned within each patrol beat to 

coordinate government and nongovernment community policing 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 by special units, although there may be a need for specialist units that are tasked 

with identifying and solving particularly complex problems or managing complex partnerships. 

Resources (time, finances, and people) 

Agencies have to devote the necessary human and financial resources and the investment of time to support 

community policing to ensure that problem-solving efforts are robust and that partnerships are sustained and 

effective. 

Personnel 

The principles of community policing need to be infused 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 views. 

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 

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community policing agency must also thoughtfully examine where it looks for 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 community 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, raise public awareness, and 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 within the 

organization, training in its fundamental principles will need to take place regularly. 

Information technology systems 

Community policing is highly information-intensive, and technology plays a central role in providing 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 patrol beat. In addition, 

technological enhancements can greatly assist with accessing information to provide vital resources, improving 

two-way communication with community members, and 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 within their organization. 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; e-mail 

alerts; internet social media discussion forums; and feedback on interactive applications (such as surveys and 

geographical information), thereby creating open, 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. 

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. 

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Quality and accuracy of data 

Information is only as good as its source; 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 

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 similar 

in one or more ways and that is 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. 

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. 

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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), 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. 

This information is adapted from Community Policing Defined, which can be found at https://ric-zaiinc.com/Publications/cops-p157-pub.pdf. 

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Appendix D. Training and Conference Fact Sheets 

If developing or delivering training under this cooperative agreement, the COPS Office Curriculum Standards, 

Review, and Approval Process Guides: Online and In-Person and COPS Office and Instructor Quality Assurance 

Guide must be followed. This applies to the development and/or delivery of online and in-person courses. Courses 

already in existence that are part of this cooperative agreement must also comply with the two aforementioned 

guides. A copy of these guides, along with supplemental training resources, will be supplied electronically to you by 

the Program Manager and are also located on the COPS Office website for download. All training development 

processes and deliverables must be reviewed and approved by the COPS Office prior to public release following 

the process indicated in the guides. 

• Training Fact Sheet 

• ADDIE Fact Sheet 

• In Person Curriculum Standard Guide 

• Instructor Quality Assurance Guide 

• Non-TOT Instructor Guide Template 

• Non-TOT Participant Guide Template 

• Non-TOT PowerPoint Background 

• TOT Instructor Guide Template 

• TOT Participant Guide Template 

• TOT PowerPoint Background 

• Section 508 of the Rehabilitation Act of 1973 

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Appendix E. Conference and Event Guidance 

Conference and Event Approval, Planning, and Reporting FAQ 

Prior Approval 

1. Approximately how long should it take to adequately complete the Conference & Events Submission form? 

The amount of time required to adequately complete the Conference & Events Submission Form will vary 

depending on the complexity of the proposed event. A small event (in terms of number of attendees, total 

cost, etc.) may require only an hour or two to complete the form because the event is basic/routine and data 

are not required in all of the available categories. On the other hand, a large event (in terms of number of 

attendees, multiple sessions occurring at the same time, etc.) may require several hours or days depending on 

the amount of required data (categories) and level of justification needed to support the event. Regardless of 

the size of any event, the supporting justification should be sufficient to support the agency’s mission for 

conducting the event. 

2. Which types of events do not require prior approval? 

Currently there are six types of events that do not require prior approval: 

i. Conferences held by grant recipients. (Note: Conferences held by cooperative agreement recipients do 

require prior approval.) 

ii. Law enforcement operational activities, including staging, surveillance, investigation, intelligence, and 

undercover activities. 

iii. Routine operational meetings (e.g., staff meetings or all-hands meetings) if held in a federal facility, if held 

by cooperative agreement recipients in a non-federal facility that does not charge for its use, and if there 

are neither costs to the DOJ for logistical conference planning nor government-provided food or 

beverages. In all three of these instances, the answer to all the questions on the Prior Approval Not 

Required Checklist must be “No.” Site visits are considered routine operational meetings regardless of 

location so long as there are no costs to the DOJ for meeting rooms, logistical conference planning, or 

food and beverages. 

iv. Testing activities where the primary purpose of the event is to evaluate an applicant’s qualifications to 

perform certain duties necessary to his or her job. This includes firearms and weaponry proficiency testing 

and certifications. A majority of the event must be devoted to administering and taking the test. Testing 

activities that are incidental to a training course or conference or are given upon its completion do require 

prior approval. 

v. Video conferences and webinars where there are neither costs to the DOJ for logistical conference 

planning nor government-provided food or beverages. 

vi. Technical assistance visits where travel was made by an individual or a small group of project staff 

members to provide training or technical assistance to a particular entity; in this instance, the answer to 

all the questions on the Prior Approval Not Required Checklist must be “No.” 

3. Where should time staff spent working on the conference that is not related to planning be captured? 

Time spent working on a conference by staff or contractors can be classified as either logistical planning time 

or programmatic planning time. Programmatic planning includes time spent on activities such as developing 

the conference content and agenda, identifying and recruiting subject matter experts, and preparing written 

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materials. Logistical planning includes time spent on tasks such as selecting a venue, ordering and setting up 

audio-video equipment, securing hotel rooms, processing registrations, providing onsite support during the 

event, and undertaking other nonprogrammatic functions. 

4.	 If a cooperative agreement recipient or contractor is able to obtain a no-cost site for the event, are we still 

required to look into other facilities and provide justification for not selecting the other facilities? 

Yes. Cooperative agreement recipients and contractors should compare three or more facilities in a location. 

Facilities being compared should have provided a cost estimate and be able to accommodate the event as 

detailed in the requirements. A desired hotel may offer an incentive of no overall facility cost (e.g., for meeting 

rooms or audio-visual equipment) but may not be economical in other cost comparison items such as the 

availability of lodging at per diem rates, travel distance for attendees, etc. Also, recipients and contractors 

should maintain written documentation justifying their decision to select the chosen location in the event of a 

future audit. 

5.	 Is there a timeframe after the COPS Office accepts a conference request that a cooperative agreement 

recipient or contractor can expect notification of approval? 

Each event request (meeting, conference, webinar, etc.) is unique in reference to how it will accomplish the 

COPS Office’s mission. The key to any conference request moving through the review process depends on 

whether the package is complete. A complete package contains a detailed cost analysis and sufficient 

justification to support all categories within the package. 

Example: An event is submitted for approval and consists of the following categories: printing and distribution, 

meals and incidental expenses (M&IE), lodging, transportation, and trainer or facilitator costs. The package 

contains a detailed cost analysis of each cost category (e.g., one trainer at $450 per day x 2 days = $900) and 

adequate justification explaining the purpose of the event and the role of the trainer. This package can move 

through the review process in a few days and allow ample time for travelers to make reservations, if the 

package was submitted within the required timeframe. However, if the trainer or facilitator’s costs in the 

submitted package exceed the COPS Office’s threshold and if supporting justification was not included, a delay 

may occur while this justification is being retrieved. 

To avoid delays in the approval process, all recipients and contractors should adhere to the timeframe 

requirements for the dollar amount of their proposed event. 

6.	 Once an event is approved, how do we handle any increases or decreases in the amount of attendees 

originally proposed on the cost analysis spreadsheet submitted to the DOJ for approval? 

After receiving notification of approval from the COPS Office, all subsequent changes prior to the start day of 

the event should be sent to the COPS Office Conference Costs email address, as appropriate. Example: If the 

COPS Office approved on 9/1/2017 an event scheduled for 12/15/2017, the cooperative agreement recipient 

or contractor should notify the COPS Office of any changes in attendees as soon as possible (preferably 30 

days or more in advance). This scenario holds true for changes to the start and end date, location, and any 

other cost-related category. 

7.	 Does the $25 per person per day limit for meeting rooms and audio-visual costs also include service fees and 

taxes? 

Yes. The cost allowed for conference space and audio-visual equipment and services (fees and taxes) is limited 

to $25 per day per attendee and is not to exceed a cumulative total cost of $20,000. Total costs are defined as 

direct and indirect costs. 

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8.	 What if there are multiple meetings occurring within the larger event offered to all the attendees? Is the 

$25 per day per attendee limit applicable to each meeting? Example: A general session meeting contains all 

attendees and later breakout sessions are offered to the groups. Can each breakout session have its own 

$25 per person per day limit? 

No. Despite the multiple meetings offered within the larger event, the COPS Office considers and approves 

this type of situation to be a single event. 

9.	 Can we accept complimentary food and beverage? 

Yes. Complimentary food and beverages may be accepted if offered to everyone. Example: Hotel W offers a 

complimentary continental breakfast to all its overnight customers regardless of any status they may have 

with the hotel chain. This type of complimentary offer is considered a business strategy of the hotel to 

promote an increase in overnight stays. You are not required to reduce your M&IE by the value of the food 

and beverage it offered to all customers as noted in this example. 

10. Are the thresholds ($8,750 for logistical planner, $35,000 for programmatic planner, and $20,000 for 

conference space and audio-visual equipment and services) a cumulative cost for the entire event or a per 

day cost? 

The cost allowed for conference space and audio-visual equipment and services (fees and taxes) is limited to 

$25 per day per attendee and is not to exceed a cumulative total cost of $20,000. The cost allowed for a 

logistical planner is the lesser of $50 per attendee or $8,750 per event. The cost allowed for a programmatic 

planner is the lesser of $200 per attendee or $35,000 per event. 

11. To whom should I submit event requests? 

For all COPS Office events, the form should be sent to the COPS Office Conference Costs email address. Please 

do not send questions or other correspondence to this email address. This mailbox should be used only for the 

submission of conference forms and supporting documentation (e.g., hotel contracts). 

12. How far in advance do I have to submit an event for review and approval? 

Requests for conferences costing $100,000 or less, and not exceeding any cost thresholds (conference space 

and audio-visual equipment and services, logistical conference planner, and programmatic conference 

planner), must be submitted to the COPS Office 90 calendar days in advance of the earliest of the following: 

•	 Start date of the conference; 

•	 Deadline for signing conference-related contracts; or 

•	 Obligation of funds for conference costs (except for minimal costs required to assemble and submit the 

approval request).
 

Requests for conferences costing more than $100,000, or exceeding any one cost threshold (conference space 

and audio-visual equipment and services, logistical conference planner, or programmatic conference planner), 

must be submitted to the COPS Office 120 calendar days in advance of the earliest of the following: 

•	 Start date of the conference; 

•	 Deadline for signing conference-related contracts; or 

•	 Obligation of funds for conference costs (except for minimal costs required to assemble and submit the 

approval request).
 

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If approval requests are submitted less than the required number of days in advance (as noted above), the 

COPS Office, in its sole discretion, may consider the late requests but cannot ensure the requests will receive a 

decision in time to avoid having to cancel the conference (particularly if any issues arise with specific items of 

cost in the request). Cancellation costs associated with conference requests that are submitted for late prior 

approval may be determined to be unallowable costs by the COPS Office. 

13. What are the most common mistakes made on the forms so that I can avoid them in the future and increase 

the likelihood of a quick review and approval decision for my event? 

Below are the most common mistakes found: 

•	 Inaccurate calculation of daily per diem. Daily per diem rates for locations across the nation can be found on 

the GSA website. Ensure the daily rate used in the calculations corresponds to the specific location and dates 

of the meeting. In addition, remember that travel days are reimbursed at a slightly lower rate than meeting 

days. The lower rates must be used for days of travel both before and after the event. The following chart 

includes these lower rates: 

Full per diem rate Corresponding travel day rate (75%) 

$46.00 $34.50 

$51.00 $38.25 

$56.00 $42.00 

$61.00 $45.75 

$66.00 $49.50 

$71.00 $53.25 

EXCEPTION: If your organization has its own formal, written travel policy, your event submissions can 

reflect that policy instead of the rates in the chart above. In these instances, state that you have a formal, 

written travel policy, and clearly explain the rates in the policy and how the corresponding numbers in 

your submission were derived. 

•	 Insufficient explanation and justification of transportation costs. Remember to break out and briefly describe 

and justify the transportation costs that are included. Example: If participants are flying to your event and the 

tickets are being paid for with DOJ funding, you should include the anticipated number of people flying 

multiplied by the estimated cost per ticket. If cars will be rented, you should include a brief justification for 

why rental cars are being used instead of another form of ground transportation, such as taxis or shuttles. 

•	 Insufficient explanation and justification of audio-visual costs. All audio-visual costs should be broken out and 

briefly described. The quantity of equipment to be rented (number of microphones, projectors, etc.) should 

be included, along with relevant costs and a brief justification for why the proposed equipment is required to 

conduct a successful meeting. A discussion of how the audio-visual services provider was selected should be 

included (for example, did you obtain three quotes?). 

•	 Insufficient explanation and justification of printing costs. Proposed printing costs for participant materials 

should also be itemized and briefly described. Specifically, it is important to articulate why printed materials 

are needed instead of making materials available electronically (at low or no cost) to attendees before or 

after the event. 

•	 Insufficient explanation and justification of shipping costs. Provide an itemization of these costs, along with a 

brief description of why the equipment and other materials being shipped are essential to hosting a 

successful conference. 

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•	 Insufficient explanation and justification of consultant costs. The maximum daily rate for subject matter 

experts who are being reimbursed for their time is noted here. Describe all consultant costs in detail, and 

include a brief yet compelling justification for the proposed costs. Daily rates for subject matter experts 

above the maximum daily rate require prior approval by the COPS Office and DOJ. In cases where higher rates 

are included in the event submission, written documentation of prior approval is required and should be 

attached. 

14. Should I continue to exclude all food and beverage costs in my event submissions? 

Yes. The inclusion of food and beverage costs will delay the review process, and these costs are not likely to be 

approved. The only exception is when the location of the conference does not allow attendees to obtain food 

or beverages on their own or when this restriction would greatly disrupt the conference schedule. If you 

believe your event qualifies for such a rare exception, contact your Program Manager to discuss it before 

completing and submitting your form. If meals are included in your event submission, remember that 

attendees must subtract the meal costs from the M&IE reimbursement for the days on which the meals will 

occur. 

15. Can you summarize what I can do to prevent follow-up questions about my submitted events that delay the 

review and approval process? 

As a general rule, explain how you derived every cost that you include in the conference submission form. For 

lines that do not provide space for you to add descriptive narrative, include your explanations and specific cost 

breakdowns in a separate tab or in a separate document that is submitted with the form. In addition, include 

the cooperative agreement or contract number on the form. 

16. What events qualify for the expedited review process? 

There is no expedited review process. Every effort is made to review all events as quickly as possible. 

Most delays result from a need for additional information. Event requests are prioritized for review by 

balancing the following three criteria: 

•	 The start date of the event; 

•	 The date the event submission was received by COPS Office; and 

•	 The overall cost and complexity of the event. For example, conferences requiring approval by the assistant 

attorney general’s administration and the deputy attorney general (over $100,000–$250,000) typically take 

longer to process, as they must go through COPS Office and DOJ reviews, result in more questions, and are 

more likely to have issues related to cost thresholds. 

Reporting 

17. Where can I find the most updated version of the conference reporting form to use for my submissions? 

The most updated version of the conference reporting form can be found under the Training Resources for 

award recipients section on the COPS Office Training page at https://cops.usdoj.gov/training. 

18. If I have a question about conference reporting, to whom should I send it? 

Send your questions to your designated Program Manager. They are great resources and will be happy to 

assist you. 

19.	 Are we expected to have our staff track their time hour for hour for time spent on the event for planning, 

etc., or are reasonable estimates adequate for cost reporting purposes? 

Post-event reports must contain actual costs, not estimates. These costs should include logistical and 

programmatic planner staff time spent on these activities and any contracted planner costs. 

88 
20. With conference cost reports now being due 30 days after the event, how should we handle costs for 

invoices that have not been received yet? Many invoices (such as for hotels) are not received within 30 days 

after the event. Should estimates be included on the cost report? 

All conference costs for events held by cooperative agreement recipients or contractors costing more than 

$20,000, or where more than 50% of attendees are DOJ employees, must be reported within 45 calendar days 

after the last day of the event. 

On the DOJ Conference & Events Submission Form under “A. General Conference Information,” is item 19, 

“Reporting Period,” the period in which the actual cost of the event is being reported, or should this be based 

on the end date of the event? 

This reporting requirement is based on the end date of the event. All conference costs for events held by 

cooperative agreement recipients or contractors costing over $20,000, or where more than 50% of attendees 

are DOJ employees, must be reported within 45 calendar days after the last day of the event. Example: A COPS 

Office–approved conference was conducted from 3/16/2018 through 3/20/2018. A completed Conference & 

Events Submission Form must be submitted, showing the prior approval amounts compared to the actual 

costs and explaining all variances greater than 10% or $1,000. Reports should be emailed to the COPS Office 

Conference Cost email address at COPS.Conferencecosts@cops.usdoj.gov. 

89 
 


 

Department of Justice-Sponsored Conference

 Request and Report
 

 

 


 


 


 


 

A RED cell indicates that your entry exceeds the DOJ meal threshold AND cannot be submitted unless within the meal threshold.
 

A YELLOW cell indicates that your entry exceeds the DOJ threshold, and additional justification must be provided. 

A GREY box indicates that no entry is required.
 

Attachment 1 

JMD Tracking Number 

Date Received 

Component Internal Tracking Number 

(Optional) : 

CA/Contract Number 

CA/Contract Recipient 

CA/Contract PoC Phone 

Request Cost per 

Attendee #DIV/0! Actual Cost per Attendee 

COPS Average 

Cost per 

Attendee 

DOJ Average 

Cost per 

Attendee 

1. Name of Requestor 

2. Component Name (Drop Down) 

3. Is this submission for a conference request 

or report? (Drop Down) 

4. JMD Tracking # (Report Only) 

5. If this is a Re-Submission of a previously 

disapproved conference, indicate original JMD 

Tracking Number. 

6. Official Title of the Conference 

(No Abbreviations) 

7. Is this a blanket request? (Y/N) 

(Drop Down) If "YES" Skip A9-13,A16 and 

Sections C,D,& E1, If "NO" Skip A8 

If Yes, please enter the length of the 

conferene below (days). 

8. If this is a Blanket Request, indicate for 

each: 1) Number of occurrences this fiscal 

year, 2) Locations, and 3) Start and End Dates 

9. Conference Start Date (MM/DD/YYYY) 

10. Conference End Date (MM/DD/YYYY) 

COMPONENT USE ONLY: 

CA/Contract PoC 

Name 

JMD FINANCE STAFF USE ONLY: 

COPS - Office of Community Oriented Policing Services 

Conference Request 

No 

CA/Contract PoC 

Email 

#DIV/0! 

A. GENERAL CONFERENCE INFORMATION: 

DOJ-Sponsored Conference Request and Report Form_Version 2 SUBMISSION FORM
 

Release Date: 4/1/13 Return To: JMD Finance Staff, TSG at Conference.and.Non-Federal.Center@usdoj.gov 1 of 13
 
 

 

 Blank 

 

 

#DIV/0!

 

11. Location: Country (Drop Down) 

12. Location: State / Territory / Possession 

(Drop Down) 

13. Location: City 

14. Justification that conference is essential to 

accomplishing core mission 

15. Funding Appropriation Symbol 

16. Facility Name (Specific) 

17. Facility Type (Federal/Non-Federal) 

(Drop Down) 

18. Cooperative Agreement (Y/N) 

(Drop Down) 

19. Reporting Period (Required when 

reporting actuals) (Drop Down) 

Conference REQUEST Information Conference REPORT Information 

20. Number of DOJ Federal Attendees 

21. Number of Other Federal Attendees 

22. Number of Non-Federal Attendees 

23. Total Number of Attendees 

(Auto-populates) 

0 0 

24. Total number of attendees whose travel 

expenses are paid for by DOJ (required) 

25. Total Cost 

(Auto-populates from entries below) $0 $0 

26. Predominately Internal Event held at a NonFederal Facility (Y/N) (Auto-populates based on 

Facility Type and Number of Attendees) 

PLEASE PROVIDE NUMBER OF ATTENDEES 

Competitive Contracting: 

27. Were Federal procurement regulations 

followed as appropriate? (Drop Down) 

28. Were all market research documents used 

in conference planning decisions retained? 

(Drop Down) 

B. TOTAL CONFERENCE COSTS: 

Conference REQUEST Information Conference REPORT Information 

ESTIMATED 

DIRECT COST 

ESTIMATED 

INDIRECT COST 

(Funding from 

Cooperative 

Agreement ) 

ESTIMATED 

TOTAL COST 

(Auto-populates) 

% OF TOTAL 

COST 

(Auto-populates)

 ACTUAL 

DIRECT COST

 ACTUAL 

INDIRECT COST

 (Funding from 

Cooperative Agreement 

)

 ACTUAL 

TOTAL COST 

(Auto-populates) 

VARIANCE 

(Between Actual 

and Estimate) 

(Auto-populates) 

VARIANCE JUSTIFICATION 

(Provide justification if variance is 

>$1,000 and >10% as indicated by a light 

yellow cell OR exceeds cost thresholds, as 

indicated by a bright yellow cell) 

When REPORTING quarterly conferences, only complete the request information if JMD approved your request and you have a JMD tracking number 

Attachment 1 

DOJ-Sponsored Conference Request and Report Form_Version 2 SUBMISSION FORM 

Release Date: 4/1/13 Return To: JMD Finance Staff, TSG at Conference.and.Non-Federal.Center@usdoj.gov 2 of 13 
 

 

NO

NO

YES

1. Conference Meeting Space (including 

rooms for break-out sessions) 

2. Audio-visual Equipment and Services 

3. Printing and Distribution 

4. Meals Provided by DOJ 

a. Breakfast 

$ ­

-

-

-

0.00% 

0.00% 

0.00% 

0.00% 

$ ­

-

-

-

$ ­

-

-

-

b. Lunch - 0.00% - -

c. Dinner - 0.00% - -

5. Refreshments Provided by DOJ 

6. M&IE for Attendees 

-

-

0.00% 

0.00% 

-

-

-

-

7. Lodging 

8. Common Carrier Transportation 

9. Local Transportation 

10. Conference Planner - Logistical 

11. Conference Planner - Programmatic 

12. Conference 

Trainer/Instructor/Presenter/Facilitator 

13. Other Costs: ( Itemize Below)

-

-

-

-

-

-

-

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

0.00% 

-

-

-

-

-

-

-

-

-

-

-

-

-

-

- 0.00% - -

- 0.00% - -

- 0.00% - -

- 0.00% ­ -

14. Total Conference Cost: 

(Auto-populates) $ ­ $ ­ $ ­ 0.00% $ ­ $ ­ $ ­ $ ­

C. MEALS & REFRESHMENTS THRESHOLD CALCULATOR 

CONFERENCE LOCATION: PER DIEM RATE 

1. Continental United States MI&E GSA Per-Diem Rates 

2. Hawaii, Alaska, US Territories & 

Possessions MI&E 

DOD Per-Diem Rates 

3. Foreign Country MI&E State Department Per-Diem Rates 

D. MEALS 

1. Breakfast 

NUMBER OF 

TIMES MEAL IS 

SERVED 

NUMBER OF 

ATTENDEES 

0 

PER PERSON 

THRESHOLD 

($) 

 SELECT PER 

DIEM RATE 

TOTAL JMD 

THRESHOLD 

($) 

 N/A 

2. Lunch 0 SELECT PER 

DIEM RATE N/A 

3. Dinner 0 SELECT PER 

DIEM RATE N/A 

E. OTHER THRESHOLDS CALCULATOR 

DOJ-Sponsored Conference Request and Report Form_Version 2 

Release Date: 4/1/13 Return To: JMD Finance Staff, TSG at Conference.and.Non-Federal.Center@usdoj.gov 

Attachment 1 

SUBMISSION FORM 

3 of 13 
 

 

 

 

 

0.00 0.00

 

 

 

COST CATEGORY: NUMBER OF 

ATTENDEES 

PER PERSON 

THRESHOLD ($) 

TOTAL JMD 

THRESHOLD 

($) 

1. Conference Space & Audio-visual 

Equipment and Services 0 $ 25 $ ­

2. Logistical Conference Planner 0 $ 50 $ ­

3. Programmatic Conference Planner 0 $ 200 $ ­

F. JUSTIFICATION IF SUBMITTING CONFERENCE REQUEST FORM WITH ESTIMATED COSTS OVER THRESHOLD (Complete if cells turn YELLOW): 

1. Conference Space & Audio-visual 

Equipment and Services 

2. Refreshments 

3. Logistical Conference Planner 

4. Programmatic Conference Planner 

G. JUSTIFICATION REQUIRED FOR CONFERENCES WITH MEALS (Complete if cells turn YELLOW ): 

Government Provided Meals 

H. JUSTIFICATION FOR NON-FEDERAL FACILITY (Complete if cells turn YELLOW) : 

Justification for Using a Non-Federal Facility 

(Drop Down) 

I. FACILITIES CONSIDERED 

NAME 

FACILITY 

TYPE 

(Drop Down) 

TOTAL EST. 

CONFERENCE 

COST 

SELECTED 

(Y/N) REASON FOR USE OR NON-USE 

0 $ ­ YES 

Attachment 1 

DOJ-Sponsored Conference Request and Report Form_Version 2 SUBMISSION FORM 

Release Date: 4/1/13 Return To: JMD Finance Staff, TSG at Conference.and.Non-Federal.Center@usdoj.gov 4 of 13 
 

 

 

 

 

J. ESTIMATED ATTENDEE INFORMATION 

ATTENDEE DUTY STATION ATTENDEE ORGANIZATION NUMBER OF 

ATTENDEES 

TOTAL - (Breakout must match entry on line A23) 0 

Attachment 1 

DOJ-Sponsored Conference Request and Report Form_Version 2 SUBMISSION FORM 

Release Date: 4/1/13 Return To: JMD Finance Staff, TSG at Conference.and.Non-Federal.Center@usdoj.gov 5 of 13 
 

 

 

 

 

 

 

 


 


 


 


 


 


 

Please answer the following questions below:
 

Meeting/Event name:
 

Meeting/Event date:
 

Please select yes or no from the drop down: Yes/No 

Date: 

COPS Office Mission: To advance the practice of community policing by the nation’s state, local, territorial, and tribal law 

enforcement agencies through information and grant resources. 

DOJ Mission: To enforce the law and defend the interests of the United States according to the law; to ensure public safety 

against threats foreign and domestic; to provide federal leadership in preventing and controlling crime; to seek just 

punishment for those guilty of unlawful behavior; and to ensure fair and impartial administration of justice for all Americans. 

1. Is the cost of the event greater than $20,000? 

2. Are there meeting room costs? 

3. Are audio visual costs greater than $25 per attendee 

or more than $1000 in total? 

4. Are there any food and beverage costs? 

5. Did the request for the meeting come from multiple 

jurisdictions or agencies? 

6. Do the participants represent multiple agencies that 

are not co-located or joined by an agreement (e.g., task 

force with MOU)? 

7. Are there trinkets being purchased? 

8. Is there a formal published agenda? 

9. Are formal discussion or presentation panels 

planned? 

10. Are there logistical planning costs beyond 

incidental internal administrative costs necessary to 

arrange travel and lodging for a small number of 

individuals? 

If any question is answered "yes", the event must be submitted for prior 

approval. If all answers are "no", the event does not require additional prior 

approval. The CCRPOC must sign the certification below and this 

documentation along with the original cost estimate must be maintained in 

the award files in accordance with the record documentation guidelines 

outlined in the Financial Guide. 

CCRPOC Certification (only to be used if all answers are "no"): 

The CCRPOC for this award certifies that the answers to all the 

questions above are "no", thereby not requiring prior approval. 

The CCRPOC further certifies that actual costs charged to the 

cooperative agreement will not exceed $20,000, including any 

applicable indirect costs. 

Typed CCRPOC Name: 

Please answer the following questions below to continue with your prior approval: 

One sentence describing the event:
 

Purpose for the event:
 

How the purpose ties to the COPS Office/DOJ Mission:
 
Brief discussion of how and why the venue (City, State and facility) was selected. 

Answer: 

Venue selection justification documents or venue selection matrix provided. 

Intended audience (select all that apply "X") 

Community based organizations/NPOs 

Community Members/Volunteers/General Public 

Corrections / Detention Personnel 

Court Personnel 

Crime Scene Investigators 

Defense Attorneys 

Educators 

Faith-based Organizations 

Financial Managers 

Forensic Scientists 

Grant Managers 

Health services (medical, mental health, substance abuse treatment) 

Industry 

Judges 

Law Enforcement 

Probation /Community Corrections/Parole 

Prosecutors 

Tribal 

Victim Advocates 

Youth 

Other – describe below 

Topic (select all that apply "X") 

Corrections 

Courts 

Crime Prevention 

Crime Scene Investigation 

Drugs 

Forensic Science 

Grants Management (financial, administrative, programmatic) 

Justice Systems 

Juvenile Justice 

Laboratory Operations 

Law Enforcement 

Standards 

Technical Working Groups / Advisory Groups 

Victims of Crime 

Other – describe below 
 

 

 

 

 

 

 

 

 

 

 

 

 

ESTIMATED EXPENSE JUSTIFICATION/COST CALCULATION SECTION 

Printing and Distribution 

Justification Item Unit Cost Total Direct Costs Total Grantee Cost Total Cost 

$0 

$0 

$0 

$0 

$0 

$0 

Justification Item Unit Cost Number of Attendees Number of Days Total Direct Costs Total Grantee Cost Total Cost 

Breakfast $0 

Lunch $0 

Dinner $0 

Refreshment $0 

Justification Desciption Per Diem Rate Number of Travelers Number of Days Total Direct Costs Total Grantee Cost Total Cost 

$0 

$0 

$0 

$0 

$0 

DOJ Attendee M&IE $0 $0.00 

Justification Desciption Lodging Rate Number of Travelers Number of Nights Total Direct Costs Total Grantee Cost Total Cost 

$0 

$0 

$0 

$0 

$0 

DOJ Attendee Lodging $0 $0.00 

Justification Desciption Rate Total Direct Costs Total Grantee Cost Total Cost 

$0 

$0 

$0 

$0 

$0 

DOJ Attendee Transportation $0 $0.00 

Justification Item Cost/Rate Total Direct Costs 

Total Grantee Cost 

Total Cost 

Taxi $0.00 

Parking Fees $0.00 

Shuttle Service $0.00 

POV (mileage) $0.00 

$0.00 

DOJ Attendee Local Transportation $0 $0.00 

Lodging 

$0 

$0 

Quantity 

$0 $0 

Gov't Provided Meals 

$0 $0 

M & IE 

$0 

$0 

Transportation 

Number of Travelers 

$0 

$0 

Local Transportation 

Number of trips, miles, vehicles, persons 

$0 

$0 

Logistical Planner 

Conference/Meeting Space 

Justification Item Cost per Day Number of Days Total Direct Costs Total Grantee Cost Total Cost 

$0 $0 

$0 

$0 

$0 

$0 

$0 

$0 

A/V Equipment & Services 

Justification Item Cost per Day Number of Days Total Direct Costs Total Grantee Cost Total Cost 

$0 

$0 $0 

$0 

$0 

$0 

$0 

$0 

Justification Item Cost/Rate Total Direct Costs Total Grantee Cost Total Cost 

$0.00 

$0.00 

hours/days 
 

 

 

 

 

 

 

 

 

 

 

 

 

Include staff time spent on logistical and 

$0.00 $0 $0 

$0.00 

$0.00 

Programmatic Planner 

Justification Item Cost/Rate hours/days Total Direct Costs Total Grantee Cost Total Cost 

Justification 

$0.00 

Total Grantee Cost 

$0 

Total Cost 

$0 

$0.00 

$0.00 

$0.00 

Item Cost/Rate 

Conference Facilitator 

hours/days 

$0.00 

Total Direct Costs 

$0.00 

$0 $0 

$0.00 

$0.00 

$0.00 

$0.00 

 Other Expense 

Justification Item Cost/Rate Quantity Total Direct Costs Total Grantee Cost Total Cost 

$0.00 

$0 $0 

$0.00 

$0.00 

$0.00 

$0.00 

 Indirect Cost 

Justification Item Rate Base Total Direct Costs Total Grantee Cost Total Cost 

$0.00 

$0 $0 

$0.00 

$0.00 

$0.00 

$0.00 

Total Direct Costs $0 

Total Indirect Costs $0 

Total Grantee Costs $0 

Total DOJ Costs $0.00 

Total Conference Costs $0.00 figure should match submission form total 

Total Number of Event Days 

Average Meeting Space and AV expenses /person 

/day 

Attached Documents 

Please mark "X" in the box and provide a copy of the document 

Hotel contract/proposal (if applicable please mark "X" in the box and provide a copy of the unsigned contract) 

Meeting Agenda (required) 

Indirect Cost Rate Agreement 

Copy Provided 

Copy Provided 

Copy Provided 

Attendees 

List of attendees and where they are travelling from. Please add more spaces as necessary. (If attendee information is not known at this time please enter TBD in the chart below. If 

attendees are not yet known please write in a justification in the box below) If attendees are not 

*Please note if other DOJ component attendance (FBI, DEA, known ­

USMS, USAO, etc.) is expected explanation: 

Organization: Name: Duty Station: Traveling From: 
Hotel Selection Justification and Cost Breakdown 

Bid Hotel Total Cost Availability Food 

Guest Room 

Rate per 

Night 

Meeting 

Space Rental 

Fee + Service 

Fee 

Microphones, 

Mixer, and 

Recording 

Screen and 

Projector 

Technician and 

Service Fee 

1 

2 

3 

Audio/Visual Cost Justification 

If A/V estimate costs are above the threshold, use the space below to explain and/or justify the cost. 
Itemized Travel Costs Paid or Reimbursed with Cooperative Agreement Funds Only complete this form when submitting Conference Report Actuals. 

Purpose/Role Total 

Duty Station (Participant, Lodging Common Carrier Local Transportation 

(Departure and Return Facilitator, Logistical Total (Include Transportation Baggage (Includes taxi, parking, 

Name Location) Coordinator, etc.) # of days M&IE tax) (Air, Rail, or Bus) Fees* rental car, POV) Total 

$ 

$ 

$ 

$ 

$ 

$ 

-

-

-

-

-

-

TOTAL $ - $ - $ - $ - $ -

* Although there is a separate column for "Baggage Fees" that expense should be added to the "Common Carrier Transportation" in the actuals report. 
 

Complete this form only when submitting Actual Costs and if there are particular itemized expense in "Part B Total Conference Costs" of the Reporting Form exceeds 

the threshhold or the allowable variance. Provide justification/explanation and calcualtions in the below form. 

Expense Category Cost Reporting Form Variance Justification/ Explanation 

Conference Meeting Space $0 

A/V Equipment and Services $0 

Conference Meeting Space and 

A/V Equipment and Services $0 Total will auto-populate 

Printing and Distribution $0 

Gov't Provided Meals* $0 

Breakfast $0 

Lunch $0 

Dinner $0 

Refreshments* $0 

M&IE $0 

Lodging $0 

Transportation $0 

Local Transportation $0 

Logistical Conference Planner $0 

Programmatic Conference Planner $0 

Conference 

Trainer/Instructor/Presenter/Facilitator $0 Conference trainer/instructor/presentor/facilitator costs should be broken out in the "Conference Request Questions" sheet. 

Other Costs $0 

Indirect Costs $0 

$0 

$0 

$0 

$0 

$0 

$0 

Total: $0 Total will auto-populate 
Appendix F. Financial/Budget Fact Sheets 

The following pages contain financial and budget fact sheets pertinent to your agency’s CPD award. 

102
 
U.S. Department of Justice 

Office of Community Oriented Policing Services 

 Fact Sheet www.cops.usdoj.gov

Sole	 	 Source Justification
 
 

What	is	“sole	source”	procurement?

Sole source or procurement by noncompetitive proposals is 

procurement through solicitation of a proposal from only 

one source. Sole source procurements must adhere to the 

standards set forth in 2 C.F.R. § 200.320(f) 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. 

When	is	sole	source	approval	required		

by	the	COPS	Office?	

A 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 award funds. For the purchase of equipment, 

technology, or services under a COPS Office 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 standards set forth in 2 C.F.R. 

§ 200.318. A sole source justification request should be 

submitted if a recipient determines that the award of a 

contract through a competitive process is infeasible. 

Recipients may conduct noncompetitive proposals (or “sole 

source” procurement) by procurement through solicitation 

from only one source when 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. 

•	 The COPS Office authorizes noncompetitive proposals 

in response to a written request from the recipient. 

•	 Competition is determined inadequate after solicitation of a number of sources. 

Sole source procurement should be used only when 

competitive solicitation procedures like sealed bids or 

competitive proposals are not applicable to the requirements 

or are impracticable. 

What	documentation	must	be	submitted	to	

the	COPS	Office	for	sole	source	approval?

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. 

An award 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 award funds. 

The sole source request must be signed and submitted on 

the recipient's department letterhead and must include 

the agency’s ORI number and the award number for which 

approval is being sought. 
2 

Sole Source Justification 

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 four circumstances identified 

below applies to the procurement transaction (include 

supporting information as identified below under the 

applicable section(s)): 

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 (market survey 

results, independent agency research, patented or 

proprietary system, etc.) 

— Explanation of need for contractor’s expertise 

linked to the current project (knowledge of project 

management, responsiveness, experience 

of contractor personnel, prior work on earlier 

phases of project, etc.) 

— 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.	 The COPS Office authorizes noncompetitive proposals 

in response to a written request from the recipient. 

4.	 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 (c). In addition, program funds should not be 

awarded to any party that is debarred or suspended from 

participation in federal assistance programs. 

If you have any questions regarding the federal requirements 

that guide procurement procedures, please contact your Grant 

Program Specialist or Program Manager at 800-421-6770. 

Contact the COPS Office

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. 

April 2017 
U.S. Department of Justice

Office of Community Oriented Policing Services

 Fact Sheet www.cops.usdoj.gov

Consultant/Contractor Rate 

Information for FY 2017 Awards 

"Compensation for individual consultant 

services procured under a COPS Office award 

must be reasonable, allocable, and consistent 

with that paid for similar services in the 

marketplace. The recipient must provide 

justification for any consultant rate in excess of 

$650 per day and receive COPS Office approval 

of that rate before drawing award funds." 

Recipient Guidelines on Consultant Rate 

Approval Requests 

Compensation for individual consultant services procured under a 

COPS Office award must be reasonable and allocable in accordance 

with 2 C.F.R. Part 200, Subpart E—Cost Principles1 and consistent 

with that paid for similar services in the marketplace. 

Unless otherwise approved by the COPS Office, approved consultant 

rates will be based on the salary a consultant receives from his or her 

primary employer, as applicable, up to $650 per day. If individuals 

receive fringe benefits from their primary employer, such fringe benefit 

costs should not be included in the calculation of consultant rates. For 

consultant or contractor rates which exceed $650 per day, the COPS 

Office requires written justification if the consultants or contractors are 

hired through a noncompetitive bidding process. The recipient must 

provide justification for any consultant rate in excess of $650 per day 

and receive COPS Office approval of that rate before drawing down 

award funds. Any organization that does not provide sufficient written 

justification will be limited to $650 per day for each consultant 

or contractor. Please note that this does not mean that the rate can or 

should be $650 for all consultants. 

Note: Consultant and contractor daily rates do not include travel 

or subsistence costs, but may include preparation, evaluation, and 

travel time. 

1 2 C.F.R. Part 200, Subpart E—Cost Principles applies to awards made after December 26, 2014. 

For awards made prior to December 26, 2014, the following Cost Principles apply: 2 C.F.R. Part 225 (OMB Circular A-87), 

Cost Principles for State, Local, and Indian Tribal Governments); 2 C.F.R. Part 220 (OMB Circular A-21), Cost Principles for 

Educational Institutions; 2 C.F.R. Part 230 (OMB Circular A-122), Cost Principles for Non-Profit Organizations; and 48 C.F.R. 

Part 31 .000, et seq. (FAR 31.2), Cost Principles for Contracts with Commercial Organizations. 

Guidance for requesting a consultant rate based 

on employment 

a.	 Consultants Associated with Institutions of Higher Education 

(including state-run educational institutions). If representing 

the academic institution, the maximum rate of compensation 
that will be allowed is the consultant’s academic salary 

projected for 12 months, divided by 260. These 

individuals normally receive fringe benefits which 

include sick leave for a full 12-month period, even 

though they may only work 9 months per year in their 

academic positions. This does not apply to individuals 

providing consultant work outside of their academic 

commitments. In such cases, the rate of compensation 

will be based on reasonable cost principles and requires 

documentation supporting the requested rate. 

b.	 Consultants Employed by State and Local Government. 

Compensation for these consultants will be allowed only 

when the unit of government will not provide these 

services without cost. If a state or local government 

employee is providing services under a federal award and 

is representing his or her agency without pay from the 

respective unit of government, the rate of compensation 

is not to exceed the daily salary rate for the employee 

paid by the unit of government. If the state or local 

government employee is providing services under a federal 

award and is not representing his or her agency, the rate 

of compensation is based on the necessary and reasonable 

cost principles. Please note that under the nonsupplanting 

requirement of the COPS Office statute, COPS Office 

grant funds may not be used to supplant (replace) local 

funding which otherwise would have been spent on 

consultants employed by state and/or local government. 

The statute bars federal funding of existing consultants and 

of newly hired consultants that a community is committed 

to fund in the absence of a COPS Office grant. 

c.	 Consultants Employed by Commercial and NotFor-Profit Organizations. These organizations are 

normally subject to competitive bidding procedures. 

Thus, if consultants have been selected through 

competitive bidding, they are not subject to the per day 

maximum compensation threshold. Otherwise, the rate 

of compensation will be approved based on the salary a 

consultant recieves from his or her primary employer, as 

applicable, up to $650 a day. 

To request approval of a consultant rate in excess of $650 per 

day, please submit the signed request on recipient department 

letterhead and include the agency ORI number and the 

award number for which the approval is being sought. 

Please include the following: 

 Description of the services to be provided by the 

consultant(s) or contractor(s), including the following: 

»	 The number of days and hours to be worked by each 

consultant/contractor. 

»	 The daily rate of each consultant/contractor that exceeds 

$650/day (indicate fringe benefits, if applicable). 

 A resume or curriculum vitae (CV) for each consultant 

or contracted individual whose rate exceeds $650 per day. 

 Documented prior instances when a similar rate has been 

charged by or paid to the consultant/contractor. 

 If the consultant is not self-employed and has a primary 

employer, documentation showing that the requested 

daily rate is proportionate to the consultant’s regular 

salary (e.g. pay stubs, letter from employer, etc.). 

 Optional: You may submit other important information 

about the consultant(s) or contractor(s) at this time, such 

as letters of reference; lists of any relevant publications, 

papers, or honors; advanced experience as a practitioner 

or academic in the subject area; advanced training 

relating to the focus of your project; and/or any unique 

circumstances which you feel should be considered as 

the COPS Office reviews your proposed consultant/ 

contractor rates. 

To request approval of a consultant/contractor rate in excess 

of $650 per day, please return this information to your grant 

program specialist or program manager as soon as possible to 

expedite the consultant/contractor rate review process. 

Contact the COPS Office 

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. 

Updated April 2017 
U.S. Department of Justice

Office of Community Oriented Policing Services

 Fact Sheet www.cops.usdoj.gov

Program Income 

What is program income? 

Program income means gross income earned by the recipient or subrecipient that is directly generated by an awardsupported activity or earned as a result of a federal award 

during the award period.1 Program income includes income 

from fees for services performed, the use or rental of real or 

personal property acquired under federal awards, the sale of 

commodities or items fabricated under a federal award, license 

fees and royalties on patents and copyrights, and principal 

and interest on loans made with federal award funds. 

Examples of program income that has been generated from 

some COPS Office–funded activities include fees collected 

for conference registration, exhibit booths, and website 

advertisements. Interest earned on advances of federal funds 

is not program income. Except as otherwise provided for 

in federal statutes, regulations, or the award terms and 

conditions, program income does not include rebates, 

credits, discounts, and interest earned on any of them. 

The recipient may not earn or keep any profit resulting 

from a federal award unless expressly authorized, in writing, 

by the COPS Office.2 

1. Program income is defined by 2 C.F.R. § 200.80 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 for awards made after December 26, 2014. Prior awards would follow 28 C.F.R. §§ 

66.25 and 70.24. 

2. See 28 C.F.R. § 200.400(g). 

How do I know if my COPS Office award 

generates program income? 

Although recipients are encouraged to earn program income 

to defray program costs where appropriate, most COPS 

Office awards are not conducive to generating program 

income. Contact your COPS Office program manager or 

grant program specialist to determine if revenue generated 

from your COPS Office award constitutes program income. 

They will help you assess whether or not the income is 

generated as a result of the award-supported activity. 

Program income means gross income earned by the 

recipient or subrecipient that is directly generated by 

an award-supported activity or earned as a result of a 

federal award during the award period. 

How can program income be used? 

Program income must be used in accordance with the 

standards set forth in 2 C.F.R. § 200.307. Program income 

generated from an award can be 

1.	 deducted from total allowable project costs to determine 

net allowable costs to reduce the federal award; 

2.	 added to the federal award to increase funds committed 

to the project; 

3.	 used to meet the cost sharing or matching requirement 

of the federal award. 

Unless otherwise specified in the award terms and conditions 

or approved by the COPS Office, program income will be 

used to defray program costs and reduce the federal share 

of the project. Program income not anticipated at the time 

of the award must be used to reduce the federal award 

and recipient contributions rather than to increase funds 

committed to the project. For example, if you were awarded 

$100,000 in COPS Office funding with no local match 

requirement to support a conference and earned $5,000 in 

program income from registration fees generated from that 

conference, an excess of $5,000 would remain in award 

funds at the completion of the project. The $5,000 would 

be returned to the Federal Government, thereby reducing 

the federal share of the project. 
 

 

2 Program Income 

In some cases, with prior approval, recipients may be able to 

work with their COPS Office program manager to identify 

additional project-related allowable costs that could be 

supported with program income. 

Earned program income can be spent only on allowable 

project costs incurred during the award period. Program 

income cannot be commingled with other awards and cannot 

be used for purposes outside of the scope of the award that 

generated the income. 

There are a variety of circumstances that can affect how 

program income is treated. If you anticipate generating 

program income, please contact your COPS Office program 

manager, grant program specialist, or designated financial 

analyst for guidance. 

How should recipients report 

program income? 

You are required to report gross program income earned 

and expended on the Federal Financial Report (SF-425)3 

submitted each quarter. How you complete the report 

depends on when you earn and spend the program income 

and the status of your award. Using the example above 

where you earned $5,000 from registration fees, you would 

enter the total amount of program income earned ($5,000) 

on 10.l and the total amount of program income expended 

on line 10.m.4 

Program income earned and expended must be reported on 

a cumulative basis. You must manually enter these 

cumulative amounts each quarter, as the SF-425 form does 

not automatically calculate these amounts. For example, if 

$5,000 in program income was earned in the 1st quarter 

and $10,000 was earned in the 2nd quarter, you would 

add those amounts together and enter $15,000 as earned 

on line 10.l of the 2nd quarter’s SF-425. Similarly, if you 

spent $5,000 in program income in the 1st quarter and an 

additional $10,000 of program income in the 2nd quarter, 

you would enter $15,000 as expended on line 10.m of the 

2nd quarter’s SF-425. 

In the event of an audit or other award compliance 

review, your agency should maintain detailed records that 

identify the specific project activity source (e.g., conference 

registration fees) and the amount of all program income 

generated. Line 12 (“Remarks”) on the SF-425 can be useful 

to provide narrative explanations supporting the financial 

information entered. 

3. To access this form, visit https://www.cops.usdoj.gov/pdf/ 

SF-425_Form.pdf. 

4. For examples of when lines 10.n and 10.o on the SF-425 are used, contact your COPS Office 

program manager. 

Table 1. Program income on the SF-425 

Note: Use lines 10.d–10.o for single award reporting only. Do not complete these lines if reporting on multiple awards. 

LINE T R A N S A C T I O N S DESCRIPTION 

10.l Total federal program income earned Enter the amount of federal program income earned. Do not report 

any program income here that is being allocated as part of the recipient’s 

cost-sharing amount included in line 10.j. 

10.m Program income expended in accordance 

with the deduction alternative 

Enter the amount of program income that was used to reduce the federal 

share of the total project costs. 

10.n Program income expended in accordance 

with the addition alternative 

Enter the amount of program income that was approved and expended 

on the project. 

10.o Unexpended program income (Line l 

minus line m or line n) 

Enter the remaining amount of unexpended program income by taking 

line l and either subtracting line m or line n, depending on which method 

you are using. 
3 Program Income 

Can recipients keep program income as a cash 

reserve for future project costs? 

No. Recipients should expend earned program income before 

drawing down award funds.5 

How much time is available to spend 

program income? 

Allowable project expenses can be supported by earned 

program income during the open award period. Funds 

cannot be drawn down for expenses that are incurred after 

the award end date. 

Avoid retaining earned program income for extended periods 

of time. If you anticipate a significant lapse of time occurring 

between earning and spending program income, contact your 

COPS Office program manager or grant program specialist. 

Unused program income should be deposited into your 

COPS Office award account to reduce your federal share.6 

These funds remain available for future use on allowable 

costs, incurred before award expiration, to fully implement 

your project. 

If you anticipate having unused program income remaining 

toward the end of the award period, you may submit a 

request to your COPS Office program manager or grant 

program specialist for a no-cost extension to provide 

additional time for your agency to spend program income 

on allowable costs to fully implement your project. No-cost 

extension requests must be submitted prior to the award 

end date and are approved on a case-by-case basis based on 

reasonable justification. 

5. See 2 C.F.R. § 200.305 for awards made after December 26, 2014. 

Prior awards would follow 28 C.F.R. §§ 66.21 and 70.22. 

6. It can take up to six weeks for the returned program income to 

appear in your COPS Office account. 

Unused program income remaining 90 days after the award 

end date must be promptly returned to the COPS Office. 

Please contact your COPS Office program manager for 

guidance on how to return excess program income and 

complete your final SF-425. 

In the event that you earn interest on program income, 

please contact your designated COPS Office financial analyst 

for guidance on how to complete your final SF-425 to 

account for interest earned. 

Important: Awards must be open and active to incur 

project expenses paid for by program income. 

Contact the COPS Office 

If you have any questions regarding the federal requirements on program income, 

please contact your COPS Office program manager, grant program specialist, or 

designated financial analyst. 

For more information about COPS Office programs and resources, please 

contact the COPS Office Response Center at 800-421-6770 or via e-mail at 

AskCopsRC@usdoj.gov or visit the COPS Office online at www.cops.usdoj.gov. 

Updated May 2017 
U.S. Department of Justice

Office of Community Oriented Policing Services

 Fact Sheet www.cops.usdoj.gov

Indirect Cost Rate for FY 2017 Awards
 


COPS Office programs 

If you are requesting indirect costs under a COPS Office 

program that allows those costs, a copy of your agency’s most 

current, signed, federally approved Negotiated Indirect Cost 

Rate Agreement must be included with your application, 

or it must be noted in your budget narrative that you have 

never received an indirect cost rate. If the rate agreement is 

expired at the time of application, then you should submit 

documentation demonstrating that the rate is under review 

by your cognizant federal agency. If your agency requests 

indirect costs for a COPS Office award based on an expired 

rate, your agency may not draw down funding for indirect 

costs until the current approved rate agreement or an 

approved extension is submitted to the COPS Office. In 

addition, if your agency’s rate agreement expires or changes 

during the award period, you must submit the new rate 

agreement or approved one-time extension from your 

cognizant federal agency to the COPS Office. 

What are indirect costs? 

Indirect Facilities & Administrative (F&A) costs are 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.1 

1 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. 

What is an indirect cost rate proposal? 



An indirect cost rate proposal as defined in 2 C.F.R. § 200.57 

is the documentation prepared by a nonfederal entity to 

support its request for the establishment of an indirect cost 

rate, as described in Appendix III to 2 C.F.R. Part 200, 

Indirect (F&A) Costs Identification and Assignment, and Rate 

Determination for Institutions of Higher Education (IHEs) 

through Appendix VII to 2 C.F.R. Part 200, States and Local 

Government and Indian Tribe Indirect Cost Proposals. 

Indirect (facilities & administrative (F&A)) costs 

are 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. 

There are several types of indirect cost rates: 

Final rate is applicable to a specified past period that is 

based on the actual costs of the period. A final audited 

rate is not subject to adjustment. 

 Fixed rate has the same characteristics as a predetermined 

rate except that the difference between estimated costs 

and actual allowable costs of the covered period is carried 

forward as an adjustment for a future period. 

 One-time extension allows your agency to apply for a 

one-time extension of a negotiated indirect (F&A) cost 

rate. The negotiated cost rate may be extended for up 

to four years. Once your cognizant federal agency has 

approved an extension for indirect costs, you must abide 

by the rate for the agreed-upon time period. No further 

negotiations regarding indirect cost rates may occur until 

the extension has expired. At the end of the extension 

period, you must negotiate a new indirect cost rate. 
2 Indirect Cost Rate 

 Predetermined rate is applicable to a specified current 

or future period and is not subject to adjustment. A 

predetermined rate may be used where there is reasonable 

assurance that the rate is not likely to exceed a rate based 

on the agency’s actual costs. Predetermined rates may not 

be used by governmental units that have not submitted 

and negotiated the rate with the cognizant federal agency. 

 Provisional rate is a temporary rate applicable to a 

specified time period that is used for funding, interim 

reimbursement, and reporting of indirect costs pending 

establishment of a final rate for that period. 

 De minimis indirect cost rate provides the option for 

certain nonfederal entities that have never received a 

negotiated indirect cost rate to accept a flat rate of up to 

10% of modified total direct costs (MTDC). MTDC 

can include all direct salaries and wages, applicable 

fringe benefits, materials and supplies, services, travel, 

and up to the first $25,000 of each subaward (regardless 

of the period of performance of the subawards under 

the award). MTDC excludes equipment, capital 

expenditures, rental costs, tuition remission, scholarships 

and fellowships, participant support costs, and the 

portion of each subaward in excess of $25,000. Other 

items may only be excluded when necessary to avoid a 

serious inequity in the distribution of indirect costs and 

with the approval of the cognizant federal agency for 

indirect costs. 

How does an agency establish an indirect 

cost rate? 

If your agency does not have a previously established indirect 

cost rate, your agency can obtain a rate by contacting 

your agency’s cognizant federal agency, which will review 

all documentation and approve a rate for the covered 

time period. For more information on the requirements 

for development and submission of indirect (F&A) cost 

rate proposals, please refer to 2 C.F.R. § 200.414 (e) and 

Appendices III – VII to 2 C.F.R. Part 200. 

What is a cognizant federal agency? 

Cognizant federal agency for indirect costs as defined in 

2 C.F.R. § 200.19 is the Federal agency responsible for 

reviewing, negotiating, and approving cost allocation 

plans or indirect cost proposals on behalf of all Federal 

agencies. The cognizant federal agency for indirect cost is 

not necessarily the same as the cognizant federal agency for 

audit. The COPS Office is not a cognizant federal agency. 

For nonprofit, state, local, and tribal governments your 

cognizant federal agency is generally the federal agency that 

provides your organization with the most federal financial 

assistance. For assignments of cognizant federal agencies, see 

the following: 

(a)	 For institutions of higher education: Appendix III to 

Part 200—Indirect (F&A) Costs Identification and 

Assignment, and Rate Determination for Institutions 

of Higher Education (IHEs), paragraph C.11. 

(b)	 For nonprofit organizations: Appendix IV to Part 

200—Indirect (F&A) Costs Identification and 

Assignment, and Rate Determination for Nonprofit 

Organizations, paragraph C.2.a. 

(c)	 For state and local governments: Appendix V to 

Part 200—State/Local Government and Indian 

Tribe-Wide Central Service Cost Allocation Plans, 

paragraph F.1. 

(d)	 For Indian tribes: Appendix VII to Part 200—States 

and Local Government and Indian Tribe Indirect 

Cost Proposal, paragraph D.1. 

What should an agency do if its indirect cost rate 

expires or changes during the award period? 

If your agency’s approved indirect cost rate agreement expires 

during the award period, a current approved rate agreement 

must be obtained from the cognizant federal agency and 

submitted to the COPS Office. The agency must advise the 

COPS Office of any changes to its approved indirect cost rate 

during the award period and, if necessary, request a budget 

modification that reflects the rate change. Please contact your 

COPS Office Grant Program Specialist or Program Manager 

to determine when a budget modification is necessary. 
3 Indirect Cost Rate 

If the agency experiences an increase or a decrease in its 

indirect cost rate, it should submit the new rate to the COPS 

Office within 30 days of the change. 

Can an agency reprogram indirect costs to 

direct costs? 

Reprogramming requests of indirect costs to direct costs are 

administered through the budget modification process for 

the specific COPS Office award that your agency received. 

Please contact your COPS Office Grant Program Specialist 

or Program Manager to obtain guidance on any additional 

requirements that may apply to your modification request. 

The COPS Office will then evaluate your request and notify 

you, in writing, of our decision. 

Please be advised that if your agency’s revised indirect cost 

rate is lower than the rate approved at the time of award 

and a formal budget modification was not approved, excess 

indirect cost rate funds should not be drawn down and will 

be deobligated at closeout. 

What should an agency expect at the end of the 

award period regarding its indirect costs rate? 

If a provisional indirect cost rate is in effect at award 

closeout, the recipient shall proceed with closeout but 

will complete an expenditure analysis upon receipt of 

the approved final indirect cost rate to determine if an 

adjustment is necessary. If the recipient drew down excess 

COPS Office funding for indirect costs, the recipient must 

return the overpayment to the COPS Office and submit a 

revised Federal Financial Report (SF-425). If the recipient 

incurred additional indirect costs, the recipient may request 

a budget modification if the award is still open and award 

funds are available. If the recipient returns or draws down 

COPS Office funding, the recipient will need to submit a 

revised final Federal Financial Report (SF-425). 

Other important factors 

To support the indirect cost rate agreement, recipients are 

responsible for ensuring independent audits are conducted 

in accordance with existing federal auditing and reporting 

standards set forth in 2 C.F.R. Part 200, Subpart F - Audit 

Requirements. A copy of the audit report must be submitted 

to the cognizant federal agency to support the indirect cost 

rate agreement. 

In accordance with ensuring proper award management and 

use of funding awarded through the COPS Office, recipients 

may be selected for a site visit or an enhanced office-based 

grant review (EOBGR) or may need to address an alleged 

noncompliance complaint during a compliance review by the 

COPS Office Grant Monitoring Division. 

Therefore, recipients must adhere to proper accounting 

practices and recordkeeping to ensure all necessary 

documentation is available for review if requested by the 

COPS Office. Noncompliance may result in the repayment 

of misused funds, suspension of funds, or other remedial 

actions available by law until the noncompliance is resolved. 

Contact the COPS Office 

If you have any questions regarding the federal requirements 

that guide indirect cost rates, please refer to the applicable COPS 

Office Award Owner’s Manual or contact your COPS Office Grant 

Program Specialist or Program Manager. 

For more information about COPS Office programs, please 

contact the COPS Office Response Center at 800-421-6770 or by 

e-mail at AskCopsRC@usdoj.gov or visit the COPS Office online 

at www.cops.usdoj.gov. 

May 2017 
U.S. Department of Justice 

Office of Community Oriented Policing Services 

 Fact Sheet www.cops.usdoj.gov

Budget Modifications for CPD Awardees 

Under federal regulations, you are required to expend federal 

funds only as approved in your federal clearance memo 

(FCM). The COPS Office realizes that agencies may need 

to reprogram award funds and has provided this fact sheet 

for CPD awardees to assist with the process. Awardees may 

reprogram up to a total of 10 percent of their entire budget 

(over the course of the award) without submitting a formal 

budget modification. However, awardees should notify their 

COPS Office program manager (PM) prior to any reprogramming of funds regardless of whether a formal budget 

modification is needed. Once the reprogramming of funds 

reaches 10 percent of the award, your agency must submit 

a formal budget modification requesting approval from 

the COPS Office for any additional budget modification 

requests. Starting with 2016 funding, any awards under 

$150,000 do not require formal budget modifications; 

however, the awardee should communicate reprogramming 

as needed with the COPS Office PM. 

Reprogrammed funds must be allocated for items covered 

within the scope of the original award. Any funds that are 

being requested to account for a change in scope from the 

original funded project must first receive approval from the 

COPS Office to expand or change the scope. Be advised that 

reprogramming requests for unallowable costs will not be 

approved. The COPS Office will not approve any modification request that results in an increase of federal funds. 

Starting with 2017 funding, if a budget modification 

involves making a new subaward to a State or local government entity, the awardee and its intended subrecepient are 

required to certify compliance with 8 U.S.C. § 1373 regarding prohibitions or restrictions on sending to, requesting or 

receiving from, maintaining, or exchanging information on 

citizenship or immigration status, including any prohibitions or restrictions imposed or established by a State or 

local government entity or official. For information about 

the applicable form and how to certify, please contact your 

COPS Office PM. 

What to do if you need 

a budget modification 

If your budget requires a modification, please follow 

these steps: 

1.	 Contact your PM and discuss the modification and 

reasoning for the change in budget. This process 

may require back and forth discussion and further 

documentation. 

2.	 Once your agency and the PM agree to the change, 

log in to “Account Access” in the upper right corner 

of the COPS Office website, www.cops.usdoj.gov. 

3.	 Once in the system, find the appropriate award, 

and within the Action menu, select “Modify.” 

4.	 You will see the Budget Summary page with the last 

approved budget amounts. The totals will be in readonly mode. Select “Modify” for each category (Civilian/ 

Nonsworn Officer Positions, Equipment/Technology, 

etc.) that requires a modification. 

5.	 Each change will need to be entered in the system by 

either adding or modifying the amount. Every item 

that is modified must have an accompanying narrative 

explaining the modification. The narrative must include 

the following: 

a.	 A brief description of each item and change that 

includes its purpose and how the item relates to the 

overall project 

b.	 A calculation breakdown for each new item 

6.	 After each section change, select “Save to Budget Summary” to save all work. Each time “Save to Budget 

Summary” is selected, you will be returned to the Budget 

Summary page. 

7.	 After modifying all of the appropriate items and providing the required narrative, select “Validate” at the bottom 

of the Budget Summary page. 
2 

Budget Modifications 

8.		In the Budget Summary page, compare the current and 

modified data for each item. If there is an error, select 

“Cancel” to return to the Budget Summary page. If the 

modification is correct, select “Submit.” 

9.		Once your budget modification is submitted, inform 

your PM via e-mail. In addition, include any relevant 

documentation as needed for the modification. This 

documentation may include the following: 

a.		For any new personnel or consultants you plan to hire 

noncompetitively, a resume must be submitted to your 

PM for prior approval. 

b.		For consultant rates over $650 per day, a consultant 

rate justification must be submitted to your PM for 

prior approval (see the Consultant/Contractor Rate 

Information Fact Sheet). 

c.		Current Indirect Cost Rate Agreement. 

d.		Documentation for personnel and consul­


tant costs.



e.		When adding a new subaward to a State or local 
 

government entity, the awardee and its intended 
 

subrecipient must each complete and submit the 
 

applicable Certification of Compliance with the 
 

8 U.S.C. § 1373 form.



Once you have completed all of the above steps, the COPS 

Office will review the budget modification. It is important 

to note that throughout the COPS Office review, no other 

processes including extensions can be submitted. The budget 

modification typically takes 30 days to process. 

Next steps 

Your budget modification will go through two rounds 

of review at a minimum: by your PM and by a budget 

analyst (BA). 

The PM will review the budget programmatically and 

may reach out to you for clarification, changes, or justification. Any changes required by your PM will result in the 

rejection of the modification. You will receive notification 

from the COPS Office, and you will be able to access the 

modification and make the necessary changes. The awardee 

will have to reenter the system, make the budget adjustments where necessary, and resubmit the saved changes. 

Once the budget modification has been programmatically 

approved, a BA is assigned. The BA will review the modification to ensure the budget is allowable and meets all 

regulations and policies. The BA will work with the PM 

for any points of clarification, changes, or justification. 

Any changes required by the BA will result in the rejection 

of the modification, and the awardee will have to resubmit. 

In the case of any rejection, an automatic notification 

will be sent out via e-mail, and the award’s status changes 

to the green “No action required” icon, from which you 

can initiate another request. 

In the case of any approval, an automatic notification 

will be sent out via e-mail. 

Implementation of the modified award budget may 

begin following this written approval from the COPS 

Office. The modification approvals for active awards 

will be accompanied by a modified FCM reflecting the 

approved changes. 

Other resources 

Your PM can provide you with a budget detail worksheet 

to help keep track of your costs and modifications. This 

tool can be used to track all of your costs, and when you 

submit a budget modification, it can be useful to submit 

as supplemental documentation to your PM. 

For additional information, please review the sole source 

justification, consultant/contractor rate information, and 

indirect cost rate fact sheets. These fact sheets are available 

at https://www.cops.usdoj.gov/Default.asp?Item=2541. 

Finally, your Award Owner’s Manual, Award Document, 

Cooperative Agreement, FCM, and Terms and Conditions 

will provide more information on specific requirements 

and policies that are applicable to your award. Your 

Award Owner’s Manual will include a list of allowable 

and unallowable items. 

Please contact your PM for further direction on any additional requirements that may be applied to your modification request or any other questions. 

Published 2017 
Appendix G. Whistleblower protection 

Enhancement of contractor protection from reprisal for disclosure of certain information 

(a)	 Prohibition of reprisals.--

(1)	 In general.--An employee of a contractor, subcontractor, grantee, or subgrantee or personal services 

contractor 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 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 

(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. 

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(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. 

(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. 

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(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. 

(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, 1 shall be construed to 

provide any rights to disclose classified information not otherwise provided by law. 

[(i) Repealed by Pub.L. 114-261, § 1(a)(3)(A)(ii), Dec. 14, 2016, 130 Stat. 1362] 

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Appendix H. 2 C.F.R. 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 non-Federal 

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, Department of 

Labor.” 

(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 non-Federal entities must include a provision for 

compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by 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 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 non-Federal 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 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 non-Federal 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 non-Federal 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 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 

118 
 

 

 

 

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 

non-Federal 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). 

(H) 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 exclusions 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.” SAM Exclusions 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. 

(I) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352)—Contractors that apply or bid for an award exceeding 

$100,000 must file the required certification. Each tier certifies to the tier above that it will not 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 non-Federal funds that takes place in connection with 

obtaining any Federal award. Such disclosures are forwarded from tier to tier up to the non-Federal award. 

(J) See §200.322 Procurement of recovered materials. 

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Appendix I. Remittance of Interest Earned Amounts
 

2 CFR § 200.305 (b)(9) – Payment (remittance of interest earned)
 

1. Interest earned amounts up to $500 per year may be retained by the non-federal entity for administrative 

expense. Any additional interest earned on federal advance payments deposited in interest-bearing 

accounts must be remitted annually to the Department of Health and Human Services Payment 

Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) 

network or a Fedwire Funds Service payment. Remittances must include pertinent information of the 

payee and nature of payment in the memo area (often referred to as “addenda records” by Financial 

Institutions) as that will assist in the timely posting of interest earned on federal funds. Pertinent details 

include the Payee Account Number (PAN) if the payment originated from PMS, or Agency information if 

the payment originated from ASAP, NSF or another federal agency payment system. The remittance must 

be submitted as follows: 

i. For ACH Returns: 

Routing Number: 051036706 

Account number: 303000 

Bank Name and Location: Credit Gateway - ACH Receiver St. Paul, MN 

ii. For Fedwire Returns*: 

Routing Number: 021030004 

Account number: 75010501 

Bank Name and Location: Federal Reserve Bank Treas NYC/Funds Transfer Division New York, NY 

(* Please note organization initiating payment is likely to incur a charge from your Financial Institution for 

this type of payment) 

iii. For International ACH Returns: 

Beneficiary Account: Federal Reserve Bank of New York/ITS (FRBNY/ITS) 

Bank: Citibank N.A. (New York) 

Swift Code: CITIUS33 

Account Number: 36838868 

Bank Address: 388 Greenwich Street, New York, NY 10013 

Payment Details (Line 70): Agency 

Name (abbreviated when possible) and ALC Agency POC: Michelle Haney, 301-492-5065 

iv. For recipients that do not have electronic remittance capability, please make check** payable to: “The 

Department of Health and Human Services.” 

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 PMS
 

account)
 

v. Any additional information/instructions may be found on the PMS Web site at http://www.dpm.psc.gov. 

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Glossary of Terms 

allowable costs. Allowable costs are expenses that may be funded by this award program. The COPS Office PASS 

award must be limited to funding for equipment, services, personnel, and other costs purchased or hired on or 

after the award start date. Upon review of your submitted budget, any unallowable costs were removed. The 

Financial Clearance Memorandum (FCM) included in your award package specifies your allowable costs, contains 

the final budget category amounts for which your agency was approved, and notes any relevant revisions that 

were made to your original budget submission. 

audit. Work done by auditors, including both the Office of the Inspector General (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 officials. The authorized officials are the individuals in your organization who have final authority and 

responsibility for all programmatic and financial decisions regarding this award. At the time of award application, 

your agency listed the law enforcement executive (usually the chief of police, sheriff, etc.) and the government 

executive (usually the mayor, board president, etc.) for your agency. For non-law enforcement agencies 

(institutions of higher education, private organizations, etc.), the authorized officials are the programmatic and 

financial officials who have the ultimate signatory authority to sign contracts on behalf of your organization. These 

executives are listed on your award document and are understood to be your authorized officials. 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. 

award number. The award number identifies your agency’s specific PASS award and can be found on your award 

document. This number should be used as a reference when corresponding with the COPS Office. Your award 

number is in the format 2017-CKWX-0000 for awards made in FY 2017. The COPS Office tracks award information 

based upon this number. 

award start date. This is the date on or after which your agency is authorized to purchase or hire any allowable 

equipment, services, personnel, or other costs that were approved by the COPS Office. The award start date is 

found on your award document. Recipients 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 award 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 PASS Program award is 16.710. 

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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 award that your organization has received, the US 

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. 

computer aided dispatch (CAD) system. A 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 computers 

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. The Office of Community Oriented Policing Services (COPS Office) is the division within the US 

Department of Justice that is the grantor agency for your award. The COPS Office is responsible for assisting your 

agency with the administration and maintenance of your award for the entire award period. You can reach the 

COPS Office at 800-421-6770. 

COPS Office Finance Staff. The COPS Office finance staff handles your agency’s financial and budgetary needs 

related to this award. 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 award. 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. 

COPS Office Program Manager. COPS Office Program Managers are trained to assist you with implementing and 

maintaining your PASS award. A Program Manager is assigned to your project and is available to answer any 

questions that you may have concerning the administrative, programmatic, and substantive aspects of your award. 

Your Program Manager can assist you with such matters as requesting an extension on your award or modifying 

the award, and reviewing outlines for project deliverables. The name and phone number of your COPS Office 

Program Manager is provided on the award congratulatory letter and available by contacting the COPS Office 

Response Center 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 award recipient information 

throughout the award cycle and to provide consistent name and address data for electronic award application 

systems. To obtain a DUNS number, visit the Dun & Bradstreet website at www.dnb.com or call 866-705-5711. 

122 
 

 

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 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 Bureau 

of Indian Affairs (BIA) by virtue of their status as Indian tribes. They are acknowledged to have the immunities and 

privileges available to other federally recognized Indian tribes by virtue of their government-to-government 

relationship with the United States as well as the responsibilities, power, limitations, and obligations of such tribes. 

Only federally recognized tribes are eligible to apply for COPS Office tribal award funds. For further information, 

contact BIA, Division of Tribal Government Services, MS-4631 – MIB, 1849 C Street NW, Washington, DC 20240, 

202-208-2475. 

Grant Monitoring Specialist. COPS Office Grant Monitoring Specialists are trained and available to assist you in 

addressing any compliance-related questions regarding your award. Grant monitoring specialists plan and conduct 

site visits and office-based grant reviews. During the life of your award, you may be selected for a monitoring site 

visit to assess your compliance with the terms and agreements of the award program, to review your community 

policing initiatives, and to provide technical and administrative support for your award. Please contact the COPS 

Office Response Center at 800-421-6770 if you have any compliance-related questions. 

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. 

obligation of funds. The COPS Office obligates federal funds when the award document is signed by the COPS 

Office Director or his or her designated official. For the recipient, award funds are obligated when monies are 

spent or orders are placed for purchasing approved technology or services under your PASS award. 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). 

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 nonofficial ORI code to use as an agency identifier (in such cases, the 

last two characters will be “ZZ”). It can be found on your award document. When you contact the COPS Office with 

a question, please reference your ORI number (or your award 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. 

123 
 

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 problem-solving, 

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.
 

SAFECOM guidance. The US 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 recipients seeking funding for interoperable 

emergency communications projects, including allowable costs, items to consider when funding emergency 

communications projects, awards management best practices for emergency communications awards, 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. Recipients (including sub-recipients) that are using PASS 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. 

System for Award Management (SAM). The SAM database is the repository for standard information about 

federal financial assistance applicants, recipients, and sub-recipients. 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 PASS award, supplanting means replacing state, local, or Bureau 

of Indian Affairs (BIA) funds that otherwise would have been spent on award purposes with federal COPS Office 

funds. State, local, and tribal governments are prohibited from supplanting throughout the award period. This 

means that your agency may not use COPS Office funds to pay for any equipment/technology, services, personnel, 

or other items which, in the absence of the COPS Office program, would otherwise have been funded with state or 

local funds or with funds supplied by the BIA. The COPS Office funds must instead be used to supplement, or 

increase, your budget on award purposes. For additional information on supplanting, please review the award 

condition titled ‘Supplementing, Not Supplanting’ in this manual. 

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0-421-6770. 

2017 COPS Office Preparing for Active Shooter Situations 

(PASS) Program Award Owner’s Manual 

This manual was created to assist COPS Office Preparing for Active Shooter Situations (PASS) award recipients with 

the administrative and financial matters associated with their award. 

For more information about your PASS award, please contact your COPS Office Program Manager. If you do not 

know the name or telephone number of your PASS, Program Manager, please contact the COPS Office Response 

Center at 80

US Department of Justice 

Office of Community Oriented Policing Services 

145 N Street NE 

Washington, DC 20530 

To obtain details about COPS Office programs, call the COPS Office Response Center at 800-421-6770. 

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

Published September 2017