2013 COPS Community Policing 

Development (CPD) 

Program Award Owner’s Manual

U.S. Department of Justice. Office of Community Oriented Policing Services

Joshua Ederheimer, Acting Director

www.cops.usdoj.gov
2013 Community Policing Development (CPD) 

Program Award Owner’s Manual

This manual was created to assist COPS Community Policing Development (CPD) Program awardees with the 

administrative and financial matters associated with the award.

For more information about your Community Policing Development award, please contact your COPS Program 

Manager. If you do not know the name or telephone number of your COPS Program Manager, please contact the COPS 

Office Response Center at 800-421-6770.

U.S. Department of Justice 

Office of Community Oriented Policing Services 

145 N Street NE

Washington, DC 20530

The COPS Office online: www.cops.usdoj.gov

August 2013
COPS Community Policing Development (CPD) Program Owner's Manual

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CONTENTS

GETTING STARTED.

I. AWARD ACCEPTANCE, TERMS, AND CONDITIONS.

The Award Document.

Award Terms and Conditions.

Reasons for Award Conditions.

Review of Award Terms and Conditions.

1. Award Owner’s Manual.

2. Assurances and Certifications.

3. Allowable Costs.

4. Travel Costs.

5. Supplementing, Not Supplanting.

6. Extensions.

7. Modifications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

8. Evaluations. .

9. Reports. .

10. Grant Monitoring Activities. .

11. Equal Employment Opportunity Plan (EEOP). .

12. Criminal Intelligence Systems. .

13. Sole Source Justification. .

14. Employment Eligibility. .

15. State Information Technology Point of Contact. .

16. False Statements. .

17. Public Release Information. .

18. News Media. .

19. Paperwork Reduction Act (PWRA). .

20. Human Subjects Research  .

21. Copyright  .

22. Additional High-Risk Grantee Requirements. .

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

24. Reporting Subawards and Executive Compensation. .

25. Federal Civil Rights Laws. .

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

Accepting the Award. .

Who should sign the Award Document for our agency?. .

When must the Award Document be signed?. .

II. THE COOPERATIVE AGREEMENT. .

The Cooperative Agreement Document  .

III. PROCUREMENT PROCESS. .

What documentation must be submitted to the COPS Office for sole source approval?. .
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IV. ACCESSING AWARD FUNDS. .

Payment Method. .

What method of payment is used?. .

Setting Up Your Account. .

How do we set up a GPRS account?. .

How do we fill out the payment enrollment forms?. .

When should Federal Financial Reports be filed?. .

Additional Payment Questions. .

Can we receive advances?. .

How often do we request reimbursement of costs?. .

Can we earn interest on our award funds?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

Matching Funds. .

V. FINANCIAL RECORD MAINTENANCE. .

Accounting Systems and Records. .

What accounting systems are required?. .

What records must be kept?. .

How long must documents be kept?. .

What if we have more than one award?. .

Who may access our records?. .

VI. FEDERAL AUDIT REQUIREMENTS. .

Requirements and Audits. .

What are the regulations governing SAA requirements?. .

Who must have an SAA audit?. .

What is the role of the Office of the Inspector General (OIG)?. .

How are COPS Office awards selected for an OIG audit?. .

Typical Audit Findings. .

VII. REPORTS. .

Federal Financial Reports. .

How do we file Federal Financial Reports?. .

How will award funds be monitored?. .

Program Progress Reports. .

What kind of information will these reports require?. .

Do we need to request a progress report?. .

How do we file progress reports?  .

Will the data that I submit be publicly available?  .

How can I complete a COPS Office progress report online?  .

How do I obtain access to complete the COPS Office progress report?  .

What if I make a mistake or need to modify my progress report after it is submitted?  .

Contact Points to Obtain Technical Assistance and Report Violations  .

VIII. WHEN THE AWARD PERIOD HAS ENDED. .

Final Federal Financial Report (SF-425). .

When should all of the award monies be spent?. .

Final Program Progress (Closeout) Report. .

Equipment Disposition. .
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IX. CONCLUSION. .

X. GLOSSARY OF TERMS. .

XI. APPENDIXES. .

Appendix A – List of Source Documents. .

Appendix B – Assurances and Certifications. .

Appendix C – Community Policing Defined. .

Appendix D – Sole Source Justification Facts  .

Appendix E – Conference Reporting Requirements  .

Appendix F – Consultant/Contractor Rate Information Sheet. .
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GETTING STARTED

Congratulations on receiving an award from the U.S. Department of Justice (DOJ), Office of Community 

Oriented Policing Services (COPS Office). The COPS Community Policing Development (CPD) Program 

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

through knowledge resource products and services such as training and technical assistance, the 

development of innovative community policing strategies, applied research, guidebooks, and/or best 

practice documents. 

According to the COPS Office, community policing is a philosophy that promotes organizational 

strategies, which 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 Appendix C, “Community Policing 

Defined.”

This COPS Community Policing Development (CPD) Program 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 

COPS CPD awardees are able to clearly understand and meet the requirements of their award. Please review 

this manual carefully because a failure to follow award requirements can have serious ramifications. Please 

do not hesitate to call your COPS Program Manager as listed in your agency’s award package or 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 CPD Program award, your agency must access 

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

and electronically sign the Award Document with the Award Terms and Conditions; if applicable, the 

Cooperative Agreement that is incorporated by reference into the Award Document; and, if applicable, 

the Special Award Conditions and/or High Risk Conditions in the Award Document Supplement within 45 

days of the date shown on the award congratulatory letter. 

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

Document. For more information on drawing down grant funds, please see Section IV, “Accessing Award 

Funds.” 

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 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 (universities, 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 complete the 

Change of Information (COI) form online at www.cops.usdoj.gov through the Account Access option. If the 

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

law enforcement executive and/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 45 

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 and, if applicable, the Cooperative Agreement and/or 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 CPD Award is listed on your award 

document.

Your award number is in the following format: 2013-XX-XX-XXXX for FY2013 awards. The COPS Office tracks 

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

(and/or your agency’s ORI number) readily available when corresponding with the COPS Office.

Your ORI number begins with your state abbreviation followed by five numbers and/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 

non-official ORI code to use as an agency identifier (in such cases, the last two digits will be “ZZ”). If you have 

any questions regarding your award, please refer to your award number or your agency’s ORI number when 

corresponding with the COPS Office.
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Your OJP vendor number, in most circumstances, is your agency’s nine- or thirteen-digit federal tax 

identification number assigned to you by the Internal Revenue Service. 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 award program, and should not be used for Internal Revenue Service 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 conditions 

specific to your agency). The section that follows describes each of the award conditions in detail, their 

rationale, 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 Program Manager or call 

the COPS 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 conditions will be included in the Award Document Supplement. However, if you 

have questions about the special conditions, please contact your assigned COPS Program Manager.

Reasons for Award Conditions

The requirements of your CPD award are established within:

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

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

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

Treasury

•	 The specific CPD requirements established by the COPS Office

A list of source documents for this booklet is provided in Appendix A. 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-specific documents may be requested directly from the COPS Office by calling your COPS Program 

Manager.

Review of Award Terms and Conditions

By signing the Award Document to accept this CPD award, your agency agrees to abide by the following 

award terms and conditions:
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1. Award Owner’s Manual

The awardee agrees to comply with the terms and conditions in this 2013 COPS Community Policing Development 

Program Award Owner’s Manual; COPS statute (42 U.S.C. 3796dd, et seq.); 28 C.F.R. Part 66 or 28 C.F.R. Part 70 as 

applicable (governing administrative requirements for awards and cooperative agreements); 2 C.F.R. Part 225 

(OMB Circular A-87), 2 C.F.R. Part 220 (OMB Circular A-2 1), 2 C.F.R. Part 230 (OMB Circular A- 122) and 48 C.F.R. 

Part 31.000 et seq. (FAR 31.2) as applicable (governing cost principles); OMB Circular A-133 (governing audits); 

representations made in the Community Policing Development Program grant application; the Cooperative 

Agreement; 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. More 

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

be requested through your COPS Program Manager.

What You Should Do:

Please read the entire CPD Program Award Owner’s Manual carefully prior to signing the Award Document. 

If you have any questions, please contact your COPS 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

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

signed as part of its Community Policing Development Program 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 seek your assurances and certification 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 as signatures on these documents are treated as a material representation of fact 

upon which reliance will be placed when the U.S. Department of Justice determines whether to award the 

covered award. Additional copies of the Assurances and Certifications forms are contained in Appendix B of 

this manual. If you have any questions about them, please contact your assigned COPS Program Manager 

via the COPS Response Center at 800-421-6770.
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3. Allowable Costs

The funding under this project is for the payment of approved costs for Community Policing Development 

purposes. The allowable costs for which your agency’s award has been approved are limited to those listed on the 

Financial Clearance Memorandum, which is included in your agency’s award package. 

The Financial Clearance Memorandum specifies the costs that your agency is allowed to fund with your 

Community Policing Development award. It also describes any costs which have been disallowed after review of 

your proposed budget. Your agency may not use Community Policing Development award funds for any costs 

that are not identified as allowable in the Financial Clearance Memorandum.

Why This Condition:

COPS CPD Program funding may only be used to pay for items and services approved by the COPS Office as 

reflected in the Financial Clearance Memorandum (FCM). The 2013 COPS CPD Program funds are to be used 

to advance the practice of community policing in law enforcement agencies through the development of 

knowledge resource products and services such as training and technical assistance, the development of 

innovative community policing strategies, applied research, guidebooks, and/or best practice documents 

that are national in scope. 

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 Section IV, “Accessing Award Funds,” 

of this manual. Section V, “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. As long as funds are spent during the award period on the 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. All awardees should keep and maintain the most 

recent, approved version of their 2013 CPD 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 and attendance records or the equivalent must support payroll records. 

For awardees 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, 

then your agency must specify the percentage of time that each person is working solely on the project 

identified in your agency’s CPD 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.
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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 28 C.F.R. Parts 66 or 70, as applicable. For awardees 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 CPD award.

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 28 C.F.R. Part 66.33 or 28 C.F.R. Part 70.35, as 

applicable.

Travel/Training

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

with prior approval from the COPS Office. For awardees subject to 2 C.F.R. Part 220 (OMB Circular A-21) 

Cost Principles for Educational Institutions; 2 C.F.R. Part 225 (OMB Circular A-87) Cost Principles for State, 

Local and Indian Tribal Governments; or 2 C.F.R. Part 230 (OMB Circular A-1 22) Cost Principles for Non-Profit 

Organizations, travel costs incurred directly by the awardee or costs incurred for project-related nonawardee travel will be reimbursed based upon the awardee’s written institutional travel policy if the costs 

are reasonable and allocable under the project. In the absence of an acceptable and available institutional 

travel policy, allowable per diem travel costs for lodging, meals, and incidentals will be reimbursed based on 

the established U.S. General Services Administration (GSA) per diem rates for the relevant geographic area. 

These rates can be found at www.gsa.gov. Allowable airfare travel costs will be reimbursed based upon the 

lowest discount commercial airfare, the federal government contract airfare (if authorized and available), or 

standard coach airfare, unless otherwise authorized in advance by the COPS Office.

For awardees subject to 48 C.F.R. Part 31.000, et seq. (FAR-31.2) Cost Principles for Commercial Organizations, 

travel costs incurred directly by the awardee will be reimbursed if the costs are reasonable and allocable 

under the project. Travel costs for lodging, meals, and incidental expenses may be reimbursed based upon 

per diem, actual expenses, or a combination of these methods, as long as the reimbursement rate does not 

exceed established GSA per diem rates as set forth in the Federal Travel Regulation. Transportation costs may 

be reimbursed based on mileage rates, actual costs incurred, or a combination of these methods. Allowable 

airfare travel costs will be reimbursed based upon standard coach fare, unless otherwise authorized in 

advance by the COPS Office.

The COPS CPD Program will fund award-related travel costs for the awardee agency or other (nonawardee) individuals to attend training and technical assistance conferences, seminars, or classes, or 

to visit a site specified in the application. Allowable expenses for award-related lodging, meals, and 

incidental expenses that were included in the application have been approved by the COPS Office as 

part of the CPD 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 Program 

Manager.
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Contracts/Consultants

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

and allocable in accordance with OMB Cost Principles, and consistent with that paid for similar services in 

the marketplace. Unless otherwise approved by the COPS Office, consultant rates will be based on the salary 

a consultant receives from his or her primary employer, as applicable, up to $550 per day. For consultant or 

contractor rates which exceed $550 per day, the COPS Office requires written justification if the consultants 

or contractors are hired through a noncompetitive bidding process, and awardees 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.

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.

Other Costs

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

included in this section of your FCM. In addition, items that have a direct correlation to the overall success 

of an awardee’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 awardees 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 CPD award.

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

Program Manager for further assistance.

Indirect Costs

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

expenses that are approved to be included within an indirect cost rate. If applicable, during the award 

period, the awardee will submit all approved indirect cost rates, provisional and final, to the COPS Program 

Manager within 30 days of approval and receipt from the cognizant federal agency. It is important that 

awardees carefully track and update their indirect cost rates charged against your COPS Office award. You 

must make the COPS Office aware of changes in these approved rates throughout your award period.

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

funded by another Department of Justice award.
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4. Travel Costs

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

Policing Development Program with prior approval from the COPS Office. Payment for allowable travel costs 

will be in accordance with 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-3 1.2, Cost 

Principles for Commercial Organizations), as applicable.

Why This Condition:

The COPS CPD Program will fund award-related travel costs for the awardee agency or other (non-awardee) 

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 CPD 

award and final budget. For more information, please refer to Award Condition #3 on page 5, “Allowable Costs.”

What You Should Do:

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

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 Program Manager. 

5. Supplementing, Not Supplanting

State, local, and tribal government awardees must use Community Policing Development 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 awardees may not use COPS funds to supplant (replace) 

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

award.

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 awardees, 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 awardees, CPD 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, awardees may not reallocate state, local, or BIA funds from one area within the law 

enforcement budget to another as a result of receiving CPD award funds. If you have questions concerning 

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

6. Extensions

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

grant program. Such extensions do not provide additional funding. Only those awardees 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.
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What You Should Do:

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

a no-cost 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 by the 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 awardee to complete the final deliverable. 

7. Modifications

Award modifications under the Community Policing Development Program are evaluated on a case-by-case 

basis. All modification requests involving the reallocation of funding between budget categories in excess of 10 

percent of the total award amount must be approved, in writing, by the COPS Office prior to their purchase or 

implementation. In addition, please be aware that the COPS Office will not approve any modification request that 

results in an increase of federal funds.

Why This Condition:

The COPS Office realizes that agencies may need to reprogram 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. Any request to change or alter an award 

should be submitted to the COPS Office for prior 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 scope 

of the original intent of the cooperative agreement. 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 Program Manager of any reprogramming that falls below the 10 percent threshold as well. Once 

the reprogramming of funds totals an aggregate of 10 percent or more of the award, your agency must seek 

prior written approval from the COPS Office for any additional budget modification requests.

What You Should Do:

You are required to notify your COPS 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 www.cops.usdoj.gov and select the Account Access 

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

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

Please contact your COPS 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 Financial Clearance Memo reflecting the approved changes. 
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8. Evaluations

The COPS Office may conduct monitoring or sponsor national evaluations of the COPS Community Policing 

Development Program. The awardee 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 what 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 CPD award. COPS Office staff and/or evaluators may 

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

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

may ask questions about the challenges encountered during project implementation, how residents feel 

about community policing, and how police feel about their work. This information will be useful to other 

communities and police agencies across the country.

What You Should Do:

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

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

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

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

information about your award activities. You should fully comply with any requests made regarding these 

evaluations.

9. Reports

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

programmatic progress reports and quarterly financial reports. 

Why This Condition:

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

policies require that financial assistance provided by the federal government be monitored carefully to 

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

basis, the progress of our programs and awardees.

What You Should Do:

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

CPD awards. All reports should be submitted to the COPS Office within the deadlines given to avoid 

suspension or possible termination of award funds or other remedial actions. For more information, please 

refer to Section VII, “Reports,” of this manual.

10. Grant Monitoring Activities

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

compliance with their grant conditions and other applicable statutory regulations. The COPS Office is also 

interested in tracking the progress of our programs and the advancement of community policing. Both aspects 

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

coordinated by the U.S. Department of Justice. 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 Community Policing Development awardee, you agree to cooperate with and respond 

to any requests for information pertaining to your grant.
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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 awardees are adhering to COPS 

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

What You Should Do:

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

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

and financially. The most common ways are:

1. Site Visits—The COPS Office conducts awardee site visits to ensure compliance with award 

terms and conditions. These visits also provide firsthand observation of the awardee’s community 

policing strategies. Promising practices identified during site visits are documented and may be 

shared with the law enforcement community. Technical assistance and follow-up actions are 

conducted to address potential and actual vulnerabilities. The purpose of site visits is therefore 

three-fold: review community policing activities, ensure awardee compliance, and provide 

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

any on-site review of your COPS Office awards. This review is generally performed over one or more 

days and also provides an opportunity for your agency representatives to seek assistance on any 

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

required to remedy identified award violations.

2. Office-Based Grant Reviews (OBGR)—In lieu of a site visit, certain awards are selected for a 

review conducted at the COPS Office. If selected, your agency will be contacted at the start of 

this review and our staff will work with your agency to correct any award problems or deficiencies 

through telephone, e-mail, fax, and/or written correspondence with your agency.

3. Complaints—The COPS Office responds to complaints from citizens, labor associations, media, 

and other sources. Written complaints or allegations are reviewed by the COPS Office Grant 

Monitoring Division, and may result in a review of your agency’s awards to determine compliance 

with award conditions.

Awardees are responsible for remedying any award noncompliance that is identified through these or 

other monitoring or auditing activities. Remedies for noncompliance may include, but are not limited 

to: suspending award funding, repaying misused award funds, voluntary withdrawal from or involuntary 

termination of remaining award funds, and restrictions from receiving future COPS Office awards. To avoid 

findings of noncompliance, awardees are strongly encouraged to contact the COPS Office at any time 

during the life of a COPS Office award with questions concerning award requirements and also to maintain 

all relevant documentation that may demonstrate award compliance. For more information, please contact 

the COPS Office Grant Monitoring Division at 800-421-6770 or at AskCopsRC@usdoj.gov.

11. Equal Employment Opportunity Plan (EEOP)

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

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

Why This Condition:

It is the experience of the Justice Department in implementing its responsibilities under the Omnibus Crime 

Control and Safe Streets Act of 1968 (Safe Streets Act), the statute that funds 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). EEOPs do not impose quotas or hiring requirements on recipients. 
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What You Should Do:

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

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

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

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

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

Certification Form to the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice, 810 

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

ocr/pdfs/cert.pdf. 

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

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

employees but excluding political appointees), then it has to prepare a Utilization Report (formerly 

called an EEOP Short Form), but it does not have to submit it to the OCR for review. Instead, your 

organization has to maintain the Utilization Report on file and make it available to the OCR for review 

on request. In addition, your organization has to complete and submit Section B of the Certification 

Form to the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice, 810 7th 

Street NW, Washington, DC 20531. The Certification Form can be found at www.ojp.usdoj.gov/about/ocr/

pdfs/cert.pdf.

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

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

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

it to the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice, 810 7th Street 

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

organization has to complete and submit Section C of the Certification Form to the OCR. The Certification 

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

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

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

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

EEOPforms@usdoj.gov.

12. Criminal Intelligence Systems

Awardees using Community Policing Development funds to operate an inter-jurisdictional criminal intelligence 

system must comply with operating principles of 28 C.F.R. Part 23. The awardee acknowledges that it has 

completed, signed and submitted with its grant application the Reviews and Certifications form certifying that it 

will comply with 28 C.F.R. Part 23.

Why This Condition:

If your agency receives funding for equipment or technology that will be used to operate an interjurisdictional criminal intelligence system, you must comply with the operating principles found at 28 C.F.R. 

Part 23. An “inter-jurisdictional criminal intelligence system” is generally defined as a system that receives, 

stores, analyzes, and exchanges or disseminates data regarding ongoing pre-arrest criminal activities 

(examples of such activities include, but are not limited to, loan sharking, drug or stolen property trafficking, 

gambling, extortion, smuggling, bribery, and public corruption) and shares this data with other law 

enforcement jurisdictions. 28 C.F.R. Part 23 contains operating principles for these inter-jurisdictional criminal 

information systems that protect individual privacy and constitutional rights.
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If your agency will use CPD award funds simply to operate a single agency database (or other unrelated 

forms of technology) and will not share criminal intelligence data with other jurisdictions, 28 C.F.R. Part 23 

does not apply to this award.

What You Should Do:

All CPD awardees were required to agree to the Criminal Intelligence Systems/28 C.F.R. Part 23 Compliance 

Special Condition as part of their application proposal so the COPS Office can track which agencies intend 

to use their award funds to operate inter-jurisdictional criminal intelligence systems. If your agency intends 

to use award funds to operate an inter-jurisdictional 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 CPD award.

13. Sole Source Justification

Awardees who have been awarded funding for the procurement of an item (or group of items) or service in excess 

of $100,000 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.

Why This Condition:

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

However, in some instances, awardees 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 $100,000 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:

1. The item (or group of items) or service is available only from a single source

2. Public exigency or emergency for the requirement will not permit a delay resulting from competitive 

solicitation

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

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 awarded to the general rule regarding competition. 

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

III, “Procurement Process,” of this manual.
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14. Employment Eligibility

The awardee 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.

15. State Information Technology Point of Contact

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

notification regarding any information technology project funded by this Community Policing Development 

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 awardee agrees to maintain an administrative file documenting the meeting of this 

requirement. For a list of State Information Technology Points of Contact, go to http://it.ojp.gov/default.aspx?area

=policyAndPractice&page=1046.

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.

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 COPSfunded 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., 

as the communication backbone to achieve interstate connectivity.

16. False Statements

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

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

Why This Condition:

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

applications, financial and programmatic reports, or other 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.
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17. Public Release Information

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

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

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

“This project was supported by Cooperative Agreement Number 2013-XX-XX-XXXX awarded by the Office of 

Community Oriented Policing Services, U.S. Department of Justice. The opinions contained herein are those of 

the author(s) and do not necessarily represent the official position or policies of the U.S. Department of Justice. 

References to specific agencies, companies, products, or services should not be considered an endorsement by 

the author(s) or the U.S. Department of Justice. Rather, the references are illustrations to supplement discussion 

of the issues.

The Internet references cited in this publication were valid as of the date of this 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 official federal documents and should not be construed to reflect the official policy or position of 

the DOJ.

In addition, the COPS Office reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, 

publish, or otherwise use, and to authorize others to use, for federal government purposes: (1) the copyright 

in any work developed under the award including any related subaward or contract and (2) any copyright to 

which an awardee, including its subawardee or contractor, purchases ownership with financial support from 

award funds. 28 C.F.R. § § 66.34, 70.36(a).

What You Should Do:

Ensure that all publications (where applicable) relating to your COPS CPD award contain the required 

statement listed above.

In addition, the awardee is responsible for acquiring the rights, and ensuring that its subcontractors/authors 

acquire the rights, to copyrighted material for inclusion in DOJ publications or other products or deliverables 

that are developed under this cooperative agreement, including the payment of required fees. All licensing, 

publishing, or similar agreements with a copyright holder, publisher, or other relevant party shall include 

provisions giving the Federal Government a royalty-free, non-exclusive, and irrevocable license to reproduce, 

publish, or otherwise use, and to authorize others to use, the publication for federal government purposes.

18. News Media

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

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

the COPS Office and/or parameters of the award. The awardee agrees to refer all media inquiries on these topics 

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

Why This Condition:

The COPS Office External Affairs 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 DOJ 

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 External Affairs Division at 

202-514-9079.
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19. Paperwork Reduction Act (PWRA)

The awardee 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 and to maximize the practical utility and public benefit of information created, collected, disclosed, 

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

A collection of information undertaken by an awardee is considered to be conducted or sponsored by a 

federal agency only if (1) the awardee 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. 5 C.F.R. § 1320.3(d).

What You Should Do:

When surveys, interviews, and other methods of information collection are undertaken by you in 

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

Program Manager will inform you whether 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, 

thus awardees are advised to allow ample time for processing of this request.

20. Human Subjects Research 

The awardee agrees to comply with the provisions of the U.S. 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 

activity(ies), if applicable. The awardee 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 DOJ 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-supported human subjects research must provide a written 

assurance of compliance, satisfactory to the COPS Office, that it will comply with the DOJ human subjects 

regulations.

What You Should Do:

If any part of your CPD 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)(1-6), you should ensure that you meet 

the provisions of the DOJ’s common rule regarding human subjects research risk protections, 28 C.F.R. Part 

46, prior to the expenditure of federal funds to perform such activity(ies). 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.
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21. Copyright 

If applicable, U.S. Department of Justice regulations permit an awardee to copyright any work that is subject to 

copyright and was developed, or for which ownership was purchased, under an award. The awardee agrees that 

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

and to authorize others to use, for federal government purposes: (1) the copyright in any work developed under 

the Community Policing Development award, subaward, or contract; and (2) any rights of copyright to which an 

awardee, subawardee, or a contractor purchases ownership with support from Community Policing Development 

funds. The awardee also agrees that it is responsible for acquiring the rights, and ensuring that its subawardees/

contractors/authors acquire the rights, to copyrighted material for inclusion in U.S. Department of Justice 

publications and other products and deliverables that are developed under the award, including the payment of 

required fees. The COPS Office may make available for reproduction material produced under this Cooperative 

Agreement by any means, including a DOJ website, a hard copy(ies), or in electronic form(s), without restriction.

When appropriate, U.S. Department of Justice publications and other products and deliverables developed 

under the Community Policing Development award should contain the following copyright notice: “Copyright 

© [year work was published] [name of copyright owner]. The U.S. Department of Justice reserves a royaltyfree, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use, and authorize others to 

use, this publication for federal government purposes. This publication may be freely distributed and used for 

noncommercial and educational purposes only.”

Why This Condition:

DOJ regulations allow the recipient of a COPS Office 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 available for reproduction any material developed under the award by any means, including 

a DOJ website, a hard copy(ies), or in electronic form(s), without restriction. While the awardee owns the 

copyright in a COPS-funded work, the COPS Office reserves a royalty-free, nonexclusive, and irrevocable 

license to reproduce, publish, or otherwise use, and to authorize others to use, for federal government 

purposes: (1) the copyright in any work developed under the award including any related subaward or 

contract and (2) any copyright to which an awardee, including its subawardee or contractor, purchases 

ownership with financial support from award funds. 28 C.F.R. § § 66.34, 70.36(a).

What You Should Do:

The awardee is responsible for acquiring the rights, and ensuring that its subawardees/contractors/

authors acquire the rights to copyrighted material for inclusion in DOJ publications or other products or 

deliverables that are developed under this cooperative agreement, including the payment of required fees. 

All licensing, publishing, or similar agreements with a copyright holder, publisher, or other relevant party 

shall include provisions giving the Federal Government a royalty-free, non-exclusive, and irrevocable license 

to reproduce, publish, or otherwise use, and to authorize others to use, the copyrighted material for federal 

government purposes.

To help protect against unauthorized use, COPS-funded publications and other products or deliverables 

should contain the above-referenced copyright notice when appropriate.

If applicable, the awardee may copyright work that was developed, or for which ownership was purchased, 

under an award. However, please be advised that the DOJ is a nonexclusive licensee and only the legal or 

beneficial owner of an exclusive right under a copyright is entitled to institute an infringement action. An 

awardee should therefore consult its own legal counsel with any copyright infringement questions. For 

more information about registering a copyright, please visit the U.S. Copyright Office at www.copyright.gov.
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22. Additional High-Risk Grantee Requirements

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

performance period if the awarding agency determines that the recipient is a high-risk awardee (28 C.F.R. Parts 66 

and 70).

Why This Condition:

The Uniform Administrative Requirements for Awards and Cooperative Agreements to State and Local 

Governments, 28 C.F.R. Part 66.12, and for Institutions of Higher Education, Hospitals and Other Non-Profit 

Organizations, 28 C.F.R. Part 70.14, provide that an awardee or applicant may be considered “high risk” if 

the Department of Justice determines that there is unsatisfactory performance, financial or administrative 

instability, nonconformity with award terms and conditions, or other lack of responsibility. 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 awardee.

23. System for Award Management (SAM) and Universal Identifier 

Requirements

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

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

A. Requirement for System for Award Management (SAM)

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

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

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

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

your information or another award term.

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

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

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

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

2. May not make a subaward to an entity unless the entity has provided its DUNS number to you.

C. Definitions

For purposes of this award term:

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

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

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

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

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

may be obtained from D&B by telephone (currently 866-705-5711) or the Internet at http://fedgov.dnb.

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

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

b. A foreign public entity;

c. A domestic or foreign non-profit organization;

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

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

4. Subaward:

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

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

to an eligible subrecipient.

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

project or program (for further explanation, see Sec.II.210 of the attachment to OMB Circular A-133, 

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

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

consider a contract.

5. Subrecipient means an entity that:

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

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

Why This Condition:

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

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

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

applicants and recipients.

What You Should Do:

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

the SAM database. 

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

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

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

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

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

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

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

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

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

24. Reporting Subawards and Executive Compensation

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

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

a. Reporting of first-tier subawards.

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

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

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

subaward to an entity (see definitions in paragraph e. of this award term).
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2. Where and when to report.

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

fsrs.gov.

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

which the obligation was made. (For example, if the obligation was made on November 7, 2013, the 

obligation must be reported by no later than December 31, 2013.)

3. What to report. 

i. You must report the information about each obligating action that the submission instructions 

posted at www.fsrs.gov specify.

b. Reporting Total Compensation of Recipient Executives.

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

compensated executives for the preceding completed fiscal year, if—

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

ii. in the preceding fiscal year, you received—

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

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

Part 170.320 (and subawards); and

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

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

Part 170.320 (and subawards); and

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

periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 

78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine if the public 

has access to the compensation information, see the U.S. Security and Exchange Commission total 

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

2. Where and when to report. You must report executive total compensation described in paragraph b.1. of 

this award term:

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

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

c. Reporting of Total Compensation of Subrecipient Executives.

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

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

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

completed fiscal year, if—

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

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

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

Part 170.320 (and subawards); and

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

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

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

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

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

has access to the compensation information, see the U.S. Security and Exchange Commission total 

compensation filings at www.sec.gov/answers/execomp.htm.)
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2. Where and when to report. You must report subrecipient executive total compensation described in 

paragraph c.1. of this award term:

i. To the recipient.

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

example, if a subaward is obligated on any date during the month of October of a given year 

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

subrecipient by November 30 of that year.

d. Exemptions.

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

the requirements to report:

i. Subawards, and

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

e. Definitions. For purposes of this award term:

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

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

ii. A foreign public entity;

iii. A domestic or foreign 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. ll .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 C.F.R. Part 

229.402(c)(2)):

i. Salary and bonus.

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

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

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

Payments.

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

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

are available generally to all salaried employees.

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

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

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

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

property) for the executive exceeds $10,000.

Why This Condition:

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

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

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

gov. Awardees 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 totalling $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 

Internet 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.

25. Federal Civil Rights Laws

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

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

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

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

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

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

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

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

1973, as amended (29 U.S.C. § 794); the Age Discrimination Act of 1975 (42 U.S.C. 6101 et seq.); Title IX of the 

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

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

Executive Order 13279 Equal Treatment for Faith-Based Organizations and its implementing regulations 

at 28 C.F.R. Part 38, which requires equal treatment of religious organizations in the funding process and 

nondiscrimination of beneficiaries by Faith-Based Organizations on the basis of belief or non-belief.

Why This Condition:

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

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

found in the non-discrimination provisions referenced above. A hold may be placed on your award if it 

is deemed that your agency is not in compliance with federal civil rights laws and/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 and/or cooperate with any ongoing federal civil rights investigation.
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What You Should Do:

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

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

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

providing access to records, accounts, documents, information, facilities, and staff.

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

•	 Is failing to make satisfactory progress toward the goals or strategies outlined in its application

•	 Is not adhering to award requirements or conditions

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

resulted in the application being denied funding

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

•	 Is filing false statements or certifications in connection with an application, periodic report, or 

other award-related documents

•	 Is 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 U.S. 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 bar your agency from obtaining future awards

•	 Recommend civil or criminal enforcement by other agencies

•	 Take other remedies that may be legally available

In the event that sanctions are imposed or your award is terminated, your agency will be notified in writing 

of our decision and the reason(s) for that decision.

Accepting the Award

After you have reviewed the conditions of your COPS CPD 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 Section X, “Glossary of Terms”) 

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

review, and electronically sign the Award Document with the Award Terms and Conditions; if applicable, the 

Cooperative Agreement that is incorporated by reference into the Award Document; and, if applicable, the 

Special Award Conditions and/or High Risk Conditions in the Award Document Supplement within 45 days 

of the date shown on the award congratulatory letter. 
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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 awardee. The 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 (universities, 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 located in your CPD application package (if one or both of these individuals have changed, please 

complete a Change of Information (COI) form online at www.cops.usdoj.gov through the Account Access 

option). If you have any questions as to who should sign the award, please contact your organization’s legal 

counsel.

When must the Award Document be signed?

Please electronically sign the Award Document and all award condition pages within 45 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 45-day award acceptance period may result in your CPD award being withdrawn 

and the funds deobligated without additional notification. If your agency requires an extension for 

accepting the award beyond the 45-day acceptance timeframe, please submit a written request to 

your COPS Program Manager. Be sure to explain the circumstances that prevent your agency from 

electronically signing the Award Document within the 45-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 45-day award acceptance period.
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II. THE COOPERATIVE AGREEMENT

The Cooperative Agreement Document 

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

Agreement Document will accompany your Award Document. 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 awardee. 31 U.S.C. § 6305.

To officially accept and begin your CPD award, your agency must review the Cooperative Agreement 

Document along with your Award Document and electronically sign for all documents within 45 days of the 

date shown on the award congratulatory letter. 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.

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

Award Document. 

The sections that follow describe in detail each aspect of the cooperative agreement, its rationale, and its 

implications. They also address many frequently asked questions. If you have any additional questions concerning 

your cooperative agreement, please contact your designated COPS Program Manager. 

I. Statement of Authority

A cooperative agreement between the awardee and the COPS Office is entered into under the authority of 

42 U.S.C. 3796dd et seq. The purpose of the cooperative agreement is to set forth the background, purpose, 

expectations, tasks, deliverables, and timelines for the COPS-funded project. 

II. Statement of Background and Purpose

Background:

This section establishes why this cooperative effort is needed, including a history of the effort to date and 

why the effort is required now. This section also establishes the purpose of the project and explains the 

rationale for the work.

Primary Objective:

The primary objective describes what the recipient will accomplish under this CPD award. Additionally, 

the cooperative agreement highlights how CPD funds will be used to advance the practice of community 

policing. This is generally accomplished through the development of knowledge resource products and 

services such as: training and technical assistance; implementing and testing innovative community 

policing strategies; conducting applied research; and developing guidebooks or other resources.

III. Scope of Work

This section outlines the specific personnel, travel, supplies, and activities necessary to perform the work 

being funded. It is organized into two sections: Section A, which details the services and support that the 

COPS Office will provide; and Section B, which details the activities and requirements that the awardee 

agrees to accomplish and meet. 
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A. The COPS Office Responsibilities

Specifically, the COPS Office will: 

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

Agreement and to coordinate activities. 

The name of your designated COPS Program Manager will appear on the congratulatory letter 

accompanying the Award Document and in the Program Manager section of the cooperative 

agreement. This Program Manager will cooperatively work with you as outlined within the specific tasks 

of the cooperative agreement. 

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

determined appropriate by the Program Manager.

When deemed appropriate by the Program Manager, the COPS Office will provide assistance from 

government sources within and outside of the COPS Office and the DOJ.

3. Provide guidance to the awardee 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.

The COPS Office will participate in planning and developing strategies used during the project and, 

where necessary and appropriate, facilitate any work between the awardee, law enforcement agencies, 

and other organizations.

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

The COPS Office will work cooperatively with the awardee to ensure that all designated, specific projectrelated tasks and timelines outlined within the cooperative agreement are met.

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

progress and financial reports, deliverables, evaluations, and other documentation requiring COPS Office 

approval.

The COPS Office will review and approve deliverables resulting from the award, including periodic 

progress and financial reports, draft deliverables, etc. In the rare instance where your project involves 

an evaluation of a COPS Office program, the COPS Office will not exercise final approval for deliverables 

specifically intended as outcome evaluations to examine the effectiveness of COPS Office programs. 

6. If applicable, U.S. Department of Justice regulations permit an awardee to copyright any work that is subject 

to copyright and was developed, or for which ownership was purchased, under an award. The COPS Office 

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

authorize others to use, for federal government purposes: (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 

an awardee, including its subawardee or contractor, purchases ownership with support from this Cooperative 

Agreement. Additionally, the COPS Office may make available for reproduction material produced under this 

Cooperative Agreement by any means, including a U.S. Department of Justice website, a hard copy(ies), or in 

electronic form(s), without restriction. 

Please refer to Award Condition #21 on page 17 for a complete description of the copyright rights and 

responsibilities of the COPS Office and awardee.
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B. The Awardee Responsibilities

This section provides additional details of awardee responsibilities common to all COPS Office cooperative 

agreements. 

1. Be responsible for acquiring the rights, and ensuring that its subawardees/contractors/authors acquire the 

rights to copyrighted material for inclusion in DOJ publications or other products or deliverables that are 

developed under this Cooperative Agreement, including the payment of required fees. All licensing, publishing 

or similar agreements with a copyright holder, publisher, or other relevant party shall include provisions 

giving the Federal Government a royalty-free, non-exclusive, and irrevocable license to reproduce, publish, or 

otherwise use, and to authorize others to use, the copyrighted material for federal government purposes. 

Copies of copyright permissions and publication agreements should be submitted to the COPS Office.

Please refer to Award Condition #21 on page 17 for a complete description of the copyright rights and 

responsibilities of the COPS Office and awardee.

2. Work closely with the COPS Office and Program Manager to achieve the tasks specified in this Cooperative 

Agreement.

A COPS Program Manager has been designated to participate in the planning and management of 

the cooperative agreement and to coordinate activities on behalf of the COPS Office. You should 

work closely with your designated COPS Program Manager to ensure that the tasks specified in the 

cooperative agreement are met. 

3. Provide further detail on project plans as requested by the Program Manager.

Your COPS Program Manager is responsible for providing support and guidance in the planning and 

implementation of your project, and for taking steps to ensure that program objectives and goals 

are met as delineated in the cooperative agreement. In order for the COPS Program Manager to 

provide such guidance, s/he must be kept informed regarding significant project plans, activities, and 

deliverables. 

 4. Adhere to the requirements or tasks specified in this Cooperative Agreement and do not deviate from them 

unless requested adjustments are first presented to and approved by the Program Manager.

By accepting this award, you are obtaining federal funds from the COPS Office and agree to 

the terms set forth in the cooperative agreement. As part of that agreement, your agency 

acknowledges that it will comply with these conditions. The designated COPS Program Manager 

and awardee project officers for their respective organizations shall have the authority to propose 

and approve any modifications to the cooperative agreement. Modifications to the cooperative 

agreement may be proposed in writing at any time during the period of performance by either 

party, and shall become effective upon approval by both parties. Please be aware that the COPS 

Office will not approve any modification request that results in an increase of federal funds.

The COPS Office realizes that agencies may need to reprogram award funds during the project award 

period. Reprogrammed funds must be within the scope of the original intent of the cooperative 

agreement. Your agency may reprogram its budget up to an aggregate of 10 percent of the total 

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

COPS Program Manager of any reprogramming that falls below the 10 percent threshold as well. Once 

the reprogramming of funds totals an aggregate of 10 percent or more of the award, your agency must 

seek written approval from the COPS Office for any additional budget modification requests. Refrain 

from obligating or purchasing any of the requested items or services until the reprogramming request 

is approved by the COPS Office. Please be advised that reprogramming requests for unallowable costs 

will not be approved. 
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5. Submit for prior approval or disapproval to the Program Manager any proposed changes in key staff 

assignments to this project and any significant changes in any partner’s role or responsibilities.

The COPS Office must be made aware of changes in key staff that plays a significant role in the 

achievement of project deliverables. The COPS Office realizes that staff assignments and key staff 

roles may change throughout the life of the award. Your agency must seek approval from your COPS 

Program Manager before making changes in key staff assignments or significant changes in any 

partner’s role or responsibilities. 

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

Agreement funds for the award of non-competitive contracts (including equipment purchases) in excess of 

$100,000. 

Please refer to Award Condition #13 on page 13 for a complete description of the Sole Source 

Justification requirement.

7. Ensure that all proposed deliverables and publications follow and are in accordance with the COPS Office 

Editorial and Graphics Style Manual.

The COPS Office Editorial and Graphics Style Manual is the primary writing and editing reference for 

COPS Office publications and related materials and is used to maintain the consistency and quality of 

COPS Office knowledge resource products. It includes correct formats for footnotes, endnotes, and 

references; information on formatting and design; Section 508 compliance; permissions; a disclaimer 

for COPS-funded publications; a list of editorial/proofreading marks; and an alphabetical list of 

guidelines for word usages, spelling, punctuation, and grammar. A copy of The COPS Office Editorial and 

Graphics Style Manual is included in the award packet. Familiarize yourself with the document and use 

it as a guideline when preparing written materials for COPS Office publication. If you need additional 

copies, contact your COPS Program Manager, the Response Center at 800-421-6770, or visit this link to 

download a copy of this manual: www.cops.usdoj.gov/pdf/cpd/COPS-Style-Manual.pdf.

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

websites) or computer programs resulting from this Cooperative Agreement to the Program Manager 20 days 

prior to public release. 

The COPS Office has an interest in maintaining the quality, objectivity, utility, and integrity of 

reports and publications resulting from awards to ensure that the information provided to the 

public is current, complete, and accurate. It is also important for the COPS Office to be aware of 

all publications and deliverables resulting from awards so that the COPS Office can be prepared to 

respond to inquiries about these deliverables and if applicable, can seek means by which to promote 

them.

Submit copies of all deliverables (written, curricula, visual, sound, or websites) a minimum of 20 days prior 

to public release. In addition, please include the mandatory disclaimer statement and, if applicable, the 

copyright notice shown in Section III.B.9 of the cooperative agreement on all deliverables.

9. All products and deliverables (written, curricula, visual, sound, or websites) or computer programs developed 

under this cooperative agreement shall contain the following disclaimer statement:

This project was supported by Cooperative Agreement Number 2013-XX-XX-XXXX awarded by the 

Office of Community Oriented Policing Services, U.S. Department of Justice. The opinions contained 

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

U.S. Department of Justice. References to specific agencies, companies, products, or services should 

not be considered an endorsement by the author(s) or the U.S. Department of Justice. Rather, the 

references are illustrations to supplement discussion of the issues.

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

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

current validity.
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When appropriate, DOJ 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 U.S. Department of Justice 

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

and authorize others to use, this publication for federal government purposes. This publication may be 

freely distributed and used for noncommercial and educational purposes only.

For more information, please refer to Award Condition #17 on page 15 for a complete description of the 

Public Release Information requirements.

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

video and multimedia products, compact disks, software applications and operating systems, and 

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

508 accessibility requirements. 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 websites must be fully compliant with 508 accessibility standards. For more information on Section 508 

accessibility requirements, consult www.section508.gov/.

Section 508 of the Rehabilitation Act of 1973, as amended, ensures that users with disabilities have 

access to electronic and information technology produced by federal agencies and by organizations 

receiving federal funds. Accessibility involves the ability of people who are visually impaired, deaf, or 

hard of hearing to access documents through special software on their personal computers. Authors 

submitting documents to the COPS Office for publication must provide documents in text and 

accessible PDF formats that are compliant with Section 508. For example, this includes tagging PDF files 

and closed-captioning videos. For more information on Section 508 accessibility requirements, consult 

www.section508.gov or contact your COPS Program Manager.

11. 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.

For more information, please refer to Award Condition #19 on page 16 for a complete description of the 

Paperwork Reduction Act (PWRA) requirements.

12. 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. 

For more information, please refer to Award Condition #10 on page 10 for a complete description of 

Grant Monitoring Activities.

13. Be responsible for the development, approval, and operation of all subawards and require its subawardees 

to adhere to applicable federal requirements governing federal assistance. The Awardee will ensure that 

subawardees maintain effective control and accountability over all funds, property, and other assets covered 

by subawards and that each subawardee establishes and uses internal fiscal and program management 

procedures sufficient to prevent fraud, waste, or abuse, pursuant to 28 C.F.R. § 66.37 and 28 C.F.R. § 70.5, as 

applicable.

Under the Uniform Administrative Requirements, the awardee must ensure that subawardees maintain 

effective control and accountability over all funds, property, and other assets covered by subawards 

and that each subawardee establishes and uses internal fiscal and program management procedures 

sufficient to prevent fraud or abuse.
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14. Will work to develop a marketing plan to increase the visibility of the project and any accompanying 

outcomes/deliverables at the request of the COPS Office. The awardee will coordinate any marketing activities 

with the COPS Office.

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. To 

assure that COPS-funded projects and deliverables reach their intended target audiences, awardees 

are encouraged to develop specific marketing plans to advance the visibility of their project outcomes. 

These activities must be coordinated with the COPS Office and at the COPS Office’s request should be 

written down in a specific marketing plan. You should work closely with your COPS Program Manager 

to discuss the project deliverables, intended audience, marketing and promotional activities, and the 

potential need for a specific marketing plan for your CPD project.

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

and/or other COPS Office staff comments prior to the Cooperative Agreement expiration date. 

The COPS Office has an interest in maintaining the quality, objectivity, utility, and integrity of reports 

and publications resulting from awards to ensure that the information provided to the public is current, 

complete, and accurate. As part of this process, COPS Program Managers are required to follow the 

COPS Office Knowledge Resource Development Standard Operating Procedures, which are internal 

procedures that govern the production processes for COPS Office publications and resources. To ensure 

consistency in the development and distribution of quality community policing-related publications, 

your draft deliverables will be thoroughly vetted internally within the Department of Justice and peer 

reviewed externally with subject-matter experts. 

Once you submit your deliverables to the COPS Office, your COPS Program Manager will guide 

you through the knowledge resource development process, including responding to comments 

and suggestions that result from vetting and/or peer review that may result in modifications to the 

deliverables.

16. 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. For more information on allowable costs, please follow this link: 

www.ojp.gov/funding/confcost.htm.

The COPS Office recognizes the importance of its fiduciary responsibility and that of its awardees to 

ensure conference spending is accomplished within proper guidelines and with restraint. 

Awardees must strictly minimize costs, ensure prudent spending, and avoid the fact or appearance 

of extravagant spending. Awardees are encouraged to find alternative ways to facilitate events, such 

as webinars, acquire the lowest cost locations and venues, minimize travel costs, ensuring that all 

conference costs are necessary business expenses. Award funds cannot be used to purchase food and/

or beverages for any conference or similar event except in very limited circumstances so please consult 

your COPS Program Manager.

Failure to obtain written approval prior to entering into any agreement related to any conference or 

similar event may result in the determination that those costs are ineligible for reimbursement under 

the award.

17. 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.

The COPS Office will notify awardees of any updated conference costs and reporting requirements 

during the award period.
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18. 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:

1) Name of the event

2) Event dates

3) Location of event

4) Number of federal attendees

5) Number of non-federal attendees

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

7) Costs for audio visual services

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

9) Costs of printing and distribution

10) Costs of meals provided during the event

11) Costs of refreshments provided during the event

12) Costs of event planner

13) Costs of event facilitators

14) 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:

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

2) Lodging

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

4) 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. 

In the U.S. Department of Justice (DOJ) FY2008 Appropriations Act (Section 218, Title II, Division B, 

Public Law 110-161), the Attorney General was directed to collect and submit quarterly reports about 

conference activities to DOJ’s Office of the Inspector General (OIG). The reports are required to provide 

information related to the costs and contracting procedures relating to each conference, held by the 

U.S. Department of Justice during each fiscal year, for which the cost to the government was more than 

$20,000. 

This reporting requirement also applies to any conference planned and held by the DOJ, including 

conferences funded by the COPS Office, but conducted by an outside entity through the use of a 

contract or a cooperative agreement. For purposes of this requirement, a conference is defined as a: 

meeting, retreat, seminar, symposium, event, or training activity. 

To comply with the reporting requirement, the COPS Office must collect quarterly data from outside 

entities that planned and held conferences on its behalf. The deadline for the COPS Office to report this 

data is 45 days after the end of each fiscal quarter. Therefore, if you conduct any conference activities 

that fall under these reporting requirements, please complete and submit the Conference Reporting 

Template no later than 30 days after the end of the quarter to your COPS Program Manager. The 

reporting deadlines for any relevant conference activity data to be submitted to the COPS Office are 

October 31, January 31, April 30, and July 31. These reporting requirements must be done during your 

entire award period, but you only need to report each event once.
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The template for this report can be found in Appendix E, “Conference Reporting Requirements,” and an 

electronic version can be obtained from your COPS Program Manager. Please complete the shaded and 

non-shaded fields on this template.

While registration fees do not need to be reported on the Conference Reporting Template, registration 

fees or any other revenue that is generated as a result of a COPS-funded activity under this award may 

need to be reported as program income on the quarterly Federal Financial Report (SF-425). For more 

information on what constitutes program income, please contact your COPS Program Manager.

19. Submit all approved indirect cost rates, if applicable, 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 Awardee 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 Awardee drew down excess COPS funding for indirect costs, the Awardee must 

return the overpayment to the COPS Office. If the Awardee incurred additional indirect costs, the Awardee may 

request a budget modification if the award is still open and award funds are available. If the Awardee returns 

or draws down COPS funding, the Awardee will submit a revised final Federal Financial Report (SF-425). 

The Awardee 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 grant rules set out in 

the Office of Management and Budget (OMB) Circulars and regulations:

1. $25,000 Subcontract/Subaward Limitation: For Educational Institutions and Non-Profit Organizations, 

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. (2 C.F.R. 

Part 220 (Educational Institutions, formerly Circular A-21), Appendix A, G(2) and 2 C.F.R. Part 230 (Non-Profit 

Organizations, formerly Circular A-122), Appendix A, D(3)(f ).)

2. Participant Support Costs: For Non-Profit Organizations, in accordance with 2 C.F.R. Part 230, Appendix 

A, D(2)(C), participant support costs are generally excluded from the distribution base. “The distribution 

base may be total direct costs (excluding capital expenditures and other distorting items, such as 

major subcontracts or subgrants), direct salaries and wages, or other base which results in an equitable 

distribution. The distribution base shall generally exclude participant support costs as defined in paragraph 

32 of Appendix B {in 2 C.F.R. Part 230}.”

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. This exclusion applies to the entirety of 

any subcontracts for the lodging and travel of conference participants or trainees (but not employees).

Please note that only employees of the Non-Profit Organization are excluded from the definition of 

participant support costs. Costs related to contractors of the Non-Profit Organization 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 follow this link: 

www.ojp.gov/funding/confcost.htm.

Indirect costs were removed from the budget if the Awardee 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.
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Indirect cost rates are federally negotiated and approved rates that are based on audited and 

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

that awardees carefully track and update their indirect cost rates charged against their COPS Office 

award. You must make the COPS Office aware of changes in these approved rates throughout your 

award period. 

Indirect costs were removed from the budget if the Awardee 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 approved rate expires during the award period, a current rate must be submitted to the COPS 

Office in order to recover indirect costs.

If indirect cost rates change during the award period, you must request a budget modification with 

the COPS Office to reflect the changed rates. Please be aware that the COPS Office will not approve 

any modification request that results in an increase in federal funds. In addition, before awards are 

closed the awardee must reconcile any changes between their final approved indirect cost rate and the 

provisional rate and, if necessary, repay the COPS Office for any indirect cost rate overpayment. 

During the award period, you should submit all approved indirect cost rates, provisional and final, to 

your COPS Program Manager within 30 days of receipt. At award closeout, if a provisional indirect cost 

rate is in effect, you may proceed with closeout. After closeout, upon receipt of the final approved 

indirect cost rate, you should complete an expenditure analysis to determine if an adjustment 

is necessary. If you drew down excess COPS Office funding for indirect costs, please return the 

overpayment to the COPS Office and submit a revised FFR (SF-425).

20. Follow the COPS Office Curriculum Standards, Review and Approval Guide and COPS Office Instructor Quality 

Assurance Guide, if developing training curriculum or delivering training under this Cooperative Agreement. A 

copy of these guides will be supplied to you by your COPS Program Manager.

The purpose of the COPS Office Curriculum Standards, Review, and Approval Guide is to support the 

development, review, and approval of COPS-funded courses by supplying training providers with 

recommended instructional guidelines and educating awardees on the process by which curriculum 

will be reviewed and approved by the COPS Office. The COPS Office will utilize the ADDIE Model as a 

process to standardize the development, delivery, and evaluation of training developed by the COPS 

Office training providers. This process will provide the COPS Office with a more effective and efficient 

verification and validation methodology, ensuring the awardees’ capability to develop and deliver 

training that advances and promotes the practice of community policing. 

The ADDIE Model is an industry standard for curriculum development. This instructional design process 

will be used as the foundation for developing curriculum for the COPS Office training. The design 

process includes the following: 

1. Analysis – This is the first stage of the ADDIE and focuses on gathering information on the who for, 

what, where, why, and by whom in preparation for creating curriculum that fills the learning needs of 

students. 

2. Design – This stage of the ADDIE focuses on creating the blueprint for the instructional experience, 

such as the structure of the content and learning materials, etc.

3. Development – This stage of the ADDIE focuses on production—where the plans that are created 

during the design phase become a reality. This phase addresses how the instructional materials will 

be used to support learning and engage students in innovative and productive ways. 

4. Implementation – This stage of the ADDIE tests and deploys the course to determine whether the 

components function as designed within the identified environment (online, classroom, etc.).

5. Evaluation – This stage of the ADDIE ensures that the course functions as designed with actual 

end-users. 
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It is the goal of the COPS Office to maintain the COPS Office training products and services, keeping 

them current, relevant, and applicable through comprehensive updates on community policing 

methodology, tools, and techniques. Awardees are required to adhere to the standards outlined in the 

guidance.

C. Awardee Acknowledgements

This section of the cooperative agreement is similar to the award conditions listed above and notifies you of 

important award requirements.

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. Part 46.101(b)(1-6), the Awardee must meet the 

provisions of the U.S. Department of Justice’s common rule regarding the Protection of Human Subjects, 28 

C.F.R. Part 46, prior to the expenditure of federal funds to perform such activity(ies). The Awardee also agrees 

to comply with 28 C.F.R. Part 22 regarding the safeguarding of individually identifiable information collected 

from research participants.

When conducting research involving human subjects, it is critical that the proper steps be taken to 

provide the appropriate and required protections. Please consult the U.S. Department of Justice’s 

common rule regarding human subjects research risk protections, 28 C.F.R. Part 46 and 28 C.F.R. Part 22, 

to ensure that you comply with these research requirements. If applicable, also follow any requirements 

or processes governing your organization’s institutional review board (IRB) that approves, monitors, and 

reviews your research involving human subjects. 

For more information, please refer to Award Condition #20 on page 16 for a complete description of 

Human Subjects Research requirements.

2. Implementation of this award shall be subject to federal monitoring, auditing, and/or evaluation and/or a 

Single Audit Act audit (see OMB Circular A-133) and the Awardee agrees to cooperate with such activities by 

providing access to and copies of, as appropriate, all project-related records, documents, and personnel. If the 

Awardee is a for-profit organization, the Uniform Administrative Requirements 28 C.F.R. § 70.26(d) states that, 

“Commercial organizations must follow the audit threshold in revised OMB Circular A-133 in determining 

whether to conduct an audit in accordance with Government Auditing Standards.”

For more information, please refer to Section VI, “Federal Audit Requirements,” in this manual. 

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 funding.

For more information, please refer to Award Condition #10 on page 10 on Grant Monitoring Activities, 

Award Condition #22 on page 18 on Additional High-Risk Grantee Requirements, and the paragraph on 

page 23, “What are the specific rules regarding termination of award funding?”

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

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

Federal Government.

For more information, please refer to Award Condition #16 on page 14 for a complete description of 

false statements requirements.
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D. Specific Requirements

This section of the cooperative agreement will specify tasks that awardees agree to fulfill during the stated 

timeframes including addressing peer reviewer and the COPS Office staff comments to deliverables 

and producing an executive summary document for each publication developed under the award. Any 

proposed changes to these tasks must be submitted to the COPS Program Manager for approval. 

E. Performance Time Line and Deliverables

A performance time line for all deliverables which are considered to be significant in the performance of 

the cooperative agreement and due dates based upon the award start date will be listed in this section. 

One electronic copy of the deliverable items must be delivered to the COPS Program Manager in 

accordance with the agreed upon schedule in the cooperative agreement. 

F. Financial Status Reports

The Awardee will provide quarterly reports of project activity and expenditures. Specifically, the Awardee 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 grant period. Awardees must submit the quarterly SF-425 online. Visit the 

COPS Office website at www.cops.usdoj.gov and select the “Account Access” link in the upper right corner to login, 

complete, and submit reports online. 

For more information, please refer to Award Condition #9 on page 10 and Section VII, “Reports,” of this 

manual for a complete description of reporting requirements.

G. Programmatic Progress Reports

The Awardee will provide periodic progress reports detailing project activity. Specifically, the Awardee 

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 awardee will also submit a final progress report to the COPS Office within 90 days of 

the end of the award period.

For more information, please refer to Award Condition #9 on page 10 and Section VII, “Reports,” of this 

manual for a complete description of reporting requirements.

IV. Period of Performance

This section specifies the cooperative agreement period of performance (start and end dates).

V. Financial Administration

A. Funding

The total amount of federal funding to be provided under the cooperative agreement is stated on the Award 

Document, award congratulatory letter, and official Financial Clearance Memorandum (FCM).
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B. Travel

All travel plans related to the cooperative agreement and to the development of the deliverables should be 

submitted to the COPS Program Manager for review by the COPS Office.

1. If the Awardee is subject to Circular A-21 Cost Principles for Educational Institutions; Circular A-87 Cost Principles 

for State, Local and Indian Tribal Governments; or Circular A-122 Cost Principles for Non-Profit Organizations, 

then travel costs that are incurred directly by the Awardee or for project-related non-Awardee travel will be 

reimbursed based upon the awardee’s written institutional travel policy if the costs are reasonable and allocable 

to the project. In the absence of an acceptable institutional travel policy, allowable per diem travel costs for 

lodging, meals, and incidentals will be reimbursed based on the established GSA per diem rates for the relevant 

geographic area. Allowable airfare travel costs will be reimbursed based upon the 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. 

2. If the Awardee is subject to FAR-31.2, Contracts with Commercial Organizations, then travel costs that are 

incurred directly by the Awardee will be reimbursed if the costs are reasonable and allowable under the 

project. Travel costs for lodging, meals, and incidental expenses may be reimbursed based on per diem, 

actual expenses, or a combination of these methods, as long as the reimbursement rate does not exceed 

established GSA per diem rates as set forth in the Federal Travel Regulation. Transportation costs may be 

reimbursed based on mileage rates, actual costs incurred, or on a combination of these methods. Allowable 

airfare travel costs will be reimbursed based upon standard coach fare, unless otherwise authorized in 

advance by the COPS Office.

Depending on the status and type of the awardee organization, different circulars and requirements 

govern your travel expenses. Please consult the appropriate circular governing your organization type. In all 

instances, costs must be reasonable and directly support project objectives and goals. For more information 

on the GSA lodging/per diem rates, please visit www.gsa.gov/perdiem.

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 $550 per day. For consultant or contractor rates 

which exceed $550 per day, the COPS Office requires written justification if the consultants or contractors are hired 

through a noncompetitive bidding process. 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. 

For more information, please refer to Appendix F, “Consultant/Contractor Rate Information Sheet,” in 

this manual.

D. Project Budget

The approved project budget is incorporated herein and made a part of this Cooperative Agreement. Reallocation 

between approved budget categories is allowed up to 10 percent of the total award amount as last approved by 

the COPS Office, providing there is no change in project scope. When the cumulative changes exceed 10 percent of 

the total award amount or change the scope of the project, prior written approval from the COPS Office is required. 

The awardee must promptly notify the COPS Office in writing of events or proposed changes in excess of 10 

percent of the total award amount and must obtain written approval from the COPS Office for the changes before 

incurring the proposed costs. In requesting an adjustment, the Awardee will set forth the reasons and the basis for 

the proposed change and any other information deemed helpful for review by the COPS Office.
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The COPS Office realizes that agencies may need to reprogram award funds during the project award period. 

Reprogrammed funds must be within the scope of the original intent of the cooperative agreement. Your 

agency may reprogram its budget up to an aggregate of 10 percent of the total project cost without prior 

written approval from the COPS Office. However, you should notify your COPS Program Manager of any 

reprogramming that falls below the 10 percent threshold as well. Once the reprogramming of funds totals 

an aggregate of 10 percent or more of the award, your agency must seek written approval from the COPS 

Office for any additional budget modification requests. Refrain from obligating or purchasing any of the 

requested items or services until the reprogramming request is approved by the COPS Office. Please be 

advised that reprogramming requests for unallowable costs will not be approved. 

For more information, please refer to Award Condition #7 on page 9 for a complete description of 

modifications requirements.

E. Payment

All costs claimed for reimbursement, and payment, including the final payment, shall be submitted via the Grant 

Payment Request System (GPRS).

For more information, please see Section IV, “Accessing Award Funds,” in this manual. 

F. No-Cost Extensions of Time

Awardee 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 grant 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. 

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

a no-cost extension is needed. Requests to extend the award period must be received by the COPS Office 

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

award may result in the immediate deobligation of any remaining award funds. Extension requests must be 

received prior to the end date of the award. Under federal regulations, requests to extend the award period 

require prior written approval from the COPS Office. Without an approved extension, your funding will stop 

automatically at the end of the original award period. 

For more information, please refer to Award Condition #6 on page 8 for a complete description of extensions 

requirements.

G. Employment

Awardee acknowledges that nothing in this Cooperative Agreement shall be construed to create an employment 

relationship with the COPS Office or with the federal government or to require provision of any benefits incident to 

employment.

The cooperative agreement does not create an employment relationship with the COPS Office. 

VI. Program Managers

The contact information for the COPS Program Manager and the awardee project/program manager will be 

listed in the cooperative agreement including name, title, organization, telephone, and e-mail address. These 

program/project managers have the authority to propose and approve any modifications to the cooperative 

agreement for their respective organizations.
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VII. General Provisions

The Awardee of record must follow all requirements imposed by the Department of Justice as an award term, 

condition, or administrative requirement of the grant, including but not limited to: the COPS Community Policing 

Development Program Award Owner’s Manual; the Assurances and Certifications; the COPS statute (42 U.S.C. 

3796dd et seq.); 28 C.F.R. Part 66 or 28 C.F.R. Part 70 as applicable (governing administrative requirements for grants 

and cooperative agreements); 2 C.F.R. Part 225 (OMB Circular A-87), 2 C.F.R. Part 220 (OMB Circular A-21), 2 C.F.R. 

Part 230 (OMB Circular A-122) and 48 C.F.R. Part 31.000 et seq. (FAR 31.2) as applicable (governing cost principles); 

OMB Circular A-133 (governing audits); the current edition of the COPS Grant Monitoring Standards and 

Guidelines; the COPS Office Editorial and Graphics Style Manual; and all other applicable program requirements, 

laws, orders, regulations, or circulars. 

The terms, conditions, and requirements listed in the above section are mandatory and must be met and 

satisfied.

Pursuant to Executive Order 13513, “Federal Leadership on Reducing Text Messaging While Driving,” the COPS Office 

encourages recipients of 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.

To improve safety on roads and highways, recipients of federal assistance are encouraged to adopt and 

enforce policies that ban text messaging while driving.

VIII. Modifications

The designated COPS Office and Awardee project officers (under Sections VI (A) and VI (B)) for their respective 

organizations shall 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 shall become effective upon approval by both parties. 

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 Program Manager of any reprogramming that falls below the 10 percent threshold as well. Once 

the reprogramming of funds totals an aggregate of 10 percent or more of the award, your agency must 

seek written approval from the COPS Office for any additional budget modification requests. For more 

information, please refer to Award Condition #7 on page 9 for a complete description of modifications 

requirements.
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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 signed the Award Document.

Joshua Ederheimer, Acting 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]

For the 2013 Community Policing Development Program, the cooperative agreement between the awardee 

and the COPS Office is incorporated by reference into the Award Document and is part of the Award 

Document. By signing the Award Document, the awardee has entered into the cooperative agreement with 

the COPS Office and agrees to abide by all the requirements in the cooperative agreement. The cooperative 

agreement becomes effective on the date that the last responsible party (e.g., Law Enforcement Executive, 

Program Official, Government Executive, or Financial Official) signs the Award Document.
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III. PROCUREMENT PROCESS

In general, award 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, 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 28 C.F.R. § 66.36 and 28 C.F.R. § 70.40 et seq. 

(as applicable).

As described in Award Condition #13 on page 13, awardees are required to submit a sole source justification 

(SSJ) request if a competitive bidding will not be possible and the threshold of $100,000 for goods or 

services to be procured through a sole source is met. The COPS Office will review your request and 

supporting information to determine whether an exception can be awarded to the general rule of open 

competition. Written approval from the COPS Office for the use of a sole source must be received prior to 

purchasing items or services, obligating funding for a contract, or entering into a contract with award funds. 

All awardees are expected to review and abide by 28 C.F.R. Parts 66 and 70, as applicable, in determining if an 

SSJ must be completed. Please contact your COPS Program Manager at 800-421-6770 for further assistance 

with this federal regulation.

A sole source justification request should be submitted if an award recipient determines that the award of a 

contract through a competitive process is infeasible, and if one or more of the following circumstances apply:

•	 The item (or group of items) or service is available only from one source

•	 The public exigency or emergency for the item/service will not permit a delay resulting from 

competitive solicitation

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

What documentation must be submitted to the COPS Office for sole 

source approval?

Requests for sole source procurements of equipment, technology, or services in excess of $100,000 must be 

submitted to the COPS Office in writing, confirming that the award of the contract through full and open 

competition is infeasible. Please note that a justification must be submitted for each vendor providing goods 

or services in excess of $100,000.

To ensure that all of the necessary information is included and submitted to the COPS Office, the following 

checklist can be used when preparing your agency’s sole source request:

Letterhead – The sole source request must be signed by an authorized representative and submitted on 

awardee department letterhead, and must include the agency ORI and the award number for which the 

approval is being sought. The request should also include the following information:

Section I. Description of Project

A brief description of the project, the amount to be designated for the sole source procurement, and the 

purpose of the contract.

Section II. Reason for Request

1. An explanation as to why full and open competition is infeasible (e.g., why it is necessary to contract in a 

noncompetitive manner), and
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2. Which one (or more) of the three required categories identified below applies to the requested sole 

source procurement transaction(s).

— The item/service is available only from one source

— The public exigency or emergency for the requirement will not permit a delay resulting from 

competitive solicitation

— Competition is determined inadequate after solicitation of a number of sources

Section III. Supporting Documentation

The information below should support the applicable category(ies) identified in Section II.

1. If the item/service is available only from one source, please include the following:

— Uniqueness of items/services to be procured from the proposed contractor or vendor 

(compatibility, patent issues, etc.)

— How the agency determined that the item/service is only available from one source (e.g., market 

survey results, independent agency research, patented or proprietary system)

— Explanation of need for contractor’s expertise linked to the current project (e.g., knowledge of 

project management, responsiveness, experience of contractor personnel, prior work on earlier 

phases of project)

— Any additional information that would support the case

2. If the public exigency or emergency for the requirement will not permit a delay resulting from 

competitive solicitation, please include the following:

— Explanation of the specific public emergency

— Impact on project if deadline/dates are not met

— When the contractual coverage is required by your department and why

— Any additional information that would support the case

3. If competition is determined inadequate after solicitation of a number of sources, please include the 

following:

— Results of a market survey to determine competition availability (if no survey is conducted, please 

explain why not)

— Any additional information that would support the case

Section IV. Best Interest Statement

A statement declaring 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 documentation is 

required. The COPS Office will notify your agency in writing after completion of the review.

Please be advised that conflicts of interest are prohibited under the procurement standards set forth in 28 

C.F.R. § 66.36 and 28 C.F.R. § 70.40 et seq.
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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 method of payment available for accessing federal grant funds—the Grant Payment 

Request System (GPRS). GPRS is a web-based system that enables awardees to use a secure Internet 

connection to request funds. Approved payment requests will automatically be scheduled for payment by 

the U.S. Treasury Department. An awardee will be able to review previous requests made since 2007. For 

more information on the GPRS please go to www.ojp.usdoj.gov/about/offices/ocfogprs.htm to view the 

User Guide.

Setting Up Your Account

How do we set up a GPRS account?

If you are a new awardee to the COPS Office, your law enforcement executive and/ or government executive 

should receive notification about GPRS shortly after the COPS Office receives your signed Award Document. 

This notification will contain all of the information that your agency needs to set up the GPRS payment 

method. If your law enforcement executive and/or government executive do not perform drawdown 

requests for your agency, your award administrator will need to go online to https://grants.ojp.usdoj.gov/

gprs/login to log in and register to become a Drawdown Specialist. You will receive, via e-mail, 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 information provided by the Drawdown Specialist.

If you are already registered in GPRS and would like to add a newly awarded cooperative 

agreement award to the existing username, contact the COPS GPRS Registration Team via e-mail at 

COPSGPRSRegistration@usdoj.gov and provide the following information:

•	 User name

•	 First/Last name

•	 Vendor Number

•	 Grant /Award number (s) to be added

How do we fill out the payment enrollment forms?

If you are a new awardee to the COPS Office, your agency will need to complete an Automated Clearing 

House (ACH) Vendor/Miscellaneous Payment (SF-3881) enrollment form. This form can be found on the 

COPS Office website at the following address: www.cops.usdoj.gov/Default.asp?Item=100.

Prior to accessing your award funds, your agency must mail the original form to:

Office of Justice Programs

Office of the Chief Financial Officer 

810 7th Street NW

Washington, DC 20531

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.
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If you are already a COPS Office awardee, you should already have filled out an ACH enrollment form. 

Therefore, your agency will not be required to submit a new ACH enrollment form for the newly awarded 

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.

When should Federal Financial Reports be filed?

After your agency returns the signed Award Document to the COPS Office, under current regulations, you 

are required to submit quarterly Federal Financial Reports (FFRs) using a Standard Form 425 (SF-425). This 

report reflects the actual monies spent and unliquidated obligations incurred by your agency. You will not 

be able to make drawdowns from your award account if the SF-425 for the most recent reporting quarter 

is not on file with the COPS Office by the deadline date. Awardees are encouraged to submit their SF-425 

reports via the Internet at www.cops.usdoj.gov.

For more information on how to complete and where to submit your quarterly SF-425, see Section VII of this 

Award Owner’s Manual titled “Reports.”

Filing the FFR (SF-425) identifies your federal and local expenditures made during that calendar quarter. 

However, to receive actual payment, you must request it through GPRS.

Additional Payment Questions

Can we receive advances?

Yes. If you receive funds through electronic transfer, the period allowed is 10 days in advance. In general, the 

concept of “minimum cash on hand” applies to COPS Office 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.

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 

awardee:

•	 Is unwilling or unable to attain project goals

•	 Maintains excess cash on hand

•	 Does not adhere to the terms and conditions of the award

•	 Fails to submit reliable and/or timely reports

How often do we request reimbursement of costs?

There are no limitations on how often your agency may request reimbursements. However, reimbursement 

is only for costs that were approved in the Financial Clearance Memorandum. 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.
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Can we earn interest on our award funds?

Your agency should minimize the time between your draw down of award 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:

•	 Local units of government may keep interest earned on all advances of federal funds up to $100 per 

federal fiscal year in the aggregate. Interest earned in excess of $100 must be remitted promptly, but at 

least quarterly, to the U.S. Department of Health and Human Services, Payment Management Systems, 

P.O. Box 6021, Rockville, MD 20852.

•	 Except as provided in 28 C.F.R. Part 70.22(l), nonprofit organizations may keep interest earned on all 

advances of federal funds up to $250 per federal fiscal year in the aggregate. Interest earned in excess 

of $250 must be remitted annually to the U.S. Department of Health and Human Services, Payment 

Management Systems, P.O. Box 6021, Rockville, MD 20852.

•	 Please notify the COPS Office Finance Division when any interest that is earned is remitted to 

Department of Health and Human Services (HHS), Payment Management Systems, P.O. Box 6021, 

Rockville, MD 20852. After a check for the interest is remitted to HHS, please send a copy to the COPS 

Office Finance Division.

•	 State governments, including any agency or instrumentality of a state, should follow the provisions of 

the Intergovernmental Cooperation Act (31 U.S.C. 6501 et. seq.) pertaining to the disposition of interest 

earned on federal funds.

Matching Funds

Under the COPS Community Policing Development 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.
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V. FINANCIAL RECORD MAINTENANCE

Under the COPS CPD 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.

Your accounting system should:

•	 Present and itemize actual expenditures of funded items

•	 Demonstrate that funds are spent in compliance with your award conditions

•	 Be able to provide the necessary information for periodic financial review and audit

What records must be kept?

Your agency’s fiscal control and accounting systems should enable you to make accurate, current, and 

complete disclosure of the financial activity under your CPD 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 documents be kept?

All financial records, including payroll, time and attendance records, canceled checks, purchase orders, and 

similar documents associated with your CPD award should be kept for at least three years from the date the 

COPS Office officially closes the award. 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.

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 DOJ, 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.

Records must be kept for at least three years from the date that the COPS Office has officially closed 

your agency’s award.
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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 Department of Justice (DOJ) 

Office of the Inspector General (OIG) audits.

Requirements and Audits

What are the regulations governing SAA requirements?

The Single Audit Act of 1984 established uniform guidelines for state and local governments receiving 

federal financial assistance. The 1984 Act was amended in July 1996 and revised again June 27, 2003, and 

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 Circular A-1 33 (OMB A-1 33), Audits of 

States, Local Governments and Non-Profit Organizations, provides additional guidelines regarding the 

implementation of SAA requirements.

Who must have an SAA audit?

Each non-federal entity that expends a total amount of federal awards equal to or in excess of $500,000 in 

a fiscal year is required to have a Single Audit conducted, except when it elects to have a program-specific 

audit conducted. An auditee may be a recipient, a subrecipient, and/or a vendor. Specifically, “Federal awards 

expended as a recipient or a subrecipient would be subject to an audit under A-133, Subpart B, Section 210.” 

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 awardee’s financial statements, internal controls, major and non-major 

award programs, and compliance with government laws and regulations. Single Audits may also address 

specific compliance issues with respect to the COPS Office award requirements.

Failure to have an audit performed may result in sanctions imposed by federal agencies for noncompliance 

with Circular A-133. These sanctions could include withholding part of your federal award until a required 

audit is completed satisfactorily, withholding or disallowing overhead costs, suspending your award until the 

audit is performed, or terminating your award.

Your Single Audit Act reports should not be sent to the COPS Office. If the U.S. Department of Justice is 

your Cognizant Federal Agency (see Section X, “Glossary of Terms”), they should be sent to the Federal Audit 

Clearinghouse at:

Federal Audit Clearinghouse 

Bureau of Census

1201 E. 10th Street

Jeffersonville, IN 47132

The U.S. Department of Justice, Office of Justice Programs (OJP) serves as the liaison between awardees and 

auditors in the conduct of SAA audits. Questions and comments regarding SAA audits may be directed to 

the COPS Office Response Center at 800-421-6770.

What is the role of the Office of the Inspector General (OIG)?

The OIG is a separate component of the U.S. Department of Justice and is independent of the COPS 

Office. The primary objective of OIG audits is to assess compliance with award conditions. OIG audits are 

designed to promote economy, efficiency, and effectiveness in the administration of awards by evaluating 

compliance with laws, regulations, policies, and procedures governing the operations encompassed in the 

scope of the audit.
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How are COPS Office awards selected for an OIG audit?

The OIG may conduct a COPS Office award audit in response to a referral that the OIG believes warrants 

further evaluation. The OIG also surveys DOJ agencies on an annual basis to solicit input on suggested audit 

areas for the upcoming fiscal year. In most instances, however, the OIG selects awards based on a number of 

factors, including the geographical distribution of awards awarded, award amount, population served, and 

type of award (both active and expired). As such, the fact that your award has been selected for an OIG audit 

is not necessarily indicative of a suspected concern or problem area.

The COPS Grant Monitoring Division serves as the liaison between awardees and the OIG’s Audit Division, 

which conducts the audit. After the OIG notifies the COPS Office of upcoming audits to be conducted, the 

COPS Grant Monitoring Division will send out a notification letter to the awardee outlining the scope of each 

audit and the anticipated audit timeframe. This notification letter also advises awardees of the supporting 

documentation required and information necessary for the OIG during their scheduled field work, and 

provides a COPS Office point of contact to address questions and concerns. If you have any questions 

regarding an OIG audit, please contact the COPS Grant Monitoring Division at 800-421-6770. Questions and 

comments regarding the administration of your COPS CPD award, not specifically related to an audit, should 

be referred to your COPS Program Manager.

Typical Audit Findings

The OIG has typically reported the following audit findings pertaining to awards as a result of lack of proper 

documentation, poor business practices, or inadequate accounting and record keeping systems:

•	 Unallowable costs – Awardee incurred costs that were not approved in the original budget, 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, or 

award expenditures were in excess of actual award costs.

•	 Lack of complete/timely programmatic and financial reporting – Awardee failed to submit 

required programmatic and financial reports in a timely manner and/or had inadequate record keeping 

systems.

•	 Supplanting – Awardee could not document efforts to backfill vacant positions and/or awardee could 

not explain reductions in local law enforcement budget during the award period.

•	 Funds to better use – Funds could be used more efficiently based on management actions such as: 

a) reductions in outlays; b) deobligation of funds; c) withdrawal; d) costs not incurred by implementing 

recommended improvements; or e) any other savings which are specifically identified.

•	 Questioned costs – Costs that are questioned by the auditor because of an audit finding which 

resulted from a violation or possible violation of a provision of law, regulation, 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.

After the final OIG audit report has been issued, the COPS Audit Liaison Division will continue working as 

the liaison between your agency and the OIG to obtain closure on any audit findings. The COPS Office 

will issue a closure letter once all audit recommendations have been closed by the OIG. You must keep all 

documentation related to the audit for a period of three years following the audit’s closure.
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VII. REPORTS

As part of the CPD Program, your agency will be required to submit quarterly Federal Financial Reports as 

well as program progress reports. Awarded agencies should be prepared to track and report CPD Program 

award funding separately from other funding sources (including other COPS Office and federal grants and 

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 CPD Program funding 

and ensure that its use is consistent with the award terms and conditions. Good practices in this area 

would include written accounting practices, an accounting system that tracks all drawdowns and award 

expenditures, and the ability to track when award-funded positions are filled and/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 award funding or other remedial actions.

Federal Financial Reports

Your agency is required to submit quarterly Federal Financial Reports (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 monies spent, unliquidated obligations 

incurred, and any unobligated balance of federal funds.

How do we file Federal Financial Reports?

All COPS Office awardees are required to submit quarterly FFRs using the SF-425.

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 below:

Reporting Quarters SF-425 Due Date

January 1 – March 31 April 30

April 1 – June 30 July 30

July 1 – September 30 October 30

October 1 – December 31 January 30

Awardees are strongly encouraged to submit the quarterly SF-425 online. Visit the COPS Office website at 

www.cops.usdoj.gov and select the Account Access link in the upper right corner to log in, complete, and 

submit reports online. The online SF-425 requires the same reporting information as the paper version. 

The use of this online application enables authorized users to view past SF-425s, and allows them to file or 

amend the SF-425 for the current quarter.

For your first SF-425 submission, determine when the most recent SF-425 reporting quarter ended and 

complete an SF-425 to cover the period from the award start date of your award to that particular end date. 

You are required to submit an SF-425 even if you have not spent any money or incurred any costs during a 

reporting period. The due dates for online filing of SF-425s are the same as for the submission of paper copies.

Example:

If your award start date is 02-01-13 and the current date is 04-15-13, then your first SF-425 would be due no 

later than 04-30-13 and would cover the period 02-01-13 (award start date) through 03-31-13 (end of the 

most recent reporting quarter). This SF-425 must be on file with the COPS Office so that you can successfully 

complete a drawdown of funds through GPRS.
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Awardees who do not submit SF-425s by the due date will be unable to draw down funds. The payment 

system contains a function which checks for SF-425 delinquency and will reject a drawdown attempt if the 

SF-425 is not up to date. Subsequent e-mail, fax, and/or hard copy reminders may be sent to the awardee if 

the SF-425 is delinquent.

For general information concerning online filing of SF-425 reports, go to www.cops.usdoj.gov/Default.

asp?Item=740 or contact the COPS Office Response Center by phone at 800-421-6770 or by e-mail at 

AskCopsRC@usdoj.gov.

If you need assistance in completing the SF-425, please contact the COPS Office Response Center at 800-

421-6770, 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/Publications/SF-425_HelpfulHints_2-4b.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, office based award reviews, meetings, telephone contacts, reports, audits, reviews of award change 

requests, and special request submissions.

Program Progress Reports

Program progress reports and a final closeout report will be required as requested by the COPS Office during 

the life of the award. The COPS Office will notify the agency when the progress report is due and provide 

instructions for submission. The report must be submitted online by the awardee agency’s representative.

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.

Do we need to request a progress report?

No. The COPS Office will contact your agency when progress reports are being requested. A notification 

for submitting your Program Progress Report to the COPS Office will be sent in January/April/July/October, 

covering activities for the preceding calendar quarter. Notification for submitting your final Program Progress 

Report will be sent to your agency in the month following your grant end date. 

How do we file progress reports? 

All awardees will be required to submit their COPS Office progress reports through the COPS Office Account 

Access site at www.cops.usdoj.gov. 

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.

Will the data that I submit be publicly available? 

Reports submitted to the COPS Office may be reported publicly in response to a Freedom of Information 

Act request. 

How can I complete a COPS Office progress report online? 

Please access the COPS Office website at www.cops.usdoj.gov and click on Account Access at the top righthand 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.
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If you do not have login access, you should contact your agency portal administrator to set up an account 

for you. 

If you have a registered account, but do not remember your password you may reset your password by 

going to the agency portal homepage, in Account Access enter your e-mail address, click on the “Forgot 

Password” link. For additional assistance, you may contact the COPS Office Response Center by phone at 

800-421-6770 or send an e-mail to AskCopsRC@usdoj.gov.

How do I obtain access to complete the COPS Office progress report? 

If you do not have your user name and/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 e-mail 

the Response Center at AskCopsRC@usdoj.gov. 

What if I make a mistake or need to modify my progress report after it is submitted? 

Awardees 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 Progress Report Team at 800-659-7379. 

Contact Points to Obtain Technical Assistance and Report Violations 

Any alleged violations, serious irregularities, or acts that may result in the use of public funds in a manner 

inconsistent with the Public Safety Partnership and Community Policing Act of 1994 or the purposes of 

this grant may be reported to the U.S. Department of Justice. Furthermore, the COPS Office welcomes 

the opportunity to provide assistance regarding the implementation of grant provisions to help ensure 

that federal grant funds are spent responsibly. As such, the following contacts are provided to address 

noncompliance and technical assistance issues:

•	 If you suspect violations of a criminal nature, please contact the U.S. Department of Justice, Office 

of the Inspector General (OIG) at OIG.hotline@usdoj.gov, www.justice.gov/oig/FOIA/hotline.htm or 

800-869-4499.

•	 If you suspect grant violations (not criminal in nature) related to the grant conditions listed in this 

manual, please contact the COPS Grant Monitoring Division at 202-514-9202.

•	 If you have any questions and/or need assistance regarding your grant, please contact your COPS Grant 

Program Specialist at 800-421-6770.
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VIII. WHEN THE AWARD PERIOD HAS ENDED

At the end of your agency’s Community Policing Development 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 and 

any applicable final program reports.

Final Federal Financial Report (SF-425)

The final FFR (SF-425) for your award is due to the COPS Office no later than 90 days after the end of the award 

period. The final report should reflect the total amount of federal expenditures and the amount of unobligated 

funds, if any. Additionally, it should reconcile with the amount of funds drawn down by your agency.

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 funds obligated.

Please be advised that 28 C.F.R. Part 66.50(c) requires awardees to submit final Federal Financial Reports (SF-425) 

and 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 excess award funds remaining in your account following the award 

period due to an overestimate of item costs during the award 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 excess unobligated or unspent funds should remain in your account, and will 

be deobligated during the closeout process.

Final Program Progress (Closeout) Report

After your 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.

Equipment Disposition

Each awardee 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 awardee. 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:
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•	 Items of equipment with a current per-unit fair market value of less than $5,000 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 shall have a right to an amount calculated by multiplying the current 

market value or proceeds from sale by the awarding agency’s share of the equipment.

For more information, please see 28 C.F.R. § 66.32 and 28 C.F.R. § 70.34, as applicable.

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 CPD 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 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 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.

X. GLOSSARY OF TERMS

Allowable Costs

Allowable costs are expenses that may be funded by this grant program. The COPS CPD 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) that was 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: (a) compliance with laws and regulations; (b) 

economy and efficiency of operations; (c) effectiveness in achieving program results; and (d) 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 grant 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. 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 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 grant Award Document. Awardees 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.
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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 CPD Program award is 16.710.

Closeout 

This is the process in which the awarding agency, the COPS Office, determines that all applicable 

administrative actions and all required work and conditions of the award have been completed and met 

by the recipient and awarding agency.

Cognizant Federal Agency

Your Cognizant Federal Agency is generally the federal agency that provides your agency with the most 

federal money. The Office of Management and Budget (OMB) may have already assigned your Cognizant 

Federal Agency to you. If this is the first federal award that your organization has received, the U.S. 

Department of Justice (DOJ) is your Cognizant Federal Agency. 

Community Policing

Community policing is a philosophy that promotes organizational strategies, which 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 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 grant. To identify your staff accountant, please call the 

COPS Office Response Center at 800-421-6770, or visit the COPS Office website at www.cops.usdoj.gov.

COPS Office

The Office of Community Oriented Policing Services (COPS Office) is the division within the U.S. 

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 Program Manager

COPS Program Managers are trained to assist you with implementing and maintaining your Community 

Policing Development 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 Program Manager is provided on the award congratulatory letter and 

available by contacting the COPS Office Response Center at 800-421-6770.
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Data Universal Numbering System (DUNS) Number 

Since FY2004, the Office of Management and Budget (OMB) has required all agencies applying for federal funding 

to obtain this number prior to application. The DUNS number is a unique nine- or thirteen-digit identification 

number that is assigned upon request to agencies by Dun & Bradstreet (D&B). This number will be used by 

the federal government to better track grant recipient information throughout the grant cycle and to provide 

consistent name and address data for electronic grant application systems. To obtain a DUNS number, visit the 

Dun & Bradstreet website at www.dnb.com or call 866-705-5711.

Employer Identification Number (EIN) / OJP Vendor Number 

This number is usually your agency’s nine-digit federal tax identification number as assigned to you by 

the Internal Revenue Service (IRS). Your accounting/bookkeeping department should have this number. 

In some cases, the EIN has been previously assigned to another agency within your jurisdiction. In this 

instance, a new vendor number will be assigned to you by the Office of the Chief Financial Officer. The 

newly assigned number is to be used for COPS Office administrative purposes only and should not be 

used for IRS purposes.

Federally Recognized Tribe

Tribal entities that are recognized and eligible for funding and services from the BIA by virtue of their 

status as Indian Tribes. They are acknowledged to have the immunities and privileges available to other 

federally 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 grant funds. For further information, 

contact: BIA, Division of Tribal Government Services, MS-4631 – MIB, 1849 C Street NW, Washington, DC 

20240, 202-208-2475. 

Grant Monitoring Specialist

COPS Grant Monitoring Specialists are trained and available to assist you in addressing any compliancerelated questions regarding your award. Grant Monitoring Specialists plan and conduct site visits and officebased 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.

Grant/Award Number

The award number identifies your agency’s specific Community Policing Development 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 following format: 2013-CKWX-0000 for grants 

awarded in FY2013. The COPS Office tracks award information based upon this number.

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/her designated official. For the awardee, award funds are obligated when monies are 

spent or orders are placed for purchasing approved technology or services under your Community 

Policing Development 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).
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Originating Agency Identifier (ORI) Number 

This number is assigned by the FBI, and it is your agency’s unique identifier. The first two letters are your 

state abbreviation, the next three numbers are your county’s code, and the final two numbers identify 

your jurisdiction within your county. If your agency does not have an ORI number assigned by the FBI, 

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

digits 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 (and/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, and/or investigation of 

violations of criminal laws within its jurisdiction.

The Public Safety Partnership and Community Policing Act of 1994

The COPS Office is charged with fulfilling the mandates of this law. The purposes of the law are to:

•	 Increase the number of community policing officers on the beat

•	 Provide additional and more effective training to law enforcement officers to enhance their problemsolving, service, and other skills needed in interacting with members of the community

•	 Encourage the development and implementation of innovative programs to permit members of the 

community to assist law enforcement agencies in the prevention of crime

•	 Encourage the development of new technologies to assist law enforcement agencies in reorienting the 

emphasis of their activities from reacting to crime to preventing crime.

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 Community Policing Development 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 and/or local funds, or 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 Award Condition 

#5 on page 8 in this manual.
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XI. APPENDIXES

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 (C.F.R.)/Office of Management and Budget (OMB):

4 C.F.R. Parts 101-105, Department of Justice/Government Accountability Office, “Joint Federal Claims 

Collections Standards”

5 C.F.R. Part 1320, “Controlling the Paperwork Burden on the Public”

5 C.F.R. Part 151, “Political Activities of State and Local Officials or Employees”

28 C.F.R. Part 23, “Criminal Intelligence Systems Operating Policies”

28 C.F.R. Part 61, “Procedures for Implementing the National Environmental Policy Act”

28 C.F.R. Part 66, “Uniform Administrative Requirements for Grants and Cooperative Agreements to State 

and Local Governments”

28 C.F.R. Part 67, “Government-wide Requirements for Drug-Free Workplaces (Grants)”

28 C.F.R. Part 69, “Government-wide New Restrictions on Lobbying”

28 C.F.R. Part 70, “Uniform Administrative Requirements for Grants and Agreements with Institutions of 

Higher Education, Hospitals, and Other Non-Profit Organizations”

31 C.F.R. Part 205, “Treasury Department Regulations Implementing for Cash Management Improvement 

Act of 1990”

2 C.F.R. Part 220 (OMB Circular A-21), “Cost Principles for Educational Institutions”

OMB Circular A-33, “Audits of Educational Institutions”

2 C.F.R. Part 225 (OMB Circular A-87), “Cost Principles for State and Local Governments”

2 C.F.R. Part 230 (OMB Circular A-122), “Cost Principles for Non-Profit Organizations”

OMB Circular A-129, “Managing Federal Credit Programs”

OMB Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations”

48 C.F.R. Part 31.000, et seq. (FAR-31.2), “Cost Principles for Commercial Organizations”

Executive Orders:

Executive Order 12291, “Regulations”

Executive Order 12372, 28 C.F.R. Part 30 “Intergovernmental Review of Federal Programs”

Executive Order 12547, “Non-Procurement Debarments and Suspension”
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Appendix B – Assurances and Certifications

Assurances

Several provisions of federal law and policy apply to all grant programs. The Office of Community Oriented 

Policing Services 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 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 grant funds. In particular, the applicant assures 

us that: 

1. It has been legally and officially authorized by the appropriate governing body (for example, mayor or city 

council) to apply for this grant 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 grantee 

employees whose principal employment is in connection with an activity financed in whole or in part 

with this grant. 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 Federal Fair Labor Standards 

Act, 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. 

5. It will give the Department of Justice or the Comptroller General access to and the right to examine 

records and documents related to the grant. 

6. It will comply with all requirements imposed by the Department of Justice as a condition or 

administrative requirement of the grant, including but not limited to: the requirements of 28 C.F.R. Part 

66 and 28 C.F.R. Part 70 (governing administrative requirements for grants and cooperative agreements); 

2 C.F.R. Part 225 (OMB Circular A-87), 2 C.F.R. Part 220 (OMB Circular A-21), 2 C.F.R. Part 230 (OMB Circular 

A-122) and 48 C.F.R. Part 31.000, et seq. (FAR 31) (governing cost principles); OMB Circular A-133 

(governing audits) and other applicable OMB circulars; the applicable provisions of the Omnibus Crime 

Control and Safe Streets Act of 1968, as amended; 28 C.F.R. Part 38.1; the applicable COPS Application 

Guidelines; the applicable COPS Grant Owner’s Manuals; and with all other applicable program 

requirements, laws, orders, regulations, or circulars. 

7. If applicable, 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. 
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8. It will not, on the ground of race, color, religion, national origin, gender, disability or age, unlawfully exclude 

any person from participation in, deny the benefits of or employment to any person, or subject any person 

to discrimination in connection with any programs or activities funded in whole or in part with federal 

funds. These civil rights requirements are found in the non-discrimination provisions of the Omnibus Crime 

Control and Safe Streets Act of 1968, as amended (42 U.S.C. § 3789d); Title VI of the Civil Rights Act of 1964, 

as amended (42 U.S.C. § 2000d); Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794); 

the Age Discrimination Act of 1975 (42 U.S.C. § 6101, et seq.); Title IX of the Education Amendments of 1972, 

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

at 28 C.F.R. Part 42 (subparts C, D, E, G, and I). It will also comply with Executive Order 13279 Equal Treatment 

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

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

A. In the event that any court or administrative agency makes a finding of discrimination on grounds of 

race, color, religion, national origin, gender, disability or age 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, DC 20531. 

B. If your organization has received an award for $500,000 or more and has 50 or more employees, then 

it has to prepare an Equal Employment Opportunity Plan (EEOP) and submit it to the Office for Civil 

Rights (OCR), Office of Justice Programs, 810 7th Street NW, Washington, DC 20531, for review within 

60 days of the notification of the award. If your organization received an award between $25,000 and 

$500,000 and has 50 or more employees, your organization still has to prepare an EEOP, but it does 

not have to submit the EEOP to OCR for review. Instead, your organization has to maintain the EEOP 

on file and make it available for review on request. In addition, your organization has to complete 

Section B of the Certification Form and return it to OCR. If your organization received an award for 

less than $25,000; or if your organization has less than 50 employees, regardless of the amount of the 

award; or if your organization is a medical institution, educational institution, nonprofit organization 

or Indian tribe, then your organization is exempt from the EEOP requirement. However, your 

organization must complete Section A of the Certification Form and return it to OCR. 

9. Pursuant to 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’s (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. 

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. 
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14. Pursuant to Executive Order 13043, it will enforce on-the-job seat belt policies and programs for 

employees when operating agency-owned, rented or personally-owned vehicles. 

15. It will not use COPS funds to supplant (replace) state, local, or Bureau of Indian Affairs funds that 

otherwise would be made available for the purposes of this grant, as applicable. 

16. If the awarded grant contains a retention requirement, it will retain the increased officer staffing level 

and/or the increased officer redeployment level, as applicable, with state or local funds for a minimum of 

12 months following expiration of the grant 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 grant 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 awarded grant does not contain a cost sharing requirement, contribute a nonfederal share) equal to the amount seized in order to fully implement the grant project.

19. None of the funds made available under this award may be distributed to the Association of Community 

Organizations for Reform Now (ACORN) or its subsidiaries.

False statements or claims made in connection with COPS grants (including cooperative agreements) may 

result in fines, imprisonment, disbarment from participating in federal grants 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 grantee entity of its obligations under 

this grant. 

__________________________________________________________ _____________________

Signature of Government Executive/Financial Official 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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Certifications

Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; Federal Taxes and 

Assessments; Drug-Free Workplace Requirements; and Coordination with Affected Agencies.

Although the 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 read the regulations cited below and the instructions for certification included in the regulations 

to understand the requirements and whether they apply to a particular applicant. Signing this form 

complies with certification requirements under 28 C.F.R. Part 69, “New Restrictions on Lobbying,” 2 C.F.R. Part 

2867, “Nonprocurement Debarment and Suspension,” Public Law 111-117 or the most recent applicable 

appropriations Act, 28 C.F.R. Part 83, “Government-Wide Requirements for Drug-Free Workplace (Grants),” and 

the coordination requirements of 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 Department of Justice determines to award the covered grant. 

1. Lobbying 

As required by Section 1352, Title 31 of the U.S. Code, and implemented at 28 C.F.R. Part 69, for persons 

entering into a grant or cooperative agreement over $100,000, as defined at 28 C.F.R. Part 69, the applicant 

certifies that: 

A. No federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, 

to any person for influencing or attempting to influence an officer or employee of any agency, 

a member of Congress, an officer or employee of Congress, or an employee of a member of 

Congress in connection with the making of any federal grant; the entering into of any cooperative 

agreement; and the extension, continuation, renewal, amendment or modification of any federal 

grant or cooperative agreement; 

B. If any funds other than federal appropriated funds have been paid or will be paid to any person 

for influencing or attempting to influence an officer or employee of any agency, a member 

of Congress, an officer or employee of Congress, or an employee of a member of Congress in 

connection with this federal grant or cooperative agreement, the undersigned shall complete and 

submit Standard Form – LLL, “Disclosure of Lobbying Activities,” in accordance with its instructions; 

and

C. The undersigned shall require that the language of this certification be included in the award 

documents for all subawards at all tiers (including subgrants, contracts under grants and 

cooperative agreements, and subcontracts) and that all sub-recipients shall certify and disclose 

accordingly. 

2. Debarment, Suspension and Other Responsibility Matters (Direct Recipient) 

As required by Executive Order 12549, Debarment and Suspension, and implemented at 2 C.F.R. Part 2867, 

for prospective participants in primary covered transactions, as defined at 2 C.F.R. Part 2867.20(a)- A. The 

applicant certifies that it and its principals: 

A. Are not presently debarred, suspended, proposed for debarment, declared ineligible, sentenced 

to a denial of federal benefits by a state or federal court, or voluntarily excluded from covered 

transactions by any federal department or agency; 
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B. Have not within a three-year period preceding this application been convicted of or had a civil 

judgment rendered against them for commission of fraud or a criminal offense in connection with 

obtaining, attempting to obtain, or performing a public (federal, state or local) 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. Federal Taxes and Assessments

A. 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. 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.

4. Drug-Free Workplace (Grantees Other Than Individuals) 

As required by the Drug-Free Workplace Act of 1988, and implemented at 28 C.F.R. Part 83, for grantees/

recipients, as defined at 28 C.F.R. Part 83.660 – 

A. The applicant certifies that it will, or will continue to, provide a drug-free workplace by: 

(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; 
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(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, DC 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). 

Grantee Agency Name and Address: 

B. The grantee may insert in the space provided below the site(s) for the performance of work done in 

connection with the specific grant: 

Place of performance (street address, city, county, state, zip code) 

____________________________________________________

____________________________________________________

Check □ if there are workplaces on file that are not identified here. 

5. Coordination 

The Public Safety Partnership and Community Policing Act of 1994 requires applicants to 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 

here □ 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. 
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Grantee Agency Name and Address: 

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

Grantee IRS/ Vendor Number: ______________________________ 

False statements or claims made in connection with COPS grants (including cooperative agreements) may 

result in fines, imprisonment, disbarment from participating in federal grants 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 grantee entity of its obligations under this grant. 

__________________________________________________________ _____________________

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:

•	 Community Partnerships

•	 Organizational Transformation

•	 Problem Solving

Community Partnerships 

Collaborative partnerships between the law enforcement agency and the individuals and organizations they 

serve to develop solutions to problems and increase trust in police.

Community policing, recognizing that police rarely can solve public safety problems alone, encourages 

interactive partnerships with relevant stakeholders. The range of potential partners is large and these 

partnerships can be used to accomplish the two interrelated goals of developing solutions to problems 

through collaborative problem solving and improving public trust. The public should play a role in 

prioritizing and addressing public safety problems.

Other Government Agencies

Law enforcement organizations can partner with a number of other government agencies to identify 

community concerns and offer alternative solutions. Examples of agencies include legislative bodies, 

prosecutors, probation and parole, public works departments, neighboring law enforcement agencies, 

health and human services, child support services, ordinance enforcement, and schools.

Community Members/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/storefronts in the 

community, and team beat assignments.

Nonprofits/Service Providers

Advocacy and community-based organizations that provide services to the community and advocate on its 

behalf can be powerful partners. These groups often work with or are composed of individuals who share 

common interests and can include such entities as victims groups, service clubs, support groups, issue 

groups, advocacy groups, community development corporations, and the faith community.

Private Businesses

For-profit businesses also have a great stake in the health of the community and can be key partners 

because they often bring considerable resources to bear in addressing problems of mutual concern. 

Businesses can help identify problems and provide resources for responses, often including their own 

security technology and community outreach. The local chamber of commerce and visitor centers can 

also assist in disseminating information about police and business partnerships and initiatives, and crime 

prevention practices.
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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 

The alignment of organizational management, structure, personnel, and information systems to support 

community partnerships and proactive problem-solving efforts.

The community policing philosophy focuses on the way 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.

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.
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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 how 

feedback information is used, not only how outcomes are measured.

Transparency

Community policing involves decision-making processes that are more open than traditional policing. 

If the community is to be a full partner, the department needs mechanisms for readily sharing relevant 

information on crime and social disorder problems and police operations with the community.

Organizational Structure

It is important that the organizational structure of the agency ensures 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 citizens, thus establishing a strong relationship and mutual accountability. Beat 

boundaries should correspond to neighborhood boundaries and other government services should 

recognize these boundaries when coordinating government public-service activities.

Despecialization

To achieve community policing goals, officers have to be able to handle multiple responsibilities and take a 

team approach to collaborative problem solving and partnering with the community. Community policing 

encourages its adoption agency-wide, not just by special units, although there may be a need for some 

specialist units that are tasked with identifying and solving particularly complex problems or managing 

complex partnerships.

Resources and finances

Agencies have to devote the necessary human and financial resources to support community policing to 

ensure that problem-solving efforts are robust and that partnerships are sustained and effective.
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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 values.

Recruitment, hiring, and selection

Agencies need a systematic means of incorporating community policing elements into their recruitment, 

selection, and hiring processes. Job descriptions should recognize community policing and problem-solving 

responsibilities and encourage the recruitment of officers who have a “spirit of service,” instead of only a 

“spirit of adventure.” A community policing agency also has to thoughtfully examine where it is seeking 

recruits, whom it is recruiting and hiring, and what is being tested. Agencies are also encouraged to seek 

community involvement in this process through the identification of competencies and participation in 

review boards.

Personnel supervision/evaluations

Supervisors must tie performance evaluations to community policing principles and activities that are 

incorporated into job descriptions. Performance, reward, and promotional procedures should support sound 

problem-solving activities, proactive policing, community collaboration, and citizen satisfaction with police 

services.

Training

Training at all levels—academy, field, and in-service—must support community policing principles and 

tactics. It also needs to encourage creative thinking, a proactive orientation, communication and analytical 

skills, and techniques for dealing with quality-of-life concerns and maintaining order. Officers can be trained to 

identify and correct conditions that could lead to crime, 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 in the organization, training in its fundamental principles will need to take place regularly.

Information Systems (Technology) 

Community policing is information-intensive and technology plays a central role in helping to provide ready 

access to quality information. Accurate and timely information makes problem-solving efforts more effective 

and ensures that officers are informed about the crime and community conditions of their beat. In addition, 

technological enhancements can greatly assist with improving two-way communication with citizens and in 

developing agency accountability systems and performance outcome measures.

Communication/access to data

Technology provides agencies with an important forum by which to communicate externally with the 

public and internally with their own staff. To communicate with the public, community policing encourages 

agencies to develop two-way communication systems through the Internet that allow for online reports, 

reverse 911 and e-mail alerts, discussion forums, and feedback on interactive applications (surveys, maps), 

thereby creating on-going 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.
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Community policing encourages the use of technology to provide officers with ready access to timely 

information on crime and community characteristics within their beats, either through laptop computers 

in their patrol cars or through personal data devices. In addition, technology can support crime/problem 

analysis functions by enabling agencies to gather more detailed information about offenders, victims, crime 

locations, and quality-of-life concerns, and to further enhance analysis.

SAFECOM Guidance

The Department of Homeland Security Office of Emergency Communications, in coordination with various 

stakeholder groups, develops the annual SAFECOM Guidance on Emergency Communications Grants. 

The guidance provides recommendations to grantees seeking funding for interoperable emergency 

communications projects, including allowable costs, items to consider when funding emergency 

communications projects, grants management best practices for emergency communications grants, and 

information on standards that ensure greater interoperability. The guidance is intended to ensure that 

federally-funded investments are compatible and support national goals and objectives for improving 

interoperability nationwide. Grantees (including sub-grantees) that are using TRGP funds to support 

emergency communications activities should comply with the latest version of SAFECOM Guidance, 

including provisions on technical standards that ensure and enhance interoperable communications. The 

most recent version of SAFECOM Guidance is available at: www.safecomprogram.gov/grant/Default.aspx.

Quality and accuracy of data

Information is only as good as its source and, therefore, it is not useful if it is of questionable quality and 

accuracy. Community policing encourages agencies to put safeguards in place to ensure that information 

from various sources is collected in a systematic fashion and entered into central systems that are linked 

to one another and checked for accuracy so that it can be used effectively for strategic planning, problem 

solving, and performance measurement.

Problem Solving

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.
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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 either totally eliminating the problem, substantially 

reducing the problem, reducing the amount of harm caused by the problem, or improving the quality of 

community cohesion.

Assessment: Evaluating the success of the responses

Assessment attempts to determine if the response strategies were successful by understanding if the 

problem declined and if the response contributed to the decline. This information not only assists the 

current effort but also gathers data that build knowledge for the future. Strategies and programs can be 

assessed for process, outcomes, or both. If the responses implemented are not effective, the information 

gathered during analysis should be reviewed. New information may have to be collected before new 

solutions can be developed and tested. The entire process should be viewed as circular rather than linear, 

meaning that additional scanning, analysis, or responses may be required.

Using the crime triangle to focus on immediate conditions (victim/offender/ location)

To understand a problem, many problem solvers have found it useful to visualize links among the 

victim, offender, and location (the crime triangle) and those factors that could have an impact on them, 

for example, capable guardians for victims (e.g., security guards, teachers, and neighbors), handlers for 

offenders (e.g., parents, friends, and probation), 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.
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Appendix D – Sole Source Justification Facts 

What is “sole source” procurement?

Sole source, or procurement by noncompetitive proposals, is procurement through solicitation of a 

proposal from only one source, or after solicitation of a number of sources, competition is determined 

inadequate. Sole source procurements must adhere to the standards set forth in the Uniform Administrative 

Requirements, 28 C.F.R. § 66.36 or 28 C.F.R. § 70 (as applicable).

When is sole source approval required by the COPS Office?

A grant recipient must request written approval from the COPS Office for sole source procurements in excess 

of $100,000 prior to purchasing equipment, technology or services, obligating funding for a contract, or 

entering into a contract with grant funds. For the purchase of equipment, technology or services under a 

COPS grant award, grant recipients must follow their own policies and procedures on procurement as long 

as those requirements conform to the federal procurement requirements set forth in 28 C.F.R. § 66.36 and 

28 C.F.R. § 70 (as applicable). A sole source justification request should be submitted if a grant recipient 

determines that the award of a contract through a competitive process is infeasible, and if one or more of 

the following circumstances apply: 

1. The item/service is available only from one source 

2. The public exigency or emergency for the requirement will not permit a delay resulting from 

competitive solicitation 

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

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 $100,000 must 

be submitted to the COPS Office in writing, confirming that the award of the contract through full and open 

competition is infeasible. Please note that a justification must be submitted for each vendor providing goods 

or services in excess of $100,000.

To ensure that all of the necessary information is included and submitted to the COPS Office, the following 

checklist can be used when preparing your agency’s sole source request: 

Letterhead – The sole source request must be signed by an authorized representative and submitted on 

grantee department letterhead, and must include the agency ORI and the grant number for which the 

approval is being sought. The request should also include the following information:

Section I. Description of Project – A brief description of the project, the amount to be designated for the 

sole source procurement, and the purpose of the contract. 

Section II. Reason for Request

1. An explanation as to why full and open competition is infeasible (e.g., why it is necessary to contract in a 

noncompetitive manner) and 

2. Which one (or more) of the three required categories identified below applies to the requested sole 

source procurement transaction(s). 

[ ] 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; and/or

[ ] Competition is determined inadequate after solicitation of a number of sources.
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Section III. Supporting Documentation – The information below should support the applicable 

category(ies) identified in Section II. 

1. If the item/service is available only from one source, please include the following:

•	 Uniqueness of items/services to be procured from the proposed contractor or vendor (compatibility, 

patent issues, etc.); 

•	 How the agency determined that the item/service is only available from one source (e.g., market 

survey results, independent agency research, patented or proprietary system); 

•	 Explanation of need for contractor’s expertise linked to the current project (e.g., knowledge of 

project management, responsiveness, experience of contractor personnel, prior work on earlier 

phases of project); and/or

•	 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:

•	 Explanation of the specific public emergency;

•	 Impact on project if deadline/dates are not met;

•	 When the contractual coverage is required by your department and why; and/or 

•	 Any additional information that would support the case. 

3. If competition is determined inadequate after solicitation of a number of sources, please include the 

following: 

•	 Results of a market survey to determine competition availability; 

•	 If no survey is conducted, please explain why not; and/or

•	 Any additional information that would support the case.

Section IV. Best Interest Statement – A statement declaring 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 documentation is required. 

The COPS Office will notify your agency in writing after completion of the review. 

Please be advised that conflicts of interest are prohibited under the procurement standards set forth in 28 

C.F.R. § 66 and 28 C.F.R. § 70. 

Contact the COPS Office

If you have any questions regarding the federal requirements that guide procurement procedures, please 

contact your COPS 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.
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Appendix E – Conference Reporting Requirements 

Quarterly Report on Conference Costs

Component: Telephone:

Point of Contact: Email:

Conference Title:

Non-Federal 

Facility

Conference over 

$20,000

Non-Federal 

Facility

Conference over 

$20,000

Non-Federal 

Facility

Conference over 

$20,000

Conference Date (Start & End)

Facility Name

City and State

Number of Federal Attendees

Number of non-Federal 

Attendees

Total Number of Attendees

Purpose of the Conference:

Conference Costs:

Conference/Meeting Space 

(incld. Break out Room Cost)

A/V Equipment & Services

Other Equipment Costs

Printing and Distribution

Gov't Provided Meals

Refreshments

M&IE

Lodging

Transportation

Local Transportation

Conference Planner

Conference Facilitator

Other Costs

Total Conference Cost

Average Cost per Attendee

Describe any issues encountered 

in determining the costs related 

to the conference1:

Description of contracting 

procedures2

:

Total Original Cost Estimate

Variance (Actual vs. Estimated)

Variance Justification3

:

2

Attach additional pages to explain contracting procedures.

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

3

Use Attachment C to provide a justification narrative for all events in which the actual cost exceeds the estimate, the justification needs to be 

itemized.

1

Attach additional pages to explain methodology if you are unable to capture costs as described in Policy 08-08 or if any costs appear to be out of 

the ordinary.

$0.00

$0.00

$0.00

$0.00 $0.00

$0.00

$0.00

$0.00

For Events in Non-federal Facilities Only

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00 $0.00

$0.00 $0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

$0.00

Conferences/Events

$0.00 $0.00

$0.00

$0.00

Event Type

$0.00

$0.00

$0.00

1
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Appendix F – Consultant/Contractor Rate Information Sheet

Awardee Guidelines on Consultant Rate Approval Requests 

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

and allocable in accordance with 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 Commercial Organizations), as applicable, 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 $550 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 $550 per day, the COPS 

Office requires written justification if the consultants or contractors are hired through a noncompetitive 

bidding process. The awardee agency must provide justification for any such rate in excess of $550 per 

day and receive COPS Office approval of that rate before drawing down grant funds. Any jurisdiction that 

does not provide sufficient written justification will be limited to $550 per day for each consultant and/or 

contractor. Please note that this does not mean that the rate can or should be $550 for all consultants. 

Note: Consultant and contractor daily rates do not include travel or subsistence, but may include 

preparation, evaluation, and travel time.

Guidance for requesting a consultant rate based on employment

•	 Consultants Associated with Educational Institutions (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.

•	 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 grant and is representing his or her 

agency without pay from its 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 grant 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 award 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 also 

of newly hired consultants that a community is committed to fund in the absence of a COPS Office 

award.

•	 Consultants Employed by Commercial and Not-For-Profit Organizations. These organizations 

are normally subject to competitive bidding procedures. Thus, if they have been selected through 

competitive bidding, they are not subject to the $550 per day maximum compensation threshold. In 

those cases where an individual has authority to consult without employer involvement, the rate of 

compensation should not exceed the individual’s daily salary rate paid by his or her employer, subject 

to the $550 limitation.
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To request approval of a consultant rate in excess of $550 per day, please submit the signed request on 

awardee department letterhead, and include the agency ORI 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 $550/day (indicate fringe benefits, if 

applicable) 

•	 A resume or curriculum vitae (CV) for each consultant or contracted individual whose rate exceeds 

$550 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).

•	 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 $550 per day, please return this information 

to your Grant Program Specialist or project 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.

U.S. Department of Justice

Office of Community Oriented Policing Services

145 N Street NE

Washington, DC 20530
U.S. Department of Justice

Office of Community Oriented Policing Services

145 N Street NE

Washington, DC 20530

To obtain details on COPS programs, call the COPS Office Response Center at 800-421-6770.

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

August 2013