Guide to Developing the Anti-Gang Initiative and Project Safe Neighborhoods (PSN) Grants for United States Attorneys and PSN Task Forces
This web guide is designed for United States Attorneys' Offices
and the Project Safe Neighborhoods Task Forces to help them through
the process of developing and funding a PSN and/or Anti-Gang strategy. The steps involved in developing both the Anti-Gang Initiative and PSN strategies are similar.
This guide includes a step-by-step process and various sample documents and
other tools.
Overview of PSN Grants
The U.S. Department of Justice (DOJ) has dedicated $30 million in funding in FY 2006 to support new and expanded anti-gang prevention and enforcement efforts under the Project Safe Neighborhoods (PSN) Initiative. In addition, DOJ has dedicated $10 million in FY 2006 to fund current and expanded comprehensive gun crime reduction strategies. The $30 million in Anti-Gang funds will be awarded on a formula basis, and the $10 million in PSN grant funds will be awarded on a competitive basis. Both initiatives are authorized by H. Rept. 2862.
The new Anti-Gang Initiative funds will enhance PSN task force efforts to combat gangs by building on the effective strategies and partnerships developed under PSN. Each district must show how their gang funding may impact their PSN strategies and need for additional funding.
Through the development of district-wide comprehensive anti-gang strategies, the U.S. Attorney in each of the 94 federal judicial districts will partner with local law enforcement and others in the PSN task force to pattern strategies for both the FY 2006 PSN and Anti-Gang Initiatives after PSN's five essential elements: 1) partnerships, 2) strategic planning, 3) training, 4) outreach, and 5) accountability. For more on these elements, visit www.ncjrs.org/html/bja/205263/.
The Anti-Gang Initiative and PSN are separate solicitations requiring separate applications to BJA. The following step-by-step guidance should be used to develop the applications for funding and select grant recipients and sub-recipients for the both programs.
Step One: Develop a Strategy
The PSN Task Force should meet to discuss an overall strategy to
support their efforts. Generally, almost anything intended to reduce
gun or gang violence will be acceptable. The task force should develop a
plan that lists all of the initiatives you wish to fund along with
the tentative funding amounts to go to each.
To develop either strategy, the task force may wish to target new prosecutors to key areas,
support increased enforcement or investigations, provide intensive supervision programs, augment your research or
community outreach efforts, engage in prevention or intervention efforts, or focus
on other such strategies. The research and media partners should be consulted to educate the task force on the crucial needs and help
guiding the strategy session.
At this point, because the task force is not making decisions regarding
the actual grantees or subcontractors for this program, the U.S.
Attorney and his or her staff may be included in this strategy session.
The U.S. Attorney will designate a selection committee to (1) choose
a single grantee to act as a fiscal agent for the strategy and (2)
determine what portions of the strategy will be funded and to whom.
In doing so, the U.S. Attorney may consult with the task force or
delegate this responsibility to a task force member, as appropriate.
This selection committee must not include the U.S. Attorney, a member
of his or her staff, or any federal employee, but can include any
or all of the other members of the task force, as long as their
participation does not represent an actual or apparent conflict
of interest. No member of the selection committee is eligible to
receive funding under the current grant program for which funding decisions are being made.
The Tool Box contains a summary of the Standards of Conduct and
Conflict of Interest Rules that apply to U.S. Attorneys and their
staff members. In designating the selection committee, the same
rules regarding conflicts of interest apply to members of the committee.
The selection committee should have a chairperson and can include
as many people as appropriate or as few as three.
BJA will award a single grant based on an approved application
in each of the U.S. Attorney Districts. However, the selection
committee may wish to dedicate funds to more than one jurisdiction
or for more than one project. As a result, each task force will
need to use a fiscal agent to receive the funds and then make subawards
to or enter into contracts with each project or entity that will
carry out each component of the strategy. Only nonprofit organizations
and units of state and local government are eligible to apply to
be the fiscal agent.
After the selection committee members have selected a potential
fiscal agent, they should forward the name of the organization to
the U.S. Attorney for certification. The certification process is
outlined in the Tool Box. After the fiscal agent is certified, the
U.S. Attorney should notify BJA by forwarding the certification
letter. A copy of the sample certification letter is included in
the Tool Box.
Responsibilities of the Fiscal Agent
Enter into contracts with each entity responsible for carrying out each portion of the Task Force Strategy.
Oversee the contracts entered into.
Account for all funds awarded.
Prepare required federal reports.
Draw down federal funds as needed.
Make payments to each contractor.
Work with federal monitors or auditors as needed.
Attend a training on Office of Justice Programs financial rules, unless the chosen fiscal agent has a demonstrated record in this area.
The selection committee may allocate funds in your overall budget
for the use of the fiscal agent in administering funds and meeting
the above requirements, but such funds cannot exceed 10 percent
of the total grant. This includes the travel funds needed to attend
the required financial training.
Considerations in Selecting a Fiscal Agent
The selection committee may select any government agency or legal
nonprofit organization as your fiscal agent. However, it is important
to remember that this organization should have a track record in
overseeing and accounting for funds, especially grant funds. Remember
that all of these expenditures are subject to federal rules and
federal audits. There are two options for fiscal agents:
Many state agencies and large local jurisdictions have the expertise
needed to be a fiscal agent. If they have experience either in
awarding grants or in receiving them, they are a good choice.
Although the selection committee is free to select any such qualified
organization, BJA has established a relationship with a state
administering agency in each state and the selection committee
may be interested in considering them. A list is available below.
The selection committee may select a nonprofit agency; however,
it should ask for references and experience. This experience might
include administering grant funds, either as a grantor or a grantee,
or the personal experience of their employees in grant funding
or contracting using federal rules.
Based on the priorities identified in the strategy, the selection
committee will need to allocate the available funds and lay out
all of the expected expenditures in a budget. This will form the
basis for the grant budget. To develop this budget, the selection
committee should simply list all of the components of the strategy
and the amounts to be devoted to each. In doing so, the selection
committee should consider any needed administrative funds.
Awards made by BJA to the fiscal agent will be for up to 3 years. However,
individual grants or contracts made to the subrecipients may be
for any length of time up to, but should not exceed, 3 years.
Administrative Funds
In Step Three, the task force selection
committee selected a fiscal agent that will make subawards to the
entities responsible for each portion of the strategy. The fiscal
agent may need funds in order to administer these subawards, including
accounting for the funds, preparing grant reports, and working with
federal monitors or auditors as needed. The task force may want
to allocate funds in the overall budget for this purpose, but such
funds cannot exceed 10 percent of the total grant. For example, if the allocation for your district is $100,000, then
up to $10,000 can be used for administration.
Administrative funds may be spent on portions of salaries, supplies, equipment, travel, and contracts needed to support and properly administer these funds.
Step Five: Determine a Method for Selecting Subrecipients
After determining an overall strategy and selecting a fiscal agent,
the PSN Task Force selection committee should decide how to allocate
funding to each portion of the strategy. The task force may decide
to simply choose who will receive funding, decide to host competitive
selection processes, or use a combination of the two. The fiscal
agent may be helpful in making these decisions and in guiding a
selection process. Remember that an official representing an agency
that stands to receive funds cannot be part of the process. Only
nonprofit organizations and units of state and local government
are eligible to apply.
Competitive Selection Process
If the task force chooses to competitively select any portion of the strategy, you can find a guide to developing a subaward solicitation in the Tool Box. Be sure to include all of the components in the proposal guide.
After the selection committee develops a solicitation, the U.S.
Attorney should determine the universe of potential subrecipients
and inform them of the funding opportunity. This can be done either
by mailing the solicitation to a limited number of organizations
or by more widely posting the opportunity through the State Register,
on the Internet, through a wider mailing, or using another appropriate
method.
Noncompetitive Selection Process
If the task force chooses to simply select some or all of the subawardees without
a competitive selection process, then the task force must forward
the names of these organizations to the U.S. Attorney for certification,
before finalizing the decisions. (See Step Six.)
If the chosen fiscal agent does not have grantmaking authority
and must use contracts to provide funds to subrecipients, they should
familiarize themselves with rules on sole source selections, which
limit the ability to provide contracts in excess of $100,000 to
an entity without a competitive process. In these cases, such contracts
can only be entered into if it can be shown that the selected organization
is the only entity that can provide the exact services required.
All such arrangements must be approved in advance by BJA.
Although the U.S. Attorneys will not be actively involved in the selection of a grantee or subrecipients, it is appropriate and necessary that they certify the applicants as suitable to apply. This certification ensures that every candidate for either a fiscal agent or a subrecipient is appropriate for federal funding and that each is an entity within the community that the U.S. Attorney can work with as part of the U.S. Attorney's PSN Task Force.
After the task force provides the U.S. Attorney with the list of potential subrecipients under a noncompetitive process or all applicants under a competitive process, the U.S. Attorney will review them using the certification process below.
The U.S. Attorney's certification of applicants will be conveyed
to the selection committee, whose members will then review and make
final selections from the certified organizations. At a later time,
when final selections have been made, the U.S. Attorney will prepare
a certification letter to cover all subrecipients. (See Step
Eight.)
Step Seven: Hold a Final Subrecipient Selection Meeting
If the selection committee is using a competitive selection process, after the U.S. Attorney has certified applicants, the selection committee should meet on its own to review the proposals and select subrecipients.
The committee should determine in advance how it will make the selections. The group might choose to simply meet to discuss the merits of each proposal and come to consensus. Alternatively, the committee may choose to use a scoring instrument to more objectively weigh the proposals, which is useful if entertaining more than a few proposals. Sample instruments can be found in the Tool Box.
If, on the other hand, the selection committee is simply choosing the subrecipients based on their expertise, then the committee should meet to make sure that all previously identified candidates received a certification from the U.S. Attorney and that there is a consensus on the decisions among the selection committee members.
Final applications must be submitted online by the fiscal agent
through the Office of Justice
Programs Grants Management System (GMS). The online application
system can also be accessed through the Tool Box. Only the organization
selected as the fiscal agent should apply; all subrecipient funding
will be covered by a single application. The fiscal agent must register
for the online system and apply for all funds. But before doing
so, the task force and the fiscal agent along with all selected
subrecipients, if selected at the time, should develop the application.
All applications must include a program narrative, budget detail worksheet and narrative, and the U.S. Attorney certification letter. The program guidance or solicitation identifies the required contents for the program and budget narratives.
Various certifications and other information are also required. To learn about them, the fiscal agent should register for the online system and then review the requirements.
