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Home My WebLink About2017-09-01 MonitoringF®LE Florida Department of Law Enforcement Richard L. Swearingen Commissioner September 1, 2017 Business Support Office of Criminal Justice Grants Post Office Box 1489 Tallahassee, FL 32302-1489 (850)617-1250 www.fdle.state.fl.us Honorable Bob McPartlan Mayor City of Sebastian 1225 Main Street Sebastian, FL 32958 Rick Scott, Governor Pam Bondi, Attorney General Jimmy Patronis, Chief Financial Officer Adam Putnam, Commissioner of Agriculture RECEIVED SEP 14 2017 City of Sebastian City Clerk's Office Subject: Edward Byrne Memorial Justice Assistance Grant (JAG Subaward) Monitoring Dear Mayor McPartlan: This letter reports the results of the recent desk monitoring for the Edward Byrne Memorial Justice Assistance Grant (JAG), grant number 2017-JAGC-INRI-3-F9-083 completed via correspondence questionnaire. Our grant manager, Krista Sanders, reviewed the questionnaire and accompanying documentation submitted by your agency. Although the monitoring revealed your agency is operating grant activities in compliance with state and federal rules, regulations and standard conditions; there is one recommendation being provided that should be addressed to prevent future areas of non-compliance. We wish to thank you and members of your agency for your continuing efforts with the JAG grant program. Please contact your grant manager, Krista Sanders or Senior Management Analyst Supervisor, Rona Kay Cradit, at (850) 617-1250 with any questions or for additional information or assistance. PTH/ar cc: Chief Michelle Morris, Project Director, City of Sebastian Police Department Enclosure Service • Integrity • Respect • Quality Justice Assistance Grant - County -wide Desk Monitoring Report Contract No: 2017-JAGC-INRI-3-F9-083 Project Director: Michelle J. Morris Telephone No: 772-388-9750 Subgrantee: City of Sebastian Project Title: PURCHASE EQUIPMENT Other Person(s) Contacted: Monitoring Date: 06/12/2017 Project Monitored By: G, Krista M Sanders Report Number: 1 Date Written Report Complete: 08/17i2017 Date of Approval: qYa[p /.Zrl -7 Report agency maintain a 2. Are all organization officials in SIMON current and correct? �y 3. Are project staff aware of and familiar with the Standard Conditions section of the approved contract? �y 4. Are project staff familiar with the USDOJ/OJP Financial Guide? �y 2017-JAGC-INRI-3-F9-083 8/17/17 4:48 PM Report# 1 Page 1 of 6 5. Does the financial officer/project director understand that only costs incurred between the beginning and�y ending dates of the contract are eligible for reimbursement and that an invoice must have been paid prior to the expenditure being reported to the FDLE? 6. Does the project staff understand the procedure for requesting a grant adjustment and the due date for �y adjustment requests? 7. If subgrantee has delegated signature authority for submitting grant adjustments in SIMON, do they �y have written documentation of this in their file? 8. Does project staff understand the reporting requirements? Is project staff aware of the reporting process�y and which roles may submit transactions in SIMON? 9. Have audits been submitted as required by the grant agreement for this and prior years? �y 10. If yes, are there any findings and recommendations that require response by the subrecipient or N/A implementing agency and/or follow-up by the Office of Criminal Justice Grants? Is the subgrant recipient in compliance with the Equal Employment Opportunity (EEO) Plan requirement? 2. Did the subgrantee provide any documentation rc ated to civil rights compliance? �y 3. Is the subgrantee in compliance with the civil rights requirements? �y Monitoring Finding/Recommendation Findings Recommendations: The City of Sebastian is currently in compliance with Office for Civil Rights (OCR) requirements. However, it is noted the City of Sebastian does not have a Limited English Proficiency (LEP) Plan, policies or procedures in place to provide services to non-English speaking persons. All recipients and subrecipients of federal funding must comply wiin the provisions of the Omnibus Crime Control and Safe Streets Act of 1968. It is advised that the City of Sebastian develop a written LEP Plan. For additional information, please see subaward Standard Condition, Section II #14.0, or www.lep.gov. 4. Is the implementing agency in compliance with the Equal Employment Opportunity (EEO) Plan �y requirement? 5. Did the implementing agency provide any documentation related to civil rights compliance? �y 6. Is the implementing agency in compfance with the civil rights requirements? 0 2017-JAGC-INRI-3-F9-083 8/17/17 4:48 PM Report# 1 Page 2 of 6 7. Does the agency utilize the Florida Law Enforcement Basic Abilities Test (LE BAT) score to help rank, order, or otherwise select among candidates for any law enforcement office position? Cate o : Compliance Issues 1. Does project staff understand and are all complying with the records retention requirements? y 2. For state agencies, is there a Certification Regarding Lobbying on file, and is the agency complying with N/A the stipulations of that certification? 3. Is the subgrantee's SAM registration current and does the agency verify each vendor/provider being �y paid from the grant is not suspended or debarred from receiving federal funds? 4. If travel expenses are being charged to the grant, does the subgrantee/implementing agency have a N!A written travel policy? If not, are they using the state policy? 5. Does the agency have a Conflict of Interest Certification on file? �y 6. Did review of the agency's procurement procedures during monitoring result in identification of any potential or actual conflicts of interest? reports been submitted as required by the grant agreement? 2. Is the grant program accomplishing activities in accordance with the subaward agreement? �y Cate o : Financial Management 1. Are all agencies receiving funds actively involved in the activities described in the grant? y 2. Do project staff know how to access financial reports in SIMON to confirm financial status? �y 3. Are system controls adequate to account for the receipt, obligation, and expenditure of project funds, �y and are financial records at the subgrantee, implementing agency, and service provider, if applicable, consistent with each other? 4. Is the project expending funds at a rate that will allow for total expenditure of project funds within the �y grant period? 5. Have Project Expenditure Reports been submitted as required by the grant agreement? 0 6. Does backup documentation support expenditures reflected in the PER selected for review? �y 7. Did the PER reviewed include onN costs in L.rred &ring the approve' contract period? 0 2017-JAGC-INRI-3-79-083 8/17/17 4:48 PM Report# 1 Page 3 of 6 8. Did the per reviewed only include invoices paid prior to submittal to FDLE for reimbursement? �y 9. If budget is based on unit cost, did available documentation support the number of units reported on the N/q PER submitted for reimbursement? 10. Did the agency review proposed grant expenditures and line items to assure supplanting would not �y occur and local/state funds were not already allocated for the same items or purpose? source documentation on file and recipient have written purchasing procedures? it meet the requirements? 3. Does documentation of procurement indicate these procedures were followed? �y 4. Did the procurement process for the purchase of grant funded items comply with federal procurement 0 standards? 1. Have expense and/or OCO items cutlincd in the 2. Is equipment purchased with grant collars being used as described in the contract? �y 3. Are property management records being maintaineo in accordance with contract requirements and is all �y grant funded property being insured in the same method as all other agency property? 4. Are there any items that qualify under the BJA's controlled or prohibited expenditure list? 5. If yes, are all requests, documentofcn, *ind approvals from the agency, OCJG, and BJA on file? N/A 6. If grant funds are used for bulletproof vests, does the implementing agency have a written Mandatory NIA Wear policy in effect? 7. Have the type of vests funded by the Gran: bean tested and found to comply with applicable National N/A Institute of Justice ballistic or stab standards and are the vests American-made? 8. If grant funds are used for body worn cameras, has the implementing agency provided a body worn N/A camera policy and is the certification on file? Salaries and Benefits 1. Does recipient have a current Policies and Procedures manual or cle written overtime policy, a written leave and fringe benefits policy, and applicable? 2017-J AG C- I N R I -3-F g-083 Report# 1 ned staff rules including a N/A job descriptions, as 8/17/17 4:48 PM Page 4 of 6 Cate o : Salaries and Benefits 2. If Salaries and Benefits are included in the budget, was documentation provided to support that a net N/A increase in staff resulted due to the grant funds? If funds are used to retain positions that would have been laid off but for the availability of federal funds, documentation must substantiate the certification that these positions have been cut only because of a funding shortfall affecting the entire unit of government. 3. Has a completed Personnel Tracking worksheet been submitted to the Office of Criminal Justice N/A Grants? 4. Do all personnel paid by the project, including personnel only receiving overtime, have timesheets that document that all hours chargez, ;r the project were worked on the project? 5. Have semi-annual certifications for all personnel who are assigned to work solely on the grant been N/q completed and submitted to OCJG? are included in the approved budget, has the executed contract been reviewed by the FDLE? 2. Are effective dates of the contract consistent with the grant period? N/q 3. Are all parties to the contract ci6a,,y identiriad and consistent with the grant agreement? N/A 4. Were all subcontracted activities identified in the approved grant agreement? N/q 5. Are USDOJ compliance requiremenis passed through by contract provisions and are the subgrant N/A standard conditions included by reference? This would include resolution of disputes, reporting, patents, rights in data and copyrights, examination of records, clean air and water, EEO, and termination of contract. 6. Has the grant manager confirmed that the contractor(s) are not included on the federal government's Wq Excluded Parties List? Category : Treatment 1. Were copies of any equired ^urren: a:< to o =:pride ;icer se,e) for the treatment agency and treatment N/A agency staff available for review and consistent with information provided in the approved contract? 2. Was a copy of the most recent Monitoring Report from the State of Florida licensing agency provided for N/q review, along with a copy of the treatment providers response to identified deficiencies, if applicable? 3. If services to clients were provided, were they provided only to clients meeting the selection/eligibility N/A criteria as per the subgrant? 2017-JAGC-INRI-3 •Fg-083 8/17/17 4:48 PM Report# 1 Page 5 of 6 training? Generated Income project staff attended the required 1. Have PGI reports been submitted as required by the grant agreement? 2. Has the subgrantee requested approval to expend earned PGI on all projects with a remaining PGI N/A balance? 3. Are system controls adequate to account for the receipt, obligation and expenditure of PGI? N/A 4. Does backup documentation support earnings and expenditures reflected in the PGI Earnings and N/q Expenditures Report selected for review? Confidential Funds 1. Is documentation of confidential funds adequate for the amount of expenditures made? N/A 2. Does project staff understand that the amount of confidential funds reported on expenditure reports N/q must represent only the amount spent? 3. Do financial records of confidential funs show adequate separation of accountability? F N/A 4. Does the implementing agency's management of confidential funds meet the requirements outlined in N/A the Office of Justice Programs Financiai Guide? Cate ory : Meth gabs 1. For projects including the investigation and closure of Methamphetamine Labs, has the subgrantee / N/A implementing agency provided documentation of compliance with the Federal, State, and local environmental health and safety laws and regulations applicable to the investigation and closure of such labs? 2017-JAGC-INRI-3-F9-083 8/17/17 4:48 PM Report# 1 Page 6 of 6