RFCUNY is required to follow US Department of Justice, Office of Justice Programs (OJP) Financial Guide requirements for OJP/COPS (Community Oriented Policing Services) funded conferences. Principal Investigators (PIs) are required to review and follow the Financial Guide regarding conference approval, planning, and reporting. This procedure highlights selected requirements within the USDOJ/OJP Financial Guide and establishes responsibilities for compliance.
Conference is defined broadly and includes meetings, retreats, seminars, symposia, or training activities. Conference costs and conference expenses mean all costs using DOJ funds associated with planning, hosting, sponsoring, or otherwise holding any conference.
Indirect costs/overhead rates are applied to direct costs associated with the conference (In accordance with negotiated agreements, all indirect costs associated with a conference must be applied to the above categories as appropriate and reported as conference costs.)
A. Cooperative Agreement and Contractor Recipients
Cooperative agreement and contractor recipients are required to seek and obtain OJP’s prior written approval for each event held with OJP funds, and for all conference costs associated with that event that are paid by OJP funds. No conference (regardless of the number of attendees) can proceed, nor can conference-related contracts (e.g., hotel contracts and travel arrangements/reservations) be signed, or conference implementation funding be obligated/work authorized (whether performed by cooperative agreement staff or outside staff), until DOJ’s written approval has been obtained. Approval of the overall proposal or budget does not grant prior approval to use Federal funds for events anticipated in the budget. The Project Investigator is required to obtain written prior approval of conference costs. A copy of DOJ’s approval must be provided to the Grants & Contract PA/APA team.
Conferences costing $100,000 or less and not exceeding any cost thresholds must be submitted for DOJ approval a minimum of 90 calendar days in advance of the mandatory timeframes noted in the DOJ/OJP Financial Guide. All conferences costing over $100,000 or exceeding any one cost threshold must be submitted for approval a minimum of 120 calendar days in advance of the mandatory timeframes noted in the Financial Guide.
B. Non-Cooperative Agreement Grantees
OJP/COPS does not require non-cooperative agreement grantees to obtain additional prior approval for specific conference costs. For non-cooperative agreement grantees, reasonable conference-related activity costs are allowable uses of OJP funding as long as the grant budget has been approved by OJP. Meals, refreshments, and trinkets (items such as hats, mugs, portfolios, t-shirts, coins, gift bags, etc., regardless of whether they include the conference name or OJP/DOJ logo) generally are not allowable. Any form of giveaways and raffles are also unallowable. However, cost limits apply and PIs should make every effort to stay within the cost limitation thresholds on meeting space, audio-visual equipment/services, and conference planning, as set out by the DOJ/OJP Financial Guide.
Where PIs plan to exceed (or do exceed) cost limitations, they must provide adequate documentation to justify exceeding limitations. Documentation supporting conference costs exceeding limitations should also be reviewed by the Grants & Contracts Project Administrator (PA)/Assistant Project Administrator (APA) team and maintained as part of support documentation for the conference cost.
PIs should consult the USDOJ/OJP Financial Guide and follow requirements to complete the Conference & Event Submission Form, submit supporting documentation, and obtain prior approvals. USDOJ requires cooperative agreements and contract recipients to complete the Conference and Events Submission Form. Actual costs should be provided where possible, but estimates may be provided for purposes of submitting requests for prior approval.
PIs are required to provide detailed cost estimates for each conference cost category (e.g., lodging rate per attendee, itemized audio-visual cost, transportation). Cost comparisons should be conducted to minimize costs of contracts for services, unless a specific provider is required by a facility. PIs must retain all documentation supporting the information provided on the submission form.
All OJP funding recipients are required to ensure that conference costs are reasonable and absolutely necessary. Thus, PIs must thoroughly review all conference costs and make every effort to conduct conferences via webinar, teleconference, or video conference. In person, face to face conferences should only be held when necessary and no other option exists to conduct the business without travel and related costs.
PIs are required to conduct pricing comparisons of multiple facilities in multiple locations. Minimizing costs must be a critical consideration when determining the city and facility in which to hold a conference. Cost comparisons should include overall facility cost, availability of lodging at per diem rates, convenience of location, availability of meeting space, equipment, and supplies, and commuting/travel distance for attendees. In conducting cost comparisons of facilities, PIs should send the same detailed requirements to all potential facilities, and refrain from making commitments to any particular facility until the comparison is complete (and any required written approvals have been obtained). PIs are responsible to ensure compliance with the USDOJ/OJP Financial Guide regarding location selection, which includes selection of Federal and no cost facilities.
In order to help ensure compliance with USDOJ conference cost requirements, expenditures for each conference needs to be separately tracked. PIs must report costs for each cooperative agreement conference by conference cost category as per the USDOJ/OJP Financial Guide to the Grants & Contracts PA/APA team. The PA/APA team will establish a subaccount for each conference by award and track expenses as reported by the PI.
PIs should follow this process so that they will be able to reconcile conference expenses to the post-event report.
Following this process will ensure that conference expenses are tracked appropriately and will reconcile to the post-event reports. Back-up documentation to support each expense is maintained electronically in the RF’s ePayment Request system.
PIs should note that cooperative agreements require costs of staff time related to logistical and programmatic planning to be tracked separately in accounting records. All contracted, subcontracted, or subawarded planning costs should also be included in these categories. Total costs are defined as direct and indirect costs. The PA/APA team will maintain accounting records of staff time for logistical and programmatic planning for cooperative agreements as reported to them by the PI.
Post event reporting is required by USDOJ for cooperative agreements and contract recipients when the total cost of the conference is greater than $20,000 or where more than 50 percent of the attendees are USDOJ employees. All actual costs must be reported within 45 calendar days of the last day of the event. The report must show the prior approval cost amount compared to actual cost amount and explain all variances greater than 10 percent and $1,000. Completed reports for OJP recipients should be emailed to OJPConferenceCostReporting@ ojp.usdoj.gov, and completed reports for the COPS Office should be emailed to COPS.Conferencecosts@ usdoj.gov. When a prior approval amount exceeds $20,000, OJP/COPS expect a post event report. If the actual costs are less than $20,000, PIs should notify their program manager or OJP/COPS Office point of contact that the report is not required or you may file the report. PIs should consult the USDOJ/OJP Financial Guide regarding deadlines and additional reporting requirements.