Take appropriate steps to ensure that BJA staff and grantees receive appropriate guidance and direction related to subrecipient/contractor classifications.

Review the instances of approvals of unallowable costs and take appropriate steps to ensure that BJA personnel are aware of and recipients receive accurate guidance related to unallowable costs.

Require Newburyport to develop and implement written policies and procedures to ensure performance reporting is limited to the work performed under the relevant award, as required.

Ensure Newburyport submits its FY 2023 and FY 2024 single audit reports and require Newburyport to develop and implement policies and procedures to ensure the timely completion and submission of future single audit reports to the Federal Audit Clearinghouse

Require Newburyport to develop and implement policies and procedures related to subrecipient/contractor classifications.

Require Newburyport to develop and implement adequate policies and procedures for subrecipient management, to include assessing subrecipient risk, subrecipient monitoring, relevant special conditions, and reviewing subrecipient expenditures for allowability, appropriateness, and support.

Remedy $388,037 in unallowable costs, which consists of $233,850 in unallowable research partner costs, $139,619 in unallowable subrecipient costs, $5,750 in unallowable other direct costs, and $8,818 in unallowable supply costs

Remedy $51,662 in unsupported costs, which consists of $35,000 in unsupported subrecipient costs and $16,662 in unsupported supply costs.

Require Newburyport to improve its procedures for ensuring costs charged to the grants are allowable and reasonable according to federal regulations.

Develop mechanisms to ensure timely subrecipient monitoring going forward, including a plan to conduct site visits and desk reviews of subrecipients that did not receive them within required timeframes.

Enhance NCC's policies and procedures to ensure that NCC follows up on single audit findings within required timeframes and tracks subrecipient progress in implementing corrective actions.

Ensure VDSS documents its desk monitoring process to communicate to its personnel expectations regarding the: (1) nature and scope of monitoring activities, (2) required frequency of monitoring, and (3) sufficient documentation to substantiate that monitoring occurred, as well as the results.

Ensure VDSS develops and implements a compliant process for subaward reimbursement that includes subrecipient autonomy over tracking expenditures to funding sources and adequate VDSS controls for ensuring subrecipients adequately account for transactions by funding source at the time of execution.

Ensure that VDSS develops and implements guidance to assist its personnel and its subrecipients through the administration of the new process for reimbursing subrecipient CACs in compliance with the DOJ Grants Financial Guide and the Uniform Guidance.

Remedy the $91,918 in unallowable costs resulting from the incorrect percentage applied by VDSS when reimbursing the CACs.

Ensure VDSS implements controls to verify that subrecipients' time and effort charges are based on actual amounts.

Remedy the $9,065 in unsupported personnel costs.

Ensure VDSS enhances its monitoring policies and procedures to include a process for reviewing the accuracy of performance data in PMT.

Ensure VDSS develops, implements, and distributes a written proration strategy to the CACs to ensure PMT data is complete, accurate, and reflects only VOCA-funded activities.

Ensure that One Place establishes written policies and procedures related to program operations, including the intake of sexual assault cases and performance reporting, and distribute those among relevant officials and staff.

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

Require the PRDOJ to develop and implement adequate procedures for the accurate reporting of financial activity on annual state certification forms, including the consistent application of established financial reporting periods.

Work with OSU to develop and implement policy and procedure enhancements for (a) creating and supporting required performance reports, (b) ensuring subawards receive federal authorization when required, (c) ensuring proper separation of duties for the after-the-fact review of effort distributions, and (d) incorporating the proper approval process and requirements for budget adjustments in accordance with the DOJ Grants Financial Guide.

Remedy the net total of $292,977 in unallowable costs, which include:

a. $222,157 paid to unallowable subrecipients and the $16,700 of associated indirect costs, totaling $238,857, for grant number 15PBJA 21 GK 03997 INTE.