Discussion Thread: Increased VOCA Cap (January 2015)

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1 Discussion Thread: Increased VOCA Cap (January 2015) [Wisconsin; Amanda Powers] I hope everyone is doing well. As we all are figuring out how to plan for the increase in VOCA funding, I wondering if other states have started planning how their state will spend the VOCA increase. If so, would any states be willing to share their plans so far? [Iowa; Janelle Melohn] Here in Iowa we anticipate we will double our current VOCA awards to all DV/SA/Shelter programs in the coming fiscal year. We currently administer about $4.3 million to victim service providers. We stand to receive about $21 million total with the increase. So we anticipate giving out an additional $4 million and holding back the remaining award ($11 million). We are already in our grant application cycle, so it doesn t make sense to try to release a different grant application solicitation at this point. We figured this would give us time to strategically plan and determine our priority funding items for next year s grant application cycle. It would also give us an opportunity to ensure this increase is going to be recurrent and not a one-time cap raise. We are also talking about funding some focus groups and needs assessment-type activities over the next 6-8 months to make sure we aren t missing an initiative we should be considering funding Things we are currently considering as potential initiatives in next app cycle: 1. Mandating advocate salary increases (Iowa s advocates are horribly underpaid currently). This huge increase may be the only time we get to really make a difference in programs adequately compensating their staff. 2. Mandating advocate benefit increases (health, retirement, vision, dental, day care accounts, etc.) 3. Contracting for legal services for victims 4. Youth programming 5. Human Trafficking focused programming Again, nothing in Iowa is set in stone, but this is the direction we re moving. We are getting input from our two statewide coalitions, our programs, victims and other key stakeholders before moving in any one direction. [North Carolina; Karen Jayson] Our advisory committee met last week. I will review the notes with Misty and list the recommendations they came up with for the additional funding. If there is anything in particular you had questions about, let me know. [Massachusetts; Dan Cooper] In Massachusetts we are in the initial planning stages. As noted by our colleague from Iowa we are fortunate that we are also in an active procurement cycle (accepting applications) for the next three years. This will hopefully allow us the ability to expand funding to long standing proven programs, to support programs that have been on the periphery in previous funding cycles, and to explore much needed infrastructure improvements. Some areas we re exploring includes at a minimum: A look at one time technology investments Expansion of training initiatives for the field of victim services

2 Expansion of services that previously received less priority (and funding) such as Legal Services, Emergency Housing, LEP specific services, and Client transportation. These are areas that have been highlighted in a needs assessment we ve conducted over the past year. Areas of planning and impact that need extensive consideration: Our staffing levels Our infrastructure (look at e-grant solutions) Our physical space (we have no room for new staff) Our sub recipients situation As discussed during the webinar Sub recipients may not have access to additional funding (for match) and like us, they are most likely bursting at the seams for space should they expand staffing Some of the avenues where we have begun work (in addition to the regular procurement): ¾ Identify and bring together key funding partners (MOVA is independent managing only VOCA assistance). VAWA, JAG, Victim Compensation are managed by separate administrations. We recognize that any influx of funding via Victim Assistance and the types of services supported will have an impact on the other funders long-term plans. ¾ We have also reached out to our New England VOCA cohort (NH, CONN, VT, ME, RI) with the hopes of engaging in this conversation and finding common solutions on a smaller, yet regional scale. We are also actively monitoring the NAVAA listserv for plans, suggestions, ideas, etc. [Kentucky; Janet Brock] Until we know if this increase will be permanent, we are considering running a separate application cycle for one-time, non-recurring projects (i.e. Technology (equipment, software) Infrastructure (repair, replacement, equipment, furniture, vehicles). We would love to give salary increases and/or allow hiring of additional staff, and fund new innovative programs, but need to know if this is sustainable. [Ohio; Michael Sheline] Ohio s Plan for Increase In mid-december, 2014, the United States House and Senate both voted to pass a $1.1 trillion omnibus appropriations bill. Included in the bill, which President Obama has signed, was a significant change in the funding level of VOCA awards. The federal fiscal year 2014 VOCA allocation was $745 million; this appropriations bill increases that allocation to $2.361 billion for federal fiscal year 2015, which more than triples the national funding availability for VOCA grants. We will be able to more accurately estimate Ohio s allocation over the next few months; however we are expecting our VOCA allocation to be approximately $48 million, a significant shift from our five-year average of $14.9 million. As Ohio effectively manages a sizable increase, the ongoing unknown is whether increased funding will be sustained or if it will represent a one-time windfall. While we hope for sustained levels of funding, without this information we must provide increases conservatively to subrecipients. Continuation funding will be higher, but we will ensure funding is sustainable to subgrantees for at least two years. Much of the VOCA funding will be used for expansion and targeted projects to assist underrepresented populations of high need.

3 This increased funding will be used by the Ohio Attorney General s Office to significantly and positively impact the lives of victims and survivors of crime throughout the state. Please see our following plan and timeline to prepare for this historic funding opportunity. January, 2015 Survey all subrecipients to determine needs, thoughts, and ideas. Identify the pie-in-thesky requests for funding should grantees have vastly increased funds available. What are the most important projects and needs facing communities throughout Ohio? Analyze survey data. Identify trends of common needs. Meet with statewide organizations. Define grant goals, share information, and solicit feedback. Have statewide organizations begin preparing their constituents for increased oversight and emphasis on evidence-based practices. Discuss revised performance measures and forthcoming changes in VOCA regulations. February, 2015 Sustainability training via webinar. How will grantees ensure that gains made with significantly larger grants do not falter should funding return to historical levels? Advise grantees to plan goals that emphasize the building of infrastructure and collaborations instead of personnel costs. Provide guidance to Boards of Directors via or letters. Provide guidance on the increased oversight that will be a part of larger grants. Advise that Boards plan strategically to create change in their communities with the knowledge that increased funding may not be permanent. Publicly release updated VOCA regulations and details on performance reporting. The updated regulations are widely expected to clarify restrictions on prevention work, among others. Provide information about performance reporting changes, including the expected data that will be reported. March, 2015 Code and deploy the performance reporting system. After DOJ has finalized the performance measures for grantees, begin work to prepare, test, and deploy a subrecipient portal where recipients can submit the required data. The existing grant management system will be able to produce an output which can be provided to DOJ. Complete by June, 2015 Develop targeted grant proposals. From feedback, identify specific needs and projects which grant funding could be used to address. Current proposals include ADA compliance, technology, limited English proficiency communications, individuals with disability communications, case management, legal services, relocation of domestic violence survivors, and services for homeless youth. Convene the State Victim Assistance Committee for its annual policy meeting. Update the Committee on funding changes and proposed direction. Ensure clear, uniform, and well-informed guidance to subgrantees. Advise on future plans and solicit feedback. April, 2015 Convene a minimum of five regional open house meetings throughout the state. Specifically target organizations not currently receiving VOCA funding as well as those unable to attend the training sessions at our annual Two Days in May Victim Service conference. Regional meetings will cover funding availability, compliance, new regulations, performance measures, and other grant matters. Grant staff will be available to address specific organizational needs on-site.

4 May, 2015 Provide resources at the Two Days in May conference. Pre-workshop grant clinics and a three-hour workshop during the conference will be provided. Grant staff will be available throughout the day with office hours to address specific organizational needs. The clinics and workshop will cover funding availability, compliance, new regulations, performance measures, and other grant matters. Begin accepting grant applications. Grantees will submit the typical application, with additional optional addendums for targeted grants identified in March. This will make the application concise and simple for all organizations. June, 2015 Hire additional grant compliance staff within the AGO. Salary costs will be paid out of VOCA administrative funds, estimated to be $2.4 million. Two auditors and one clerk will be hired to cover needed oversight and appropriate fund management. Use scoring rubrics and funding priorities to review grant requests. Organize and submit funding proposals to Administration and the State Victim Assistance Committee. Identify funded priorities and allocate appropriately to ensure project success. Complete by August, 2015 August, 2015 Final internal compliance reviews. Verify the validity of submitted documentation. Query all applicants against excluded parties and charitable compliance databases. Overall, ensure all potential grantees meet eligibility and other requirements to receive grant funding. Programmatic and fiscal staff, as well as management, are required to approve all proposed grants and budgets. September, 2015 Present funding proposals to the State Victim Assistance Committee, who must, by statute, vote to recommend funding to the Attorney General. Answer questions and resolve differences to secure grants for victim service providers. Final review and approval of State Victim Assistance Committee recommendations by Attorney General DeWine. Final award determinations have been set at this point. Grantees electronically accept their awards in a paperless and secure web portal. Assurances and grant agreements are signed and submitted. October, 2015 Grants staff review signed agreements and associated documentation for completeness and potential eligibility concerns. Management approves the activation of the grant awards once all reviews are complete. Mandatory new program orientation training held for all organizations receiving funding for the first time. Covered topics will include policies and procedures, grant management system overview, and programmatic reporting. Continuous Fiscal review of high risk organizations as determined by the risk assessment tool. Highest priority for financial audit will be those organizations with historical compliance problems, relevant external audit findings, and other risk indicators. Fiscal review of all organizations receiving funding for the first time, with the purpose of correcting potential mistakes as early as possible. New grantees will be in high contact with fiscal and programmatic staff to ensure quality objectives are being met.

5 [Massachusetts; Dan Cooper] Question for the group re: Tech/infrastructure I know that allowable costs are always subject of much conversation in our circle. Could folks chime in and help me understand generally speaking, how VOCA Administrators would distribute a significant percentage of funds for tech when VOCA in the current guidelines (I believe) is intended for Direct Service? Or would you all simply consider the tech to be a direct cost? Please correct me if I am under the wrong impression. In Massachusetts we have worked off a 75/25 Direct/Indirect split for sub recipients. Technology expenditures have long been considered an indirect or administrative cost. I believe this evolved from interpretation of the VOCA Guidelines where these costs fall under other allowable costs. In order to shift to a one time (or ongoing) investment in technology expansive enough to capitalize on any increase in funding we may have to re-work our internal policies and procedures. It is helpful to understand if other administrators currently consider technology investments to be direct costs. This question would also apply to training costs (for sub recipients) which we have also long considered as indirect/administrative costs. [Ohio; Michael Sheline] My basic belief is you cannot provide effective direct service without effective technology. We consider it direct not administrative - victims use computers to fill out comp apps etc. [Alabama; Derek Yarbrough] My understanding is that anything that is not listed as unallowable in the guidelines could be considered allowable, whether it benefits a victim directly or indirectly. Based on that notion, as long as the technology is being used to provide services to victims then we would allow it. [Indiana; Sharon Langlotz] We agree and have in the past allowed service providers to purchase necessary equipment/technology needs - but what do you and Derek think about contractor fees software development? We are considering a fairly large project to improve connectivity and data collection but will need to customize it. [NAVAA; Steve Derene] I don t think it really matters how you want to classify technology as direct, indirect or administrative costs. Technology, including software, are clearly allowable under both current Guidelines and proposed regulations as long as it s used for victim services. Here s what the proposed regulations say, (e) Automated systems and technology. VOCA funds may be used for automated systems and technology that support delivery of direct services to victims. Examples are automated information and referral systems, systems that allow communications among victim service providers, automated case-tracking and management systems, and victim notification systems. Costs may include personnel, hardware, and other expenses, as determined by the State administering agency. As was discussed during the webinar, there is a great pent-up need in the field for major investments in technology (look at the survey information I sent you) for a good indication of the types of needs there are. I was struck by how many local programs are still using Windows XP, even though that is no longer supported by Microsoft. Also, many, many requests for tablets. Not only are these good investments, but I think they afford you a valuable tool in managing you use of VOCA funds to avoid deobligations.

6 [Nevada; Dorothy Edwards] I am finding these discussions very helpful. As a new manager over the grants unit in Nevada, your collective expertise is appreciated. I am releasing the RFP for our VOCA and Family Violence Funding at the end of this month and think I will follow the idea of being conservative with the VOCA amount and once we determine exactly what the increase is, do a separate release. Most of our sub recipients have heard about the award and are asking about it although with our particular demographics, service array and existing providers are one of our challenges. I am concerned at their ability to plan appropriately to spend a significant increase. [New York; Elizabeth Cronin] we are still working on our ideas as well. We definitely want to focus on technology because it s a great opportunity for that and because so many of the programs need assistance for this. We also want to consider innovative and evidence based practice programs perhaps looking to issue an RFP to fund pilot programs with the understanding that they will have to show the ability to be self-sufficient if this large amount of funding was a one-off. We also had to do an across the board cut to all those programs that were awarded funding under our latest RFP so we may be able to restore that funding. [Alabama; Derek Yarbrough] In response to Sharon: I guess it depends on how you are looking to fund this project? Out of the 5% the state can keep or the amount that has to be sub-awarded? I feel that one could make the argument of funding it out of either pot. An improved and more detailed data collection system would decrease the burden on the state from a reporting standpoint, especially with the new performance measures they are going to release. An improved data collection could also potentially help monitor subgrantee performance, improve strategic planning and if we coordinate with state stakeholders and other federal programs, i.e. VAVA, SASP, FVPSA or RPE, on the project then this would benefit crime victims across the entire state. If you sub-award the data collection system, say to a state coalition, then it you still would require coordination with other state coalitions (DV, SA and CACs). Even if you sub-award it you can still provide the same general benefits as stated above. There are other things to consider; what kind of data collection system will you implement, training users for the new system, maintenance and costs not associated with initial startup. This comes from a state that doesn t have an e-grants system and that is not as technically advanced as some other states might be. In response to Dorothy: I share the same concerns about our existing providers and it is a real concern about their ability to plan appropriately concerning this funding. Simply, I know we have to be more stringent in our monitoring and making sure that the Program guidelines and federal and state regulations are strictly adhered to. I m thinking that for right now that I have to convey to subgrantees that this is a class half empty thing and that once these funds are gone they are gone. Until we know that this level of funding continues, subgrantees have to assume that it will return back to previous funding levels. Just my 2 cents,