HomeMy WebLinkAboutReports - 2023.05.11 - 38222
AGENDA ITEM: Acceptance from the Michigan Department of State Police for the 2023 Paul
Coverdell Forensic Sciences Improvement Grant Program
DEPARTMENT: Sheriff’s Office
MEETING: Board of Commissioners
DATE: Thursday, May 11, 2023 6:00 PM - Click to View Agenda
ITEM SUMMARY SHEET
COMMITTEE REPORT TO BOARD
Resolution #2023-2823
Motion to accept the 2023 Coverdell grant award in the amount of $72,877 for the period of April 1,
2023 through March 31, 2024 and transfer $120,598 from the Law Enforcement Enhancement Lab
Fees Restricted Fund (#21340) to continue one (1) Special Revenue, Full-Time Eligible Forensic
Lab Investigator position #11785; further amend the FY 2023 budget as detailed in the attached
Schedule A.
ITEM CATEGORY SPONSORED BY
Grant Penny Luebs
INTRODUCTION AND BACKGROUND
The Oakland County Sheriff’s Office (OCSO) has been awarded 2023 Paul Coverdell Grant funding
in the amount of $72,877 from the State of Michigan, Department of State Police for the period April
1, 2023 through March 31, 2024. The Sheriff's Office provides forensic laboratory services to
Oakland County and its neighboring communities. Grant funding in the amount of $42,269 will be
used to purchase opioid-specific test kits and $30,608 will be used to continue funding a portion of
one (1) Special Revenue (SR) Full-Time Eligible (FTE) Forensic Lab Investigator (position #11785)
in the Sheriff's Office Investigative & Forensic Services Division, Forensic Services Unit. The
balance of funding, $120,598 for position #11785 and $279 for testing kits, totaling $120,877, will be
transferred from the Law Enforcement Enhancement Lab Fees Restricted Fund (#21340)..
Acceptance of this grant does not obligate the County to any future commitment, and continuation of
the Special Revenue position in the grant is contingent upon future levels of grant funding.
BUDGET AMENDMENT REQUIRED: Yes
Committee members can contact Michael Andrews, Policy and Fiscal Analysis Supervisor at
248.425.5572 or andrewsmb@oakgov.com, or the department contact persons listed for additional
information.
CONTACT
Curtis Childs
Gaia Piir, Sheriff Fiscal Officer
ITEM REVIEW TRACKING
Penny Luebs, Board of Commissioners Created/Initiated - 5/12/2023
AGENDA DEADLINE: 05/11/2023 6:00 PM
ATTACHMENTS
1. 2023 Coverdell Forensic Science Grant Schedule A
2. Grant Review Sign-Off
3. Coverdell OCSO SAA Contract FY23_Redacted
COMMITTEE TRACKING
2023-05-02 Public Health & Safety - Forward to Finance
2023-05-03 Finance - Recommend to Board
2023-05-11 Board of Commissioners - Adopted
Motioned by: Commissioner Angela Powell
Seconded by: Commissioner Robert Hoffman
Yes: David Woodward, Michael Spisz, Michael Gingell, Penny Luebs, Karen Joliat, Kristen
Nelson, Christine Long, Robert Hoffman, Philip Weipert, Gwen Markham, Angela Powell, Janet
Jackson, Gary McGillivray, William Miller III, Yolanda Smith Charles, Charles Cavell, Brendan
Johnson, Ajay Raman (18)
No: None (0)
Abstain: None (0)
Absent: Marcia Gershenson (1)
Passed
Oakland County, Michigan
SHERIFF'S OFFICE - 2023 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT PROGRAM
Schedule "A" DETAIL
R/E Fund Name Division Name
Fund #
(FND)
Cost Center
(CCN) #
Account #
(RC/SC)
Program #
(PRG)
Grant ID (GRN)
#
Project ID #
(PROJ)
Region
(REG)
Budget
Fund
Affiliate
(BFA)
Ledger
Account
Summary Account Title
FY 2023
Amendment
FY 2024
Amendment
FY 2025
Amendment
R Sheriff LE Enhancement Investigative & Forensic Svcs FND21340 CCN4030901 RC665882 PRG116240 GRN-1004116 665882 Planned Use of Balance $120,598 $-$-
Total Revenues $120,598 $-$-
E Sheriff LE Enhancement Investigative & Forensic Svcs FND21340 CCN4030901 SC788001 PRG116240 GRN-1004116 BFA11005 788001 Transfers Out $120,598 $-$-
Total Expenditures $120,598 $-$-
R Law Enforcement Grants Investigative & Forensic Svcs FND11005 CCN4030901 RC610313 PRG116240 GRN-1004117 610000 Federal Operating Grants $72,877 $-$-
R Law Enforcement Grants Investigative & Forensic Svcs FND11005 CCN4030901 RC695500 PRG116240 GRN-1004116 BFA21340 695500 Transfers In - Sheriff LE Enhancement 120,598 --
Total Revenues $193,475 $-$-
E Law Enforcement Grants Investigative & Forensic Svcs FND11005 CCN4030901 SC702010 PRG116240 GRN-1004117 702000 Salaries $95,301 $-$-
E Law Enforcement Grants Investigative & Forensic Svcs FND11005 CCN4030901 SC722900 PRG116240 GRN-1004117 722000 Fringe Benefit Adjustments 55,905
E Law Enforcement Grants Investigative & Forensic Svcs FND11005 CCN4030901 SC750280 PRG116240 GRN-1004117 750000 Laboratory Supplies 42,269
Total Expenditures $193,475 $-$-
GRANT REVIEW SIGN-OFF – Sheriff’s Office
GRANT NAME: 2023 Paul Coverdell Forensic Sciences Improvement Grant Program
FUNDING AGENCY: Michigan State Police
DEPARTMENT CONTACT: Kent Gardner/(248) 858-5019
STATUS: Grant Acceptance (Greater than $10,000)
DATE: 04/12/2023
Please be advised the captioned grant materials have completed internal grant review. Below are the returned comments.
The Board of Commissioners’ liaison committee resolution and grant acceptance package (which should include this sign-
off and the grant agreement/contract with related documentation) may be requested to be placed on the agenda(s) of the
appropriate Board of Commissioners’ committee(s) for grant acceptance by Board resolution.
DEPARTMENT REVIEW
Management and Budget:
Approved – Sheryl Johnson (04/11/2023)
Human Resources:
Approved by Human Resources. Continues one position with no changes - Heather Mason (04/07/2023)
Risk Management:
Approved. No insurance requirements in documents. – Robert Erlenbeck (04/10/2023)
Corporation Counsel:
Approved – Heather Lewis (04/10/2023)
FY2023 Page 1 of 15
Paul Coverdell Forensic Science Improvement
GRANT CONTRACT
Grant Agreement
hereinafter referred to as the “Agreement”
between
Michigan State Police
hereinafter referred to as the “Department”
and
County of Oakland
1200 North Telegraph Road, Pontiac, Michigan 48341
Federal I.D. Number: 38-6004876
hereinafter referred to as the “Contractor”
for
Oakland County Sheriff’s Office
Grant Project Number: CFS-6-23
I. Period of Agreement:
This Agreement shall commence on April 1, 2023, and continue through March 31, 2024.
This Agreement is in full force and effect for the period specified.
All projects must be initiated within 60 days of the start date of this Agreement.
II. Funding Source and Agreement Amount:
This Agreement is designated as a subrecipient relationship with the following stipulations:
A. Including federal funds and required local match, the total amount of this Agreement is $72,877.
The Department, under the terms of this Agreement, will provide federal pass-through funding not to exceed
$72,877.
B. The Catalog of Federal Domestic Assistance (CFDA) number is 16.742.
C. The CFDA Title is Paul Coverdell Forensic Science Improvement Grants Program.
D. The federal agency name is U.S. Department of Justice, Office of Justice Programs, Bureau of Justice
Assistance.
E. The federal grant award number is 15PBJA-22-GG-01983-COVE.
F. The federal program title is Paul Coverdell Forensic Science Improvement Grants Program.
III. Grant Summary:
The Contractor’s Grant Summary is outlined in Attachment 1, which is part of this Agreement through reference.
IV. Statement of Work:
The Contractor agrees to undertake, perform, and complete the services described in Attachment 2, which is part of
this Agreement through reference. Any change to the Statement of Work, by either the Contractor or Department,
requires a formal Amendment.
V. Project Timeline:
The Contractor agrees to undertake, perform, and complete the services within the timeline described in Attachment
2-A, which is part of this Agreement through reference. Any change to the Project Timeline, by either the
Contractor or Department, requires a formal Amendment.
VI. Program Budget:
The agreed upon Program Budget for this Agreement is referenced herein as Attachment 3, which is part of this
Agreement through reference. Any change to the Program Budget, by either the Contractor or Department,
FY2023 Page 2 of 15
requires a formal Amendment.
Budget deviation allowances are not permitted.
VII. Amendments:
Any change proposed by the Contractor which would affect the Department funding of any project, in whole or in
part, must be submitted in writing, to the Department for approval immediately upon determining the need for such
change. Changes made to this Agreement are only valid if made in writing and accepted by both the Contractor
and the Department.
VIII. Contractor Responsibilities:
The Contractor, in accordance with the general purposes and objectives of this Agreement, will:
A. Publication Rights:
1. Give recognition to the Department in any and all publications, papers and presentations arising from the
program (including from subcontractors) herein by placing the following disclaimer on any and all
publications, papers and presentations:
This project is supported by the FY22 Paul Coverdell Forensic Sciences Improvement Grant Program
#15PBJA-22-GG-01983-COVE, awarded by the Bureau of Justice Assistance (BJA), Office of Justice
Programs, U.S. Department of Justice (DOJ), and administered by the Michigan State Police (MSP).
Points of view or opinions contained within this document do not necessarily represent the official position
or policies of the DOJ or MSP.
The Department shall, in return, give recognition to the Contractor when applicable.
2. Where activities supported by this Agreement produce books, films, or other such copyrightable materials
issued by the Contractor, the Contractor may copyright such but shall acknowledge that the Department
reserves a royalty-free, non-exclusive, and irrevocable license to reproduce, publish, and use such
materials as well as to authorize others to reproduce and use such materials. This cannot include service
recipient information or personal identification data.
3. Any copyrighted materials or modifications bearing acknowledgment of the Department’s name must be
approved by the Department prior to reproduction and use of such materials.
B. Reporting Responsibilities:
Failure to comply with any reporting responsibilities identified in this Agreement may result in withholding
grant payment(s) or the cancellation of grant award. Contractor’s lack of compliance will also be taken into
account when considering future grant applications to, and awards from, the Department.
C. Uniform Crime Report (UCR):
The Contractor, and all of its subcontractors, must comply with Michigan Public Act 319 of 1968, as amended.
This law requires county sheriff’s departments, as well as city, village, and township police departments to
submit monthly UCR data to the Department.
D. Financial Reporting Requirements:
Financial reporting requirements shall be followed as defined within this section.
1. Reimbursement Method/Mechanism:
a. All Contractors must register as a vendor to receive State of Michigan payments as Electronic
Funds Transfers (EFT)/Direct Deposits. Vendor registration information is available on the State
of Michigan SIGMA Vendor Self Service (VSS) website located at
https://sigma.michigan.gov/webapp/PRDVSS2X1/AltSelfService.
b. This Agreement is reimbursement only. Contractor must document expenditures paid by local
sources before requesting reimbursement from the Department.
c. Reimbursement from the Department is based upon the understanding Department funds will be
paid up to the total Department allocation as agreed upon in the approved Budget. Department
FY2023 Page 3 of 15
funds are the first source after the application of fees and earmarked sources unless a specific
local match condition exists.
d. Should the Contractor discover an error in a previous reimbursement request, the Contractor
shall immediately notify the Department and refund to the Department any funds not authorized
for use under this Agreement and any payments or funds advanced to the Contractor in excess of
allowable reimbursable expenses.
2. Financial Status Report (FSR) Submission:
Once the Agreement has been signed and accepted, regardless of when this occurs, the Contractor is
responsible for preparing and submitting a FSR for each month of the Agreement period. Monthly
FSRs must be prepared and submitted to the Department, no later than 30 days after the close of each
calendar month. An example is found in Attachment 5, which is part of this agreement through
reference. Each month’s reimbursement request may only contain expenses from that month.
Reimbursement requests that include more than one month’s expenditures may not be granted and will
be returned to the Contractor for explanation and/or correction and re-submission.
3. Unobligated Funds:
Any unobligated balance of funds held by the Contractor at the end of the Agreement period will be
returned to the Department or treated in accordance with instructions provided by the Department.
4. Program Income:
The United States Department of Justice (DOJ) regulations allow Contractors to keep funds (program
income) derived from grant activities, so long as these funds are used for the same purposes as the
grant project. In the absence of such regulations, these funds would be required to be returned to the
DOJ.
Program income means the gross income earned by the Contractor during the Agreement period as a
direct result of the grant project.
All income generated as a direct result of a Department-funded project shall be deemed program
income.
Program income may be used to further program objectives under this Agreement or may be refunded
to the Department. Program income must be used for the purposes of, and under the conditions
applicable to, the award specified in this Agreement. Program income may only be used for allowable
program costs.
Asset forfeiture and treatment/lab fees are the most prominent program income derived from grant
activity. DOJ regulations require that program income be held in the custody of a governmental entity,
with reporting on those funds to the State Administrative Agency (the Department).
When applicable, ADM-208B, Program Income Reports must be filled out and submitted to the
Department quarterly.
Any program not earning program income must fill out and submit to the Department an ADM-208A,
Program Income Waiver Report within 30 days of the acceptance of this Agreement.
5. Audits:
This section applies to Contractors designated as subrecipients. Contractors designated as vendors
are exempt from the provisions of this section.
a. Single Audit:
Contractors that expend $500,000 or more in federal awards in the current fiscal year or expend
$750,000 or more in federal funds in a fiscal year after December 26, 2014 must submit a Single
Audit prepared consistent with the Single Audit Act Amendments of 1996, and Office of
Management and Budget (OMB) Circular A-133, “Audits of States, Local Governments, and Non-
Profit Organizations,” as revised or 2 CFR 200.501. Contractors must also submit a Corrective
Action Plan for any audit findings that impact Department-funded programs and management
letter (if issued) with a response.
FY2023 Page 4 of 15
b. Financial Statement Audit:
Contractors exempt from the Single Audit requirements that receive $500,000 or more in total
funding from the Department in state and federal grant funding must submit to the Department a
Financial Statement Audit prepared in accordance with generally accepted auditing standards
(GAAS). Contractors exempt from the Single Audit requirements that receive less than $500,000
of total Department grant funding must submit to the Michigan Department of Treasury a
Financial Statement Audit prepared in accordance with GAAS if the audit includes disclosures
that may negatively impact Department-funded programs including, but not limited to fraud,
financial statement misstatements, and violations of contract and grant provisions.
c. Other Audits:
The Department or federal agencies may also conduct or arrange for “agreed upon procedures”
or additional audits to meet their needs.
E. Performance/Progress/PMT Report Requirements:
The progress reporting methods, as applicable, shall be followed as described in Attachment 4, which is
part of this Agreement through reference.
Progress reporting is due no later than 20 days after the end of each quarter to the Department. The
specific requirements will be provided to the Contractor within 45 days of the start date of the Agreement.
When applicable, additional programmatic Progress Reports must be submitted to the Department no
later than 20 days after the end of each quarter.
F. Equipment Purchases and Title:
Any Contractor equipment purchases supported in whole or in part through this Agreement must be listed
in an Equipment Inventory Schedule. Equipment means tangible, non-expendable, personal property
having useful life of more than one year and an acquisition cost of $5,000 or more per unit. Title to items
having a unit acquisition cost of less than $5,000 shall vest with the Contractor upon acquisition. The
Department reserves the right to retain or transfer the title to all items of equipment having a unit
acquisition cost of $5,000 or more, to the extent that the Department’s proportionate interest in such
equipment supports such retention or transfer of title.
All purchases supported in whole or in part through this Agreement must use procurement procedures
that conform to the Contractor’s local requirements.
G. Employee Time Certification:
It is the Contractor’s obligation to notify the Department immediately when a grant-funded employee
(including employees of subcontractors):
• Is disabled or deceases while having been assigned to a grant-funded position;
• Is removed or reassigned from a grant-funded position; and/or,
• Is unable to report to work due to injury or illness not related to job performance (and is not
replaced within 30 days by another employee).
Contractor’s failure to comply with notification to the Department could result in loss of position funding
from the Department.
H. Record Maintenance/Retention:
Contractor must maintain adequate program and fiscal records and files, including source documentation
to support program activities and all expenditures made under the terms of this Agreement, as required.
Assure that all terms of this Agreement will be appropriately adhered to and that records and detailed
documentation for the project or program identified in this Agreement will be maintained (may be off-site)
for a period of not less than four years from the date of grant closure, the date of submission of the final
FSR or until litigation and audit findings have been resolved. All retention record guidelines set by the
local jurisdiction (Contractor) must be adhered to if they require additional years beyond retention
guidelines stated herein.
FY2023 Page 5 of 15
I. Authorized Access:
Contractor must permit upon reasonable notification and at reasonable times, access by authorized
representatives of the Department, Program Evaluators (contracted by the Department), Federal Grantor
Agency, Comptroller General of the United States and State Auditor General, or any of their duly
authorized representatives, to records, files and documentation related to this Agreement, to the extent
authorized by applicable state or federal law, rule, or regulation.
The Department may conduct on-site monitoring visit(s) and/or grant audit(s) any time during the grant
period. All grant records and personnel must be made available during any visit, including
subcontractors, if requested.
The Department may request that a funded program be evaluated by an outside evaluation team
contracted by the Department. Contractors shall work cooperatively with the evaluation team in such a
manner that the program be able to be fully reviewed and assessed.
J. Subcontractor/Vendor Monitoring:
The Contractor must ensure each of its subcontractors comply with the Single Audit Act of 1996, as
amended, 31 U.S.C. 7501 et seq. requirements and must issue management decisions on audit findings
of their subcontractors as required by OMB Circular A-133. The Contractor is responsible for reviewing
all single audit adverse findings and ensuring corrective actions are implemented. Contractor will ensure
subcontractors forward all single audits covering grant funds administered through the Department to the
Contractor.
The Contractor must ensure subgrantees are expending grant funds appropriately as approved and as
specified through this Agreement, and must conduct monitoring activities to ensure compliance with all
associated laws, regulations and provisions as well as ensure that performance goals are achieved.
Contractor must ensure for-profit subcontractor compliance as required by OMB Circular A-133, Section
210(e). Contractor must ensure that transactions with vendors comply with laws, regulations, and
provisions of contracts or grant agreements in compliance with OMB Circular A-133, Section 210(f).
1. Subcontracts:
Assure for any subcontracted service, activity, or product:
a. That the Contractor will submit copies of all executed subcontracts to the Department within 60
days of the execution of this Agreement. Subcontracts should cover all personnel contained in
the “contractual” line item within the grant budget. Each listed agency shall have its own
subcontract signed by the Contractor and an employee of the subcontracted agency that is
authorized to enter into legally binding contracts for the entity receiving funds. The failure to
submit these documents to the Department within 60 days may result in withholding future
payment or other penalties, as determined by the Department.
b. That a written subcontract is executed by all affected parties prior to the initiation of any new
subcontract activity. Exceptions to this policy may be granted by the Department upon written
request within 30 days of execution of this Agreement.
c. That any executed subcontract to this Agreement shall require the subcontractor to comply with
all applicable terms and conditions of this Agreement, including all Certifications and Assurances
referenced in this Agreement.
d. That, in the event of a conflict between this Agreement and the provisions of the subcontract, the
provisions of this Agreement shall prevail. A conflict between this Agreement and a subcontract,
however, shall not be deemed to exist where the subcontract:
i. Contains additional non-conflicting provisions not set forth in this Agreement;
ii. Restates provisions of this Agreement to afford the Contractor the same or substantially the
same rights and privileges as the Department; or,
iii. Requires the subcontractor to perform duties and/or services in less time than that afforded
the Contractor in this Agreement.
e. That the subcontract does not affect the Contractor’s accountability to the Department for the
subcontracted activity.
FY2023 Page 6 of 15
f. That any billing or request for reimbursement for subcontract costs is supported by a valid
subcontract and adequate source documentation on costs and services. All subcontractors must
submit requests for reimbursement to the Contractor in a timely manner such that the Contractor
can include these requests on the proper month’s FSR. Subcontractors must be paid within
30 days of invoice by the subcontractor.
K. Notification of Modifications:
Contractor must provide timely notification to the Department, in writing, of any action by its governing
board or any other funding source that would require or result in significant modification in the provision of
services, funding, or compliance with operational procedures.
L. Software Compliance:
Contractor must ensure software compliance and compatibility with the Department’s data systems for
services provided under this Agreement including, but not limited to: stored data, databases and
interfaces for the production of work products, and reports. All required data under this Agreement shall
be provided in an accurate and timely manner without interruption, failure or errors due to the inaccuracy
of the Contractor’s business operations for processing date/time data.
M. Human Subjects:
Contractor agrees that prior to the initiation of research, Contractor will submit Institutional Review Board
(IRB) application material for all research involving human subjects conducted in programs sponsored by
the Department or in programs which receive funding from or through the state of Michigan, to a federally
assured IRB for review and approval. All paperwork involving the IRB must be submitted to the
Department.
N. Notification of Criminal or Administrative Investigations/Charges:
If any employee of the Contractor associated with this grant project becomes aware of a criminal or
administrative investigation or charge that directly or indirectly involves grant funds referenced in this
Agreement, the Contractor shall immediately notify the Department's contract manager in writing
that such an investigation is ongoing or that a charge has been issued.
O. Paul Coverdell Forensic Sciences Improvement Grant Local Funding:
The Contractor, and all of its subcontractors, must apply for any and all direct Paul Coverdell Forensic
Sciences Improvement Grant funding from the DOJ for which it is eligible. The failure to submit the
application is reason for termination of this Agreement.
IX. Department Responsibilities:
The Department, in accordance with the general purposes, objectives and terms and conditions of this Agreement,
will provide reimbursement based upon appropriate reports, records and documentation maintained by the
Contractor.
X. Department Contract Manager/Administrator of the Agreement:
The individual acting on behalf of the Department in administering this Agreement as the Contract Manager is:
Ms. Nancy Becker Bennett, Division Director
Michigan State Police
Grants and Community Services Division
P.O. Box 30634
Lansing, MI 48909-0634
Telephone: (517) 284-3208
Fax: (517) 284-3216
Email: beckern@michigan.gov
XI. Agreement Suspension/Termination:
The Department and/or the Contractor may suspend and/or terminate this Agreement without further liability or
penalty to the Department for any of the following reasons:
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A. This Agreement may be suspended by the Department if any of the terms of this Agreement are not adhered to.
Suspension requires immediate action by the Contractor to comply with this Agreement terms; otherwise,
termination by the Department may occur.
B. Failure of the Contractor to make satisfactory progress toward the goals, objectives, or strategies set forth in the
Agreement.
C. Proposing or implementing substantial plan changes to the extent that, if originally submitted, the application
would not have been selected for funding.
D. Filing false certification in this Agreement or other report or document.
E. This Agreement may be terminated by either party by giving 15 days written notice to the other party. Such
written notice will provide valid, legal reasons for termination along with the effective date.
F. This Agreement may be terminated immediately if the Contractor, an official of the Contractor or an owner is
convicted of any activity referenced in Section VIII, N, of this Agreement during the term of this Agreement or
any extension thereof.
XII. Final Reporting Upon Termination:
Should this Agreement be terminated by either party, within 30 days after the termination, the Contractor shall
provide the Department with all financial, performance and other reports required as a condition of this Agreement.
The Department will make payments to the Contractor for allowable reimbursable costs not covered by previous
payments or other state or federal programs. The Contractor shall immediately refund to the Department any funds
not authorized for use and any payments or funds advanced to the Contractor in excess of allowable reimbursable
expenditures.
XIII. Severability:
If any provision of this Agreement or any provision of any document attached to or incorporated by reference is
waived or held to be invalid, such waiver or invalidity shall not affect other provisions of this Agreement.
XIV. Liability:
A. All liability to third parties, loss, or damage as a result of claims, demands, costs, or judgments arising out of
activities, such as direct service delivery, to be carried out by the Contractor in the performance of this
Agreement shall be the responsibility of the Contractor, and not the responsibility of the Department, if the
liability, loss, or damage is caused by, or arises out of, the actions or failure to act on the part of the
Contractor, any subcontractor, anyone directly or indirectly employed by the Contractor, provided that nothing
herein shall be construed as a waiver of any governmental immunity that has been provided to the Contractor
or its employees by statute or court decisions.
B. All liability to third parties, loss or damage as a result of claims, demands, costs or judgments arising out of
activities, such as the provision of policy and procedural direction, to be carried out by the Department in the
performance of this Agreement shall be the responsibility of the Department, and not the responsibility of the
Contractor, if the liability, loss, or damage is caused by, or arises out of, the action or failure to act on the part
of any Department employee or agent, provided that nothing herein shall be construed as a waiver of any
governmental immunity by the state of Michigan, its agencies (the Department) or employees as provided by
statute or court decisions.
C. In the event liability to third parties, loss, or damage arises as a result of activities conducted jointly by the
Contractor and the Department in fulfillment of their responsibilities under this Agreement, such liability, loss,
or damage shall be borne by the Contractor and the Department in relation to each party's responsibilities
under these joint activities, provided that nothing herein shall be construed as a waiver of any governmental
immunity by the Contractor, the state of Michigan, its agencies (the Department) or their employees,
respectively, as provided by statute or court decisions.
FY2023 Page 8 of 15
XV. Special Conditions:
A. This Agreement is valid upon approval and execution by the Department.
B. This Agreement is conditionally approved subject to and contingent upon the availability of funds.
C. The Department will not assume any responsibility or liability for costs incurred by the Contractor prior to the full
execution of this Agreement.
XVI. Certifications and Assurances:
These Certifications and Assurances are applicable to the Contractor and all subcontractors of the Contractor. It is
the Contractor’s responsibility to ensure subcontractors are adhering to the Certifications and Assurances. Failure
to do so may result in termination of grant funding or other remedies.
A. Certifications:
Contractors should refer to the regulations cited below to determine the certification to which they are required
to attest. Acceptance of this Agreement provides for compliance with certification requirements under 28
C.F.R. Part 69, "New Restrictions on Lobbying," 28 C.F.R. Part 67, "Government-wide Debarment and
Suspension (Non-procurement),” and 28 C.F.R. Part 83, “Government-wide Requirements for Drug-Free
Workplace (Grants)."
B. Lobbying:
As required by Section 1352, Title 31 of the U.S. Code, and implemented at 28 C.F.R. Part 69, for persons
entering into a grant or cooperative agreement over $100,000, as defined at 28 C.F.R. Part 69, the Contractor
certifies that:
1. No federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any
person for influencing or attempting to influence an officer or employee of any agency, a Member of
Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection
with the making of any federal grant, the entering into of any cooperative agreement, and the extension,
continuation, renewal, amendment, or modification of any federal grant or cooperative agreement;
2. If any funds other than federal appropriated funds have been paid or will be paid to any person for
influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an
officer or employee of Congress, or an employee of a Member of Congress in connection with this
federal grant or cooperative agreement, the contractor shall complete and submit Standard Form - LLL,
"Disclosure of Lobbying Activities," in accordance with its instructions; and,
3. The language of this certification will be included in the award documents for all subawards at all tiers
(including subgrants, contracts under grants and cooperative agreements, and subcontracts) and that
all sub-recipients shall certify and disclose accordingly.
C. Debarment, Suspension and Other Responsibility Matters (Direct Recipient):
Pursuant to Executive Order 12549 (Debarment and Suspension), and implemented at 2 C.F.R. Part 2867,
for prospective participants in primary covered transactions, as defined at 28 C.F.R. Part 2867, Section
2867.20(a):
1. The Contractor certifies that it and its principals:
a. Are not presently debarred, suspended, proposed for debarment, declared ineligible, sentenced
to a denial of federal benefits by a state or federal court, or voluntarily excluded from covered
transactions by any federal department or agency;
b. Have not within a three-year period preceding this application been convicted of or had a civil
judgment rendered against them for commission of fraud or a criminal offense in connection with
obtaining, attempting to obtain, or performing a public (federal, state, or local) transaction or
contract under a public transaction; violation of federal or state antitrust statutes or commission of
FY2023 Page 9 of 15
embezzlement, theft, forgery, bribery, falsification or destruction of records, making false
statements, or receiving stolen property;
c. Have not within a two-year period preceding this application been convicted of a felony criminal
violation under any Federal law, unless such felony criminal conviction has been disclosed in
writing to the Office of Justice Programs (OJP) at Ojpcompliancereporting@usdoj.gov, and, after
such disclosure, the applicant has received a specific written determination from OJP that neither
suspension nor debarment of the applicant is necessary to protect the interests of the Department
and U.S. Government in this case.
d. Are not presently indicted for or otherwise criminally or civilly charged by a governmental entity
(federal, state or local) with commission of any of the offenses enumerated in paragraph (1)(b) of
this certification; and,
e. Have not within a three-year period preceding this application had one or more public
transactions (federal, state or local) terminated for cause or default.
D. Federal Taxes:
If the applicant is a corporation, the applicant certifies that either (1) the corporation has no unpaid federal tax
liability that has been assessed, for which all judicial and administrative remedies have been exhausted or
have lapsed, that is not being paid in a timely manner pursuant to an agreement with the authority responsible
for collecting the tax liability, or (2) the corporation has provided written notice of such an unpaid tax liability
(or liabilities) to OJP at Ojpcompliancereporting@usdoj.gov, and after such disclosure, the applicant has
received a specific written determination from OJP that neither suspension nor debarment of the applicant is
necessary to protect the interests of the Department and U.S. Government in this case.
E. Drug-Free Workplace:
1. As required by the Drug-Free Workplace Act of 1988, and implemented at 28 C.F.R. Part 83, Subpart
F, as defined at 28 C.F.R. Sections 83.620 and 83.650 the Contractor certifies that it will provide a
drug-free workplace by:
a. Publishing a statement notifying employees that the unlawful manufacture, distribution,
dispensing, possession, or use of a controlled substance is prohibited in the contractor’s
workplace and specifying the actions that will be taken against employees for violation of such
prohibition;
b. Establishing an on-going drug-free awareness program to inform employees about:
i. The dangers of drug abuse in the workplace;
ii. The Contractor's policy of maintaining a drug-free workplace;
iii. Any available drug counseling, rehabilitation and employee assistance programs; and,
iv. The penalties that may be imposed upon employees for drug abuse violations occurring
in the workplace.
c. Making it a requirement that each employee who will be engaged in the performance of the grant
be given a copy of the statement required by paragraph (a) of this section.
d. Notifying the employee in the statement required by paragraph (a) of this section that, as a
condition of employment under the grant, the employee will:
i. Abide by the terms of the statement; and,
ii. Notify the employer in writing of his or her conviction for a violation of a criminal drug
statute occurring in the workplace no later than five calendar days after such conviction.
e. Notifying the agency, in writing, within 10 calendar days after receiving notice under
subparagraph (d) (ii) of this section from an employee or otherwise receiving actual notice of such
conviction. Employers of convicted employees must provide notice, including position title, to:
FY2023 Page 10 of 15
Department of Justice
Office of Justice Programs
Attn: Control Desk
810 7th Street, N.W.
Washington, D.C. 20531
Notice shall include the identification number(s) of each affected grant.
f. Taking one of the following actions, within 30 calendar days of receiving notice under
subparagraph (d)(ii) of this section, with respect to any employee who is so convicted:
i. Taking appropriate personnel action against such an employee, up to and including
termination, consistent with the requirements of the Rehabilitation Act of 1973, as
amended; or,
ii. Requiring such employee to participate satisfactorily in a drug abuse assistance or
rehabilitation program approved for such purposes by a federal, state or local health, law
enforcement or other appropriate agency.
g. Making a good faith effort to continue to maintain a drug-free workplace through implementation
of subparagraphs (a), (b), (c), (d), (e), and (f) above.
F. Standard Assurances:
The Contractor hereby assures and certifies compliance with all applicable federal statutes, regulations,
policies, guidelines, and requirements, including OMB Circulars A-21, A-87, A-102, A-110, A-122, A-133;
Executive Order 12372 (Intergovernmental Review of Federal Programs); and, 28 C.F.R. Parts 66 or 70
(administrative requirements for grants and cooperative agreements). The Contractor also specifically
assures and certifies that:
1. It has the legal authority to apply for federal assistance and the institutional, managerial, and financial
capability (including funds sufficient to pay any required non-federal share of project cost) to ensure
proper planning, management, and completion of the project described in this application.
2. It will establish safeguards to prohibit employees from using their positions for a purpose that
constitutes or presents the appearance of personal or organizational conflict of interest, or personal
gain.
3. It will give the awarding agency or the Government Accountability Office, through any authorized
representative, access to and the right to examine all paper or electronic records related to the financial
assistance. It will comply with all lawful requirements imposed by the awarding agency, specifically
including any applicable regulations, such as 28 C.F.R. Parts 18, 22, 23, 30, 35, 38, 42, 61 and 63, and
the award term in 2 C.F.R. § 175.15(b).
4. It will assist the awarding agency, if necessary, in assuring compliance with section 106 of the National
Historic Preservation Act of 1966, 16 U.S.C. § 470, Executive Order 11593 (Protection and
Enhancement of the Cultural Environment), the Archeological and Historical Preservation Act of 1974,
16 U.S.C. § 469 a-1 et seq., and the National Environmental Policy Act of 1969, 42 U.S.C. § 4321.
5. It will comply with Executive Order 13279 (Equal Protection of the Laws for Faith-Based and Community
Organizations), Executive Order 13559 (Fundamental Principles and Policymaking Criteria for
Partnerships With Faith-based and Other Neighborhood Organizations), and the DOJ regulations on
the Equal Treatment for Faith-Based Organizations, 28 C.F.R. Part 38, which prohibits recipients from
using DOJ financial assistance on inherently or explicitly religious activities and from discriminating in
the delivery of services on the basis of religion. Programs and activities must be carefully structured to
ensure DOJ financial assistance is not being used for literature, classes, meetings, counseling
sessions, or other activities that support twelve-step programs, which are considered to be religious in
nature. The twelve-step programs must take place at a separate time or location from the activities
supported with DOJ financial assistance and the participation of beneficiaries in twelve-step programs
is strictly voluntary. It must make clear to any and all vendors and program participants that twelve-step
FY2023 Page 11 of 15
programming is separate and distinct from DOJ-funded activities. It must also ensure participants are
not compelled to participate in twelve-step programs and cannot penalize a participant who chooses not
to participate in a twelve-step program. It must ensure employees fully funded by DOJ are not involved
with twelve-step programs whereby they are instructing or indoctrinating clients on the twelve steps.
Employees of the Contractor or subcontractor shall clearly document the number of hours spent on
secular activities associated with the DOJ-funded program and ensure that time spent on twelve-step
programs is completely separate from time spent on permissible secular activities. In addition, at least
one secular program must be provided as an alternative to twelve-step programming.
6. It will provide meaningful access to grant-funded programs and activities to Limited English Proficient
(LEP) persons in accordance with Title VI of the Civil Rights Act of 1964 and the Omnibus Crime Control
and Law Enforcement Act, 34 U.S.C § 1022(d). For a detailed discussion of the requirement to provide
meaningful access to LEP persons, refer to the guidance issued by the DOJ on this matter entitled,
"Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National
Origin Discrimination Affecting Limited English Proficient Persons," 67 FR 41455-01 (June 18, 2002).
7. It will comply and require any and all subcontractors to comply with any applicable statutorily-imposed
nondiscrimination requirements, including the Omnibus Crime Control and Law Enforcement Act, 34
U.S.C. § 10228; the Victims of Crime Act of 1984, 34 U.S.C. § 20110(e); the Juvenile Justice and
Delinquency Prevention Act of 2002, 38 U.S.C. § 1118(b); the Civil Rights Act of 1964 (42 U.S.C. §
2000d et seq.; the DOJ implementing regulations at 28 C.F.R. Part 42, Subpart C; the DOJ
implementing regulations at 28 C.F.R. Part 42, Subpart D; Section 504 of the Rehabilitation Act of 1973
(29 U.S.C. § 794); the DOJ implementing regulations at 28 C.F.R. Part 42, Subpart G; Title II of the
Americans with Disabilities Act of 1990 (42 U.S.C. § 12132); the DOJ implementing regulations at 28
C.F.R. Part 35; the Rehabilitation Act of 1973, 29 U.S.C. § 794; the Americans with Disabilities Act of
1990, 42 U.S.C. § 12131-34; Title IX of the Education Amendments of 1972, 20 U.S.C. §§1681, 1683,
1685-86; and, the Age Discrimination Act of 1975, 42 U.S.C. §§ 6101-07; The DOJ regulations on the
Equal Treatment for Faith-Based Organizations, 28 C.F.R. Part 38; The Michigan Elliott-Larsen Civil
Rights Act, MCL 37.2101 et seq.; and the Michigan Persons With Disabilities Civil Rights Act, MCL
37.1101 et seq,
a. Notification:
It may not discriminate in employment on the basis of race, color, national origin, religion, sex, and
disability and may not discriminate in the delivery of services or benefits on the basis of race, color,
national origin, religion, sex, disability, and age. These laws also prohibit retaliation against an
individual for taking action or participating in action to secure rights protected by these laws. It
shall notify all clients, customers, program participants, or consumers of the types of prohibited
discrimination, as well as the complaint procedures, in writing. Notification may include placing
posters in an area that may be easily viewed by all and/or providing a paper copy to each of the
listed types of individuals. It shall forward all discrimination complaints to the Department as
described in the complaint procedures in Attachment 6. Subcontractors, clients, customers,
program participants or consumers may also report complaints to the Office of Justice Programs
(OJP)/Office for Civil Rights (OCR) or the Michigan Department of Civil Rights (MDCR) directly, as
outlined in Attachment 6, but the Contractor shall notify the Department of the complaint as soon
as the complaint is known. In the event that a Federal or State court, or Federal or State
Administrative Agency, makes a finding of discrimination after a due process hearing on the
grounds of race, color, religion, national origin, sex, or disability against the Contractor or
subcontractor, the Contractor shall forward a copy of the finding to the OJP/OCR and the
Department.
b. Training:
Any and all DOJ-funded employees of the Contractor and subcontractors shall receive periodic
training at least once every contract year regarding the responsibility of the entities to comply with
applicable federal civil rights laws as a recipient of federal funds. The Department shall provide
the Contractor with access to training developed by the OJP/OCR, which may be found at
https://www.ojp.gov/about/ocr/ocr-training-videos/video-ocr-training.htm.. The DOJ-funded
employees of the Contractor shall complete the required training within 90 days of the start date of
FY2023 Page 12 of 15
this Agreement and certify that the required training has been completed by signing the OCR
Compliance Training Form, which will be provided by the Department after award acceptance.
New employees shall complete the required training and provide a signed OCR Compliance
Training Form to the Department within 90 days of the date of hire.
c. Monitoring:
The Department shall ensure that the Contractor is complying with all applicable civil rights laws
and procedures by completing the Civil Rights Compliance Questionnaire (see Attachment 7) with
the Contractor during site monitoring visits and desk audits.
8. It shall determine if an Equal Employment Opportunity Plan (EEOP) is required, pursuant to 28 C.F.R.
42.301 et seq. If the Contractor is not required to formulate an EEOP, a certification form shall be sent
to the OJP/OCR, and the Office of Personnel Management (OPM) indicating that an EEOP is not
required. If the Contractor is required to develop an EEOP, but is not required to submit the EEOP to
the OCR, a certification form shall be sent to the OCR and the Department certifying that an EEOP is
on file which meets the applicable requirements. If the Contractor is awarded a grant of $500,000 or
more, and has 50 or more employees, a copy of the EEOP shall be submitted to the OJP/OCR and
OPM. Non-profit organizations, Indian Tribes, and medical and educational institutions are exempt
from the EEOP requirement, but are required to submit a certification form to the OCR to claim the
exemption (a copy of the form shall be submitted to the OPM). Additional information about the EEOP
requirements may be found at https://www.ojp.gov/about/ocr/eeop.htm.
9. If the Contractor is a governmental entity,
a. it will comply with the requirements of the Uniform Relocation Assistance and Real Property
Acquisitions Policies Act of 1970, 42 U.S.C. § 4601 et seq., which governs the treatment of
persons displaced as a result of federal and federally-assisted programs; and,
b. it will comply with requirements of 5 U.S.C. §§ 1501-08 and §§ 7324-26, which limit certain
political activities of state or local government employees whose principal employment is in
connection with an activity financed in whole or in part by federal assistance.
G. Non-Supplanting:
It is imperative the Contractor understand that the nonsupplanting requirement mandates that grant funds
may be used only to supplement (increase) a Contractor’s budget, and may not supplant (replace) state,
local, or tribal funds that a Contractor, inclusive of any subcontractors, otherwise would have spent on
positions and/or any other items approved in the Grant Budget if it had not received a grant award.
This means that if your agency plans to:
1. Hire new positions (including filling existing vacancies that are no longer funded in your agency’s
budget), it must hire these additional positions on or after the official grant award start date, above its
current budgeted (funded) level of positions.
2. Rehire personnel who have already been laid off (at the time of application) as a result of state, local, or
tribal budget cuts, it must rehire the personnel on or after the official grant award start date, and
maintain documentation showing the date(s) that the positions were laid off and rehired.
3. Maintain personnel who are (at the time of application) currently scheduled to be laid off on a future
date as a result of state, local or tribal budget cuts, it must continue to fund the personnel with its own
funds from the grant award start date until the date of the scheduled lay-off and maintain documentation
showing the date(s) and reason(s) for the lay-off. For example, if the grant award start date is July 1
and the lay-off is scheduled for October 1, then the grant funds may not be used to fund the officers
until October 1, the date of the scheduled layoff.
Please note that as long as your agency can document the date that the lay-off(s) would occur if the
grant funds were not available, it may transfer the personnel to the grant funding on or immediately
FY2023 Page 13 of 15
after the date of the lay-off without formally completing the administrative steps associated with a lay-off
for each individual personnel.
4. Documentation that may be used to prove that scheduled lay-offs are occurring for local economic
reasons that are unrelated to the availability of grant funds may include (but are not limited to) council
or departmental meeting minutes, memoranda, notices, or orders discussing the lay-offs; notices
provided to the individual personnel regarding the date(s) of the layoffs; and/or budget documents
ordering departmental and/or jurisdiction-wide budget cuts. These records must be maintained with
your agency’s grant records.
H. Hatch Political Activity Act and Intergovernmental Personnel Act:
The Contractor will comply with the Hatch Act of 1939, 5 U.S.C. 1501-08, and the Intergovernmental
Personnel Act of 1970, as amended by Title VI of the Civil Service Reform Act of 1978, 42 U.S.C. 4728.
Federal funds cannot be used for partisan political purposes of any kind by any person or organization
involved in the administration of federally-assisted programs.
I. Health Insurance Portability and Accountability Act of 1996:
To the extent that the Health Insurance Portability and Accountability Act of 1996 is pertinent to the services
the Contractor provides to the Department under this Agreement, the Contractor assures that it is in
compliance with the HIPAA requirements including the following:
1. Contractor must not share any protected health data and information provided by the Department that
falls within the HIPAA requirements except to a subcontractor, as appropriate under this Agreement.
2. Contractor must require the subcontractor not to share any protected health data and information from
the Department that falls under the HIPAA requirements in the terms and conditions of the subcontract.
3. Contractor must only use the protected health data and information for the purposes of this Agreement.
4. Contractor must have written policies and procedures addressing the use of protected health data and
information that falls under the HIPAA requirements. The policies and procedures must meet all
applicable federal and state requirements including the HIPAA regulations. These policies and
procedures must include restricting access to the protected health data and information by the
Contractor’s employees.
5. Contractor must have a policy and procedure to report to the Department unauthorized use or
disclosure of protected health data and information that falls under the HIPAA requirements of which
the Contractor becomes aware.
6. Failure to comply with any of these contractual requirements may result in the termination of this
Agreement in accordance with Section XI, Agreement Suspension/Termination, above.
7. In accordance with the HIPAA requirements, the Contractor is liable for any claim, loss or damage
relating to unauthorized use or disclosure of protected health data and information received by the
Contractor from the Department or any other source.
XVII. Unallowable Expenses and Activities:
• Costs in applying for this grant (consultants, grant writers, etc.).
• Any expenses incurred prior to the date of this Agreement.
• Any administrative costs not directly related to the administration of this Agreement.
• Indirect costs rates or indirect administrative expenses (only direct costs permitted).
• Personnel, including law enforcement officers, not connected to the project for which you are applying.
• Lobbying or advocacy for particular legislative or administrative reform.
• Fundraising and any salaries or expenses associated with it.
• Legal fees.
• All travel, unless prior approval by the Department is received.
FY2023 Page 14 of 15
• Promotional items, unless prior approval by the Department is received.
• One-time events, prizes, entertainment (e.g., tours, excursions, amusement parks, sporting events), unless
prior approval by the Department is received.
• Honorariums.
• Contributions and donations.
• Management or administrative training, conferences, unless prior approval by the Department is received.
• Management studies or research and development (costs related to evaluation are permitted).
• Fines and penalties.
• Losses from uncollectible bad debts.
• Purchases of land.
• Memberships and agency dues, unless a specific requirement of the project, unless prior approval by the
Department is received.
• Compensation to federal employees.
• Military type equipment such as armored vehicles, explosive devices, and other items typically associated
with the military arsenal.
• Purchasing of vehicles, vessels or aircraft.
• Construction costs and/or renovation, including remodeling.
• Service contracts and training beyond the expiration of this Agreement.
• Informant fees, rewards or buy money.
• Expert witness fees.
• K9 dogs and horses, including any food and/or supplies relating to the upkeep of law enforcement animals.
• Livescan devices for applicant prints including any related supplies.
• Weapons, including tasers.
• Food, refreshments, snacks
Note: No funding can be used to purchase food and/or beverages for any meeting, conference, training, or other
event. Exceptions to this restriction may be made only in cases where such sustenance is not otherwise available
(e.g., extremely remote areas), or where a special presentation at a conference requires a plenary address where
there is no other time for sustenance to be attained. Such an exception would require prior approval from the
Department and the DOJ. This restriction does not apply to water provided at no cost, but does apply to any and
all other refreshments, regardless of the size or nature of the meeting. Additionally, this restriction does not impact
direct payment of per diem amounts to individuals in a travel status under your organization’s travel policy.
XVIII. Conditions on Expenses:
Costs must be reasonable and necessary. If required by the local jurisdiction, costs must be sustained by
competitive bids. All contracts and subcontracts require prior approval by the Department. If detailed information
is not included as part of the application process, the Contractor must submit a request seeking approval once the
subcontractors are identified.
Individual consultant fees are limited to $650 (excluding travel, lodging, and meal costs) per day, which includes
legal, medical, psychological, and accountant consultants. If the rate will exceed $650 for an eight-hour day, prior
written approval is required from the Department. Compensation for individual consultant services is to be
responsible and consistent with that paid for similar services in the marketplace.
XIX. Conflict of Interest:
The Contractor and Department are subject to the provisions of 1968 PA 317, as amended, MCL 15.321 et seq.,
and 1973 PA 196, as amended, MCL 15.341 et seq.
XX. State of Michigan Agreement:
This is a state of Michigan agreement and is governed by the laws of Michigan. Any dispute arising as a result of
this Agreement shall be resolved in the state of Michigan.
XXI. Compliance with Applicable Laws:
The Contractor will comply with applicable federal and state laws, guidelines, rules and regulations in carrying out
the terms of this Agreement. The Contractor will also comply with all applicable general administrative
FY2023 Page 15 of 15
requirements such as OMB Circulars covering cost principles, grant/agreement principles, and audits in carrying
out the terms of this Agreement.
XXII. Special Certification:
The individual electronically accepting this Agreement certifies by his/her acceptance that he/she is authorized to
sign this Agreement on behalf of the Contractor.
XXIII. Contractor Signature:
The Authorized Official’s signature represents the Contractor’s legal acceptance of the terms of this Agreement,
including Certifications and Assurances agreed to prior to application submission.
Authorized Official Signature:
Title of Authorized Official:
Date:
Project Director Signature:
Title of Project Director:
Date:
Financial Official Signature: Title of Financial Official: Date:
Attachment 1
GRANT SUMMARY
Page 1 of 1
OCSO’s primary goal for the use of Coverdell funding aligns with the laboratory’s strategic plan to
provide its customers, the criminal justice system, and the individuals of the communities that it serves
with the highest quality of forensic services through timely collection and examination of evidence. With
the support of prior-year Coverdell funding, the Firearms Unit is now optimally staffed, throughput has
increased, and the Unit’s turnaround time has significantly improved. In addition, prior-year Coverdell
funding enabled the Toxicology Unit to expand its service delivery model to better meet the needs of its
customers. OCSO is requesting federal FY 2022 Coverdell funding to continue supporting both of these
efforts.
Attachment 2
STATEMENT OF WORK
Page 2 of 2
Project Design and Implementation
Coverdell funding will be used to maintain the laboratory’s grant-funded Firearms Unit position for
an additional twelve-month period, with OCSO continuing to share in the cost of this position. The opioid-
specific allocation will be used to purchase methadone, buprenorphine, oxycodone, 6-AM, and fentanyl
kits to continue testing for the presence of these drugs once the inventory of kits purchased with prior-
year funding has been exhausted.
With continued Coverdell support for the Firearms Unit, OCSO will remain sufficiently staffed to
perform independent comparison verifications and to examine more cases than would otherwise be
possible. Although backlog counts and processing times can be impacted by factors beyond the
laboratory’s control (test request fluctuations, case complexity, etc.), OCSO’s Coverdell-funded examiner
will continue to have a positive impact on both metrics. It is expected that this position will complete an
average of 20 cases per month - for a total contribution of 240 cases during the award period - and assist
the Firearms Unit in maintaining a turnaround time of 30 days or less. In addition, it is anticipated that
OCSO’s opioid allocation will fund up to 19,677 methadone, 16,900 buprenorphine, 16,772 oxycodone,
10,134 6-AM, and 21,000 fentanyl tests which will be used by the Toxicology Unit for calibration and
quality control, initial screening of donor samples, and verification of samples that test positive during
initial screening. Actual test counts will be reported at the end of the award period.
Capabilities and Competencies
The OCSO provides forensic laboratory services to Oakland County and its neighboring
communities, a population of approximately 1.2 million residents. In addition to its contracted customer
base, OCSO provides forensic services to regional police departments, sheriff’s offices, and federal
agencies including the FBI, ATF, DEA, ICE, and Department of Homeland Security – supporting more
than 50 law enforcement agencies in total. The OCSO Forensic Science Laboratory is accredited under
ISO/IEC 17025:2017 to provide the following forensic services:
• Drug Chemistry Analysis (NFLIS Participant)
• Latent Print Examination
• Firearms and Toolmarks Examination
Attachment 2
STATEMENT OF WORK
Page 2 of 2
• Toxicology Analysis (Presumptive Testing and Blood Alcohol)
• Biology/DNA Analysis
Oakland County borders the city of Detroit and is located just south of Flint, two cities that
continue to lead the nation in violent crime. Pontiac, the county seat, remains one of the most violent
cities within the state of Michigan. In a recent annual analysis of U.S. Census Bureau and FBI Uniform
Crime Report data, Pontiac received a crime index rating of 13, out of a possible 100, indicating that the
Pontiac community is safer than only 13% of other cities in the United States. In addition, Oakland
County continues to feel the effects of the opioid abuse crisis, which has taken a substantial toll on
community health, emergency response, medical, and criminal justice resources nationwide. From 2008
to 2010, OCSO reported an average of 231 heroin, opium/opium derivative, and synthetic narcotic
incidents per year. After peaking at 463 incidents in 2016, OCSO has reported an average of 318
incidents per year from 2017 to 2021 (reported incidents include possession, use, manufacture, sale,
etc.). As a result, Coverdell funding remains a critical resource in helping the OCSO Forensic Science
Laboratory to meet the needs of its law enforcement customers.
Plan for Collecting Performance Measurement Data
The OCSO laboratory’s grant awards are jointly administered by OCSO’s lab director and a
contracted consultant with 17 years of forensic grant management experience. The OCSO’s lab director
and grant management consultant will have primary responsibility for administering the federal FY 2022
Coverdell subaward and will be supported in this effort by Firearms and Toxicology Unit personnel.
OCSO will use a combination of laboratory information management system (JusticeTrax) reports,
spreadsheets, and instrument data to track and support grant-related performance metrics. In accordance
with program requirements, data collected for reporting purposes will be maintained and made available
for review for three years post-award.
OCSO will provide quarterly progress reports, monthly financial reports, and BJA performance
measures to the Grants and Community Services Division, the State Administering Agency, throughout
the grant period.
Attachment 2-A
PROJECT TIMELINE
Page 1 of 1
The Oakland County Sheriff’s Office (OCSO) will implement the proposed Coverdell project within
60 days of receiving a subaward/contract from the Michigan State Police (MSP). It’s expected that both
objectives will be carried out during an April 2023 – March 2024 project period. The Toxicology Unit will
begin ordering test kits as soon as any remaining inventory purchased with prior-year Coverdell funding
has been exhausted and OCSO’s grant-funded firearms examiner will transition to the MSP FY 2023
(BJA FY 2022) Coverdell subaward once the contract agreement has been reviewed and approved by the
Oakland County Board of Commissioners.
Attachment 3
PROGRAM BUDGET
Page 1 of 2
Non-Federal Federal
Name Position Salary Rate Time Worked % of Time Total Cost Contribution Request
Firearms Examiner (Non-Opioid)95,301$ Yearly 1 100%95,301$ 76,010$ 19,291$
TOTAL:95,301$ 76,010$ 19,291$
Non-Federal Federal
Name Position Base Rate Total Cost Contribution Request
Firearms Examiner (Non-Opioid)95,301$ 58.66%55,905$ 44,588$ 11,317$
TOTAL:55,905$ 44,588$ 11,317$
N/A
TOTAL:-$ -$ -$
N/A
TOTAL:-$ -$ -$
Non-Federal Federal
Supply Items # of Items Unit Cost Total Cost Contribution Request
Methadone 1L (Opioid)3 $1,443 4,329$ -$ 4,329$
Buprenophine 1L (Opioid)2 $3,549 7,098$ -$ 7,098$
Oxycodone 1L (Opioid)2 $3,522 7,044$ -$ 7,044$
6-AM 115 mLs (Opioid)18 $381 6,857$ -$ 6,857$
Fentanyl 500 mL (Opioid)3 $5,740 17,220$ 279$ 16,941$
TOTAL:42,548$ 279$ 42,269$
The Oakland County Sheriff’s Office (OCSO) requests MSP FY 2023 (BJA FY 2022) Coverdell funding to continue supporting he Firearms position identified in this proposal. Annual
salary for Stephanie Alston is projected to be $95,301 during the April 2023 - March 2024 contract/subaward period and is budgeted at this rate accordingly. While this position will be
fully dedicated to the proposed project, total Personnel costs exceed the amount of Coverdell funding available for this purpose. As a result, OCSO is requesting a federal Personnel
contribution of $19,291, equal to 20% of the projected salary for the contract/subaward period. OCSO will fund the remaining 80%.
B. Fringe Benefits
Fringe benefits are calculated at a percentage of salary as follows: FICA (7.65%), Unemployment (0.10%), Workers Compensation (0.47%), Retirement (29.54%), Group Life
(0.22%), Disability (1 58%), Medical (17.33%), Dental (1.61%), and Vision (0.16%). While this position will be fully dedicated to the proposed project, total Fringe Benefit costs exceed
he amount of Coverdell funding available for this purpose. As a result, OCSO is requesting a federal Fringe Benefit contribution of $11,317, equal to 20% of the total benefits for the
contract/subaward period. OCSO will fund the remaining 80%.
C. Travel
D. Equipment
E. Supplies
OCSO will purchase methadone, buprenophine, oxycodone, 6-AM, and fentanyl kits to continue offering expanded opioid testing, which was added to the laboratory's
scope of service with prior-year Coverdell funds. These kits will be used by the Toxicology unit for calibration, quality control, initial screening of donor samples, and
verification of samples that test positive during the initial screening process. OPIOID IMPACT STATEMENT: This objective is dedicated to opioid testing in accordance
with BJA's preference that at least 58% of a grantee's Coverdell allocation be used for opioid-related activities. The federal request for opioid-specific test kits is $42,269
which is equal to 58% of OCSO's Coverdell subaward.
MSP FY 2023 Paul Coverdell Forensic Science Impovement Program:
BJA FY 2022 Funding Cycle
Revised: March 2023
A. Personnel
Attachment 3
PROGRAM BUDGET
Page 2 of 2
N/A
TOTAL:-$ -$ -$
N/A
TOTAL:-$ -$ -$
N/A
TOTAL:-$ -$ -$
N/A
TOTAL:-$ -$ -$
N/A
TOTAL:-$ -$ -$
Non-Federal Federal Total
Budget Category Contribution Request Budget
A. Personnel 76,010$ 19,291$ 95,301$
B. Fringe Benefits 44,588$ 11,317$ 55,905$
C. Travel -$ -$ -$
D. Equipment -$ -$ -$
E. Supplies 279$ 42,269$ 42,548$
F. Construction -$ -$ -$
G. Subawards (Subgrants)-$ -$ -$
H. Procurement Contracts -$ -$ -$
I. Other -$ -$ -$
Total Direct Costs 120,877$ 72,877$ 193,754$
J. Indirect Costs -$ -$ -$
Total Project Costs:120,877$ 72,877$ 193,754$
FY 2023 Award Total 72,877$
F. Construction
G. Subawards (Subgrants)
H. Procurement Contracts
Budget Summary:
J. Indirect Costs
I. Other Costs
Attachment 4
PERFORMANCE/PROGRESS REPORT REQUIREMENTS
Page 1 of 1
The Contractor shall submit the following reports on the following dates:
A) Quarterly progress reports are required by all grantees. Grantees must complete the individualized
quarterly progress report to the MSP Grants and Community Services Division. This report will include a
summary of your quarterly progress, accomplishments, and any barriers you encountered. Any additional
requirements to be included in this report will be provided by your grant advisor.
(1) Include a summary and assessment of the program carried out with grant funds;
(2) Identify the number and type of cases accepted during the award period by the forensic laboratory or
laboratories that received grant funds; and
(3) Cite the specific improvements in the quality and/or timeliness of forensic science and medical
examiner services (including any reduction in forensic analysis backlog) that occurred as a direct result
of the grant award.
(4) The number and nature of any allegations of serious negligence or misconduct substantially
affecting the integrity of forensic results;
(a) Information on the referrals of such allegations (e.g., the government entity or entities to
which referred, the date of referral);
(b) The outcome of such referrals (if known as of the date of the report); and
(c) If any such allegations were not referred, the reason(s) for the non-referral.
Special Reporting requirements may be required by OJP depending on the statutory, legislative or
administrative requirements of the recipient or the program.
This report is due by the 20th of the month following each quarter.
Quarterly due dates are outlined below:
1st Quarter: April 1 through June 30 Due Date: July 20
2nd Quarter: July 1 through September 30 Due Date: October 20
3rd Quarter: October 1 through December 31 Due Date: January 20
4th Quarter: January 1 through March 31 Due Date: April 20
B)Financial Status Reports
Financial Status Reports (FSR) must be submitted on a monthly basis, no later than 30 days after the close of
each calendar month. Requests for reimbursement must be submitted for the month in which payment by your
agency was made.
Financial Status Report due dates are outlined below:
3/1 - 3/31 Due 4/30 9/1 - 9/30 Due 10/30
4/1 - 4/30 Due 5/30 10/1 - 10/31 Due 11/30
5/1 - 5/31 Due 6/30 11/1 - 11/30 Due 12/30
6/1 - 6/30 Due 7/30 12/1 - 12/31 Due 1/30
7/1 - 7/31 Due 8/30 1/1 - 1/31 Due 2/28
8/1 - 8/31 Due 9/30 2/1 - 2/28 Due 3/30
Recipients must also submit, if applicable, an annual audit report in accordance with 2 CFR Part 200.
Future awards and fund drawdowns may be withheld if reports are delinquent.
Attachment 6
UD-040 (10/02)
MEMORANDUM
Page 1 of 4
STATE OF MICHIGAN
DEPARTMENT OF STATE POLICE
DATE: August 13, 2013
TO: Department Members
FROM: Nancy Becker Bennett, Director, Grants and Community Services Division (GCSD)
SUBJECT: Discrimination Complaint Procedures for Federal Grant-Funded Projects
I. Purpose
As a condition for receiving funding from the U.S. Department of Justice (DOJ), all recipients and
subrecipients of such funding must comply with applicable federal civil rights laws. This document will
establish written procedures for MSP employees and DOJ-funded grant subrecipients to follow if a
complaint alleging discrimination is received from clients, customers, program participants, or consumers
of a MSP subrecipient implementing funding from the DOJ.
II. Policy
Recipients and subrecipients of DOJ funding may not discriminate in employment on the basis of race,
color, national origin, religion, sex, and disability. They also may not discriminate in the delivery of
services or benefits on the basis of race, color, national origin, religion, sex, disability, and age. The MSP
will notify subrecipients of their required compliance with the following statues and regulations through the
interagency agreement:
■ The Omnibus Crime Control and Safe Streets Act of 1968 (42 U.S.C. § 3789d); the Victims of Crime Act
(42 U.S.C. § 10604(e)); the Juvenile Justice and Delinquency Prevention Act of 2002 (42 U.S.C. §
5672(b)); the Civil Rights Act of 1964 (42 U.S.C. § 2000d); the Rehabilitation Act of 1973 (29 U.S.C. §
794); the Americans with Disabilities Act of 1990 (42 U.S.C. §§ 12131-34); the Education Amendments of
1972 (20 U.S.C. §§1681, 1683, 1685-86); the Age Discrimination Act of 1975, (42 U.S.C. §§ 6101-07),
Ex. Order 13279 (equal organizations); and 28 C.F.R. Part 38 (U.S. Department of Justice Equal
Treatment for Faith-Based Organizations).
■ 28 CFR 42.301 et seq, which requires recipients determine if it is required to formulate an Equal
Employment Opportunity Plan (EEOP). If the recipient is not required to formulate an EEOP, it will submit
a certification form to the U.S. Department of Justice, Office of Justice Programs, Office for Civil Rights
(OCR), and the Office of Personnel Management (OPM) indicating that it is not required to develop an
EEOP. If the recipient is required to develop an EEOP, but is not required to submit the EEOP to the
OCR, it will submit a certification form to the OCR and the MSP certifying that it has an EEOP on file
which meets the applicable requirements. If the recipient is awarded a grant of $500,000 or more and
has fifty or more employees, it will submit a copy of its EEOP to the OCR and OPM. Non-profit
organizations, Indian Tribes, and medical and educational institutions are exempt from the EEOP
requirement, but are required to submit a certification form to the OCR to claim the exemption (a copy of
the form should also be submitted to the OPM).
Attachment 6
Page 2 of 4
■ Title VI of the the Civil Rights Act of 1964 and the Omnibus Crime Control and Safe Streets Act of
1968m, which require subrecipients to provide meaningful access to programs and activities to Limited
English Proficient (LEP) persons.
■ The Michigan Elliott-Larsen Civil Rights Act, MCL 37.2101 et. Seq, which prohibits discriminatory
practices, policies, and customs in the exercise of those rights based upon religion, race, color, national
origin, age, sex, height, weight, familial status, or marital status in Michigan.
■ The Michigan Persons With Disabilities Civil Rights Act, Act 220 of 1976, which defines the civil rights of
persons with disabilities; to prohibit discriminatory practices, policies, and customs in the exercise of
those rights; to prescribe penalties and to provide remedies; and to provide for the promulgation of rules.
These laws also prohibit agencies from retaliating against an individual for taking action or participating in
action to secure rights protected by these laws.
In the event that a Federal orf State court, orf Federal or State Aadministrative Aagency, makes a finding
of discrimination after a due process hearing on the grounds of race, color, religion, national origin, sex,
or disability against a Contractorthe Contractor, subcontractor or vendor, they will forward a copy of the
finding will be forwarded to the Office for Civil Rights, Office of Justice Programs and the Department.
The MSP will notify its own employees of their required compliance with the preceding civil rights statutes
and regulations through an Official Order.
III. Definitions
Contract means any Government contract or subcontract or any federally assisted construction contract
or subcontract.
Complainant is a party that makes a complaint or files a formal charge.
Discrimination means treating an individual or a group of individuals adversely because of protected
class status; or using a test, standard, or employment practice that has the effect if illegally excluding or
screening in or out of a protected class.
MSP Employee is an individual providing services for and paid by the State of Michigan/Michigan State
Police, including independent contractors, union and non-union employees, managers and supervisors,
enlisted members and civilians.
Recipient is the entity which receives a monetary award from the DOJ.
Subcontract means any agreement or arrangement between a contractor and any person (in which the
parties do not stand in the relationship of an employer and an employee):
1. For the purchase, sale or use of personal property or nonpersonal services which in whole or in part, is
necessary to the performance of any one or more contracts; or
2. Under which any portion of the contractor's obligation under any one or more contracts is performed,
undertaken or assumed.
Subcontractor is any person holding a subcontract, and, for the purposes of this definition, any person
who has held a subcontract subject to the order. The term "first-tier subcontractor" refers to a
subcontractor holding a subcontract with a prime contractor.
Subrecipient is the entity that receives a monetary award from the DOJ recipient.
Attachment 6
Page 3 of 4
Subrecipient Employee is an individual or subcontractor being paid using DOJ grant funds.
IV. Complaint Procedures
The following are MSP’s procedures for accepting and responding to discrimination complaints from
subrecipient employees, clients, customers, program participants, or consumers of a
MSP subrecipient implementing funding from the DOJ:
1. All discrimination complaints associated with DOJ grants shall be submitted to the Grants and
Community Services Division (GCSD) by mail, telephone or e-mail to:
Michigan State Police
Grants and Community Services Division
333 S. Grand Ave.
Lansing, MI 48909
(517) 373-2960
MSP-CJGrants@michigan.gov
2. The GCSD Director will send the complainant a letter within 10 days from the date it was received to
acknowledge receipt of the complaint, notify the complainant that it has been submitted to the Michigan
Department of Civil Rights, and inform the complainant that he or she may also file a complaint directly
with the federal Office for Civil Rights (OCR) at:
Office of Justice Programs
Office for Civil Rights
810 7th Street NW
Washington, DC 20531
(202) 307-0690
Fax: (202) 616-9865
TTY: (202) 307-2027
3. Within 10 days of the receipt of the complaint, the GCSD Director will send an email to the DOJ
subrecipient to notify the agency that a complaint against has been filed against it.
4. The GCSD Director will forward the complaint to the Inspector of the MSP Office of Human Resources
(OHR) immediately upon receipt of the complaint. The OHR Inspector or his or her designee will serve as
the coordinator for all complaints regarding civil rights violations and will immediately forward the
complaint to the Michigan Department of Civil Rights by emailing MDCRServiceCenter@michigan.gov. If
MDCR informs the MSP that it does not have jurisdiction to investigate the complaint, the OHR Inspector
will forward the complaint to the OCR for investigation.
The preceding complaint procedures are an attachment to the subrecipient contracts for all DOJ grants
awarded by the MSP. Subrecipients must notify all clients, customers, program participants, or
consumers of the types of prohibited discrimination, as well as the complaint procedures, in writing.
Notification may include placing posters in an area that may be easily viewed by all and/or providing a
paper copy to each of the listed types of individuals. Subrecipients must forward all discrimination
complaints to the MSP as described in the complaint procedures. Subcontractors, clients, customers,
program participants or consumers may also report complaints to the Office of Justice Programs/Office for
Civil Rights or the Michigan Department of Civil Rights directly, but the MSP must be notified of the
complaint by the subrecipient as soon as the complaint is known.
The MSP will ensure that all subrecipients are in compliance with the identified statutes and regulations
by reviewing subrecipient procedures during site visits and other subrecipient monitoring activities.
Attachment 6
Page 4 of 4
5. The MSP, in cooperation with MDCR and OCR, will review and complete complaint investigations
within 120-days. Complainants will receive written notification of the completion of the investigation and
any associated findings within 10-days of the completion of the investigation. If the complexity of the
investigation precludes this 120 day timeline from being met, the MSP shall notify the complainant in
writing when it becomes aware that the investigation will not meet the 120 day timeline. This
correspondence shall include a new timeline with an estimated completion date.
V. Training
All DOJ-funded MSP employees and subrecipients will receive periodic training at least once every
contract year regarding their responsibility to comply with applicable federal civil rights in their capacity as
a recipient of federal funds. Additionally, training will include review of these complaint procedures,
including the employee’s responsibility to refer discrimination complaints from clients, customers, program
participants, or consumers to the appropriate MSP contact. The GCSD will provide DOJ-grant
subrecipients and DOJ-funded MSP employees with access to OCR training modules, found on OCR’s
website, http://www.ojp.usdoj.gov/about/ocr/assistance.htm. Subrecipients will be required to certify
they have completed this training during the first quarter of each grant cycle as part of their grant award
agreement with the MSP.
These procedures and training requirements will also be disseminated to MSP employees via
departmental memoorandum and posted on the MSP intranet website. New employees will receive a
copy of the procedures and access to the DHS training program during initial job training from any
supervisor managing DOJ-funded employees.
VI. Monitoring
The GCSD has implemented a two-part process to ensure and monitor sub-recipients compliance with
civil rights laws. Applicants must annually complete and submit to the GCSD the Civil Rights Compliance
Questionnaire. Additionally, MSP grant advisors will complete the Civil Rights Compliance Questionnaire
with applicants during on-site monitoring visits.
VII. Policy Dissemination
This policy shall be distributed to all MSP employees via a department-wide memorandum contingent
upon final OCR approval. Additionally, the policy will be distributed via MSP’s grant award agreement
with DOJ-funded subrecipents as part of the standard grant award package.
Attachment 7
Page 1 of 4
Federal Civil Rights Compliance Checklist
1. If the sub recipient is required to prepare an Equal Employment Opportunity Plan (EEOP)
in accordance with 28 C.F.R. §§ 42.301-.308, does the sub recipient have an EEOP on
file for review?
Yes No
If yes, on what date did the sub recipient prepare the EEOP?
2. Has the sub recipient submitted an EEOP Short Form to the Office for Civil Rights
(OCR), Office of Justice Programs (OJP), U.S. Department of Justice (DOJ), if required
by 28 C.F.R. §§ 42.301-.308? If the sub recipient is not required to submit an EEOP
Short Form to the OCR, has it submitted a certification form to the OCR claiming a
partial or complete exemption from the EEOP requirements?
Yes- submitted an EEOP Short Form
Yes- submitted a certification
No
If the sub recipient prepared an EEOP Short Form, on what date did the sub recipient
prepare it?
3. How does the sub recipient notify program participants and beneficiaries that it does not
discriminate on the basis of race, color, national origin, religion, sex, disability, and age in
the delivery of services (e.g. posters, inclusion in brochures or other program materials,
etc.)?
Comments:
Attachment 7
Page 2 of 4
4. How does the sub recipient notify employees that it does not discriminate on the basis of
race, color, national origin, religion, sex, and disability in employment practices (e.g.
posters, dissemination of relevant orders or policies, inclusion in recruitment materials,
etc.)?
Comments:
5. Does the sub recipient have written policies or procedures in place for notifying program
beneficiaries how to file complaints alleging discrimination by the sub recipient with the
[State Administering Agency] or the OCR?
Yes No
If yes, an explanation of these policies and procedures:
6. If the sub recipient has 50 or more employees and receives DOJ funding of $25,000 or
more: has the sub recipient taken the following actions:
a. Adopted grievance procedures that incorporate due process standards and
provide for the prompt and equitable resolution of complaints alleging a
violation of the DOJ regulations implementing Section 504 of the
Rehabilitation Act of 1973, found at 28 C.F.R. Part 42, Subpart G, which
prohibit discrimination on the basis of a disability in employment practices and
the delivery of services.
Yes No
b. Designated a person to coordinate compliance with the prohibitions against
disability discrimination contained in 28 C.F.R. Part 42, Subpart1 G.
Yes No
c. Notified participants, beneficiaries, employees, applicants, and others that the
sub recipient does not discriminate on the basis of disability.
Yes No
Attachment 7
Page 3 of 4
Comments:
7. If the sub recipient operates an education program or activity, has the sub recipient taken
the following actions:
a. Adopted grievance procedures that provide for the prompt and equitable resolution of complaints alleging a violation of the DOJ regulations implementing Title IX of the Education Amendments of 1972, found at 28 C.F.R. Part 54, which prohibit discrimination on the basis of sex.
Yes No
b. Designated a person to coordinate compliance with the prohibitions
against sex discrimination contained in 28 C.F.R. Part 54.
Yes No
c. Notified applicants for admission and employment, employees, students,
parents, and others that the sub recipient does not discriminate on the basis of
sex in its educational programs or activities.
Yes No
Comments:
8. Has the sub recipient complied with the requirement to submit to the OCR any findings of
discrimination against the sub recipient issued by a federal or state agency or federal or
state administrative agency on the grounds of race, color, religion, national origin, or sex?
Yes No
Comments:
Attachment 7
Page 4 of 4
9. What steps has the sub recipient taken to provide meaningful access to its programs and
activities to persons who have limited English proficiency (LEP)?
Comments, including an indication of whether the sub recipient has developed a
written policy on providing language access services to LEP persons:
10. Does the sub recipient conduct any training for its employees on the requirements under
federal civil rights laws?
Yes No
Comments:
11. If the sub recipient conducts religious activities as part of its programs or services, does
the sub recipient do the following?
a. Provide services to everyone regardless of religion or religious belief.
Yes No
b. Ensure that it does not use federal funds to conduct inherently religious activities,
such as prayer, religious instruction, or proselytization, and that such activities
are kept separate in time or place from federally-funded activities.
Yes No
c. Ensure that participation in religious activities is voluntary for
beneficiaries of federally-funded programs.
Yes No
Comments: