Editor’s note: In this new recurring column, a COPS Office grant program specialist will take on commonly asked questions about managing your COPS grant. If you have a question about one of your COPS grants, instructions for contacting your grant program specialist are at the end of this article, but if you have suggestion for a topic in a future column of “Ask a GPS,” please let us know at CPDispatch@usdoj.gov.
After a Community Oriented Policing Services or “COPS” grant has been awarded, one of the most frequently asked questions of the grant program specialist (GPS) is “Must I Submit a Modification Request if…?” Keep in mind that for targeted or “sponsored” grants, generally speaking, months or even a year might have passed from the time the agency notified the sponsor of a funding need until a targeted grant is awarded. By that time, the needs of the proposed project may have changed or projected costs may have fluctuated. The same applies to competitive or “discretionary” grants. Similarly, with hiring grants, a grantee may find that it is unable to retain the officers for the duration of the grant period or throughout the required retention period. Whatever the case, whenever a grantee deviates from the approved project scope or budget, it is, in fact, a “budget modification.”
A grantee seeking to deviate from the originally approved project budget must submit a modification request in writing to the COPS Office for review and approval. The modification process ensures the scope of the project remains in line with the Program intent and the purpose or “appropriation language” for which targeted Technology and Methamphetamine Program grants have been awarded. It also ensures that any new line items are “allowable” under the respective Program. Without such a review, grantees who knowingly or unknowingly make improper or unallowable purchases can be held liable for repaying misappropriated funds.
The following are sample scenarios that warrant a budget modification approval from the COPS Office:
Example 1: The grantee had initially budgeted to implement a video surveillance system, but instead decided to purchase new radios and mobile data terminals for police vehicles. Although funds are not being moved across budget categories (e.g., the funds remain in the Equipment category), a modification request is required to ensure the new items comply with the Program intent or appropriation language, to ensure that they are allowable, and to ensure they meet prescribed standards (i.e., P25 compliance). However, if the appropriation language had stated “video-surveillance equipment,” the grantee would generally not be approved to purchase radios and mobile data terminals because those items are not in compliance with the stated purpose or “appropriation language” for which the funds have been awarded.
Example 2: The grantee budgeted to buy only the software and hardware to link up to a statewide system but the state picked up those costs. The grantee now wants to spend those funds on installation, maintenance, a warranty, and project management costs. A modification request is required because funds are being moved across budget categories, from the Equipment category to the Other Costs and Contracts/Consultants categories. The new line items also must be approved.
Example 3: The grantee incurred a significant equipment cost savings because the costs had gone down, and they also received a rebate on some of the items purchased. They now want to use the savings to pay for training and travel costs. A modification request is required because funds are being moved from the Equipment category to the Travel/Training category, but also to validate the course content and location, and associated costs as appropriate.
Example 4: The law enforcement agency was awarded funds to hire six new sworn officers and to rehire three sworn officers who had already been laid off. The agency found that one of the laid off officers had found a job elsewhere and two had relocated. The agency wants to hire three additional new sworn officers instead. A modification request is required because the agency wants to deviate from the approved number of new sworn officers and rehires. If the switch is from a layoff to a new hire scenario, those modification requests are reviewed and approved by Branch staff. However, if a grantee wants to switch from a new hire to a rehire or to a future layoff scenario, those modification requests must receive written approval from the COPS Legal Office.
Modification information pertaining to a specific COPS grant Program can be found in the Application Guide or in the Grant Owner’s Manual for the respective Program (e.g., 2010 COPS Technology Program Grant Owner’s Manual). Generally speaking, grantees must request a budget modification when the scope of the project is being changed, when funds are being moved across categories, and when the aggregate of changes exceeds the allowed percent of the grant amount.
A properly executed budget modification request will consist of the following documentation:
1. A detailed request letter (on agency letterhead and signed by the law enforcement or government executive) explaining the proposed project and budget change(s), the impact to the project, and how this change will further their community policing project goals or outcomes.
2. A budget narrative (e.g., a description of each proposed new line item, including the quantity and unit cost, in nontechnical, non-law enforcement, layman’s terms).
3. The budget modification detail worksheets. These forms can be obtained by contacting the GPS.
Specific questions regarding a potential modification request should be directed to the state grant program specialist for the respective Program (Technology, Methamphetamine, Secure Our Schools, COPS Hiring Program, etc.). To determine your specific grant program specialist, go to the State Contacts List and click on your state. You can also e-mail questions to AskCopsRC@usdoj.gov or call the COPS Response Center at 800.421.6770.
Grant Program Specialist
The COPS Office
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