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JJCPA - FAQ 4
Schiff-Cardenas Crime Prevention Act of 2000 (CPA 2000)
Frequently Asked Questions #4
7/1/2001
- What information is required to be reported for the October 15 deadline?
- Will there be a hard copy of the on-line reporting format provided by the BOC?
- Can a program be modified or replaced after the BOC and the Board of Supervisors have approved it?
- How much flexibility is there in modifying our budget and Program?
- How does the BOC define the specific line item expenditures required to be reported for the CPA Funds and CPA Interest funding categories?
- How does the BOC define the "Non-CPA Funds" category in the Program Expenditures section of the on-line reporting website?
- What level of accounting, and how much detail, is necessary for CPA funds?
- Must we account for funds that are not CPA or interest?
- Does interest that is not expended or encumbered return to the state?
- Can interest earned on CPA 2000 funds be used to exceed the .5% administrative cost limit?
- Can other county funds be used to exceed the .5% administrative cost limitation?
- Are community-based organizations (CBO) and professional service contracts also included in the .5% administrative cost limitation?
- Can audit expenses be claimed?
- Can CPA funds deposited in the county trust account be directly moved to the county operating budget?
- How do we break out CBO programs that serve more than CPA 2000 kids?
- If we are already contracting with a CBO, should we keep CPA 2000 programs and funding separate and distinct from other programs and funding?
- What type of documentation is required to corroborate that client services were rendered?
- Can CPA funds be used for tenant improvements?
- Is there a limit to how much we can spend on fixed assets before getting BOC approval?
- Will there be a policy manual and/or audit guide developed for CPA 2000 funds?
ANSWERS
1.What information is required to be reported for the October 15 deadline?
Counties are required to provide the BOC basic county program information related to each specific program in their Comprehensive Multiagency Juvenile Justice Plan (CMJJP) and to report on actual expenditures through June 30. Also, evaluation information relating to specific outcome data identified in the CMJJP which has been collected through June 30 must be reported. (revised 5/23/02)
2.Will there be a hard copy of the on-line reporting format provided by the BOC?
The BOC is currently working to finalize the on-line reporting system. The expected completion date is July 16, 2001. When completed, county personnel will be able to report online, print of the required input screens and associated instructions. All reports must be submitted online.
3.Can a program be modified or replaced after the BOC and the Board of Supervisors have approved it?
The BOC understands that modifications may be required for some approved programs as implementation occurs. Under unique circumstances a county may need to change programs after implementation. When this occurs the county should contact their BOC field representative to address the issues on a case-by-case basis. Please refer to the letter from Executive Director, Thom McConnell, dated June 7, 2001 that addresses the procedure for modifying the plan.
4.How much flexibility is there in modifying our budget and Program?
The Application for Modification Instructions defines modifications as either substantive or non-substantive.
The BOC considers substantive changes to be "Those changes that have a significant impact on any program(s) contained in the county’s BOC approved CPA 2000 plan." A substantive change could include any of the following:
- Deleting or adding new programs
- A major change in the target population of the project service by a program
- Program changes that are not supported by the existing demonstrated effectiveness evidence provided in the existing CMJJP
- Changes in program outcome measures that impact reporting requirements.
A non-substantive change would be defined as "Those changes that do not have a significant impact on any program(s) contained in the county’ BOC approved CPA 2000 plan. Non-substantive changes do not involve or impact project performance or reporting requirements and are not directly related to the success or failure of the project, program, or evaluation." Counties making non-substantive changes are not required to obtain BOC approval. Examples of non-substantive changes include:
- Moving funds between budget line items or programs
- Adding, deleting, or modifying personnel assigned to the program
- Changing community-Based Organizations or evaluation staff
Changes to the original plan should always be discussed with the county’s BOC field representative when possible.
CPA 2000 Funds Line Item Descriptions
(Also to be used for CPA 2000 Interest reporting.)
- Salaries and Benefits– Salaries and benefits of county personal providing all or part of their time to the CPA 2000 county program(s). This line item should also include those salaries obligated under MOU’s between county departments.
- Services and Supplies - Services and supplies necessary to support CPA 2000 programs. This line item should also include those services and supplies obligated under MOU’s between county departments. This line item should not include "professional services" associated with the evaluation of the CPA funded programs, services provided by a Community-based Organization, or Administrative Overhead.
- Professional Services– This line item should include only expenditures for professional services provided by contractors to collect, analyze, evaluate and report outcome measures for a county’s approved CPA 2000 program(s).
- CBO Contracts – All CPA 2000 expenditures for services provided by community-based organizations (CBOs) should be reported in this line item.
- Fixed Assets – Using the individual counties definition for those items considered fixed assets, expenditures for all fixed assets purchased to implement and operate the county’s approved CPA 2000 program(s) should be reported in this line item.
- Administrative Overhead - Using the individual county’s definition for administrative overhead, up to 0.5% of the county’s CPA 2000 total allocation can be paid by CPA 2000 funds. If the county intends to claim administrative overhead the expenditure up to the 0.5% limit should be shown in this line item.
- Other - This line item has been included to cover any expenditures which do not fall under the categories identified above.
"Non-CPA Funds" expenditures should include the total only (specific line item reporting for this funding category is not required) from all other funding sources used to support CPA approved programs.
7.What level of accounting, and how much detail, is necessary for CPA funds??
Counties are expected to maintain sufficient source documentation to support expenditures of CPA 2000 funds. This requires programs to have a clear audit trail for all revenues and expenditures. Counties are encouraged to follow the Generally Accepted Auditing Standards (GAAS), accounting practices set forth in the State Administrative Manual (SAM) and the Government Auditing Standards (GAS) manual. Your county’s auditor will be able to advise on proper and accepted accounting standards.
8.Must we account for funds that are not CPA or interest?
Yes. The legislation requires counties to report on expenditures of CPA 2000 funds. The legislation also specifies that any interest or other income earned on the investment of Supplemental Law Enforcement Services Funds (SLESF) shall be used only for specified CPA 2000 program activities. The BOC requires expenditures to be reported for CPA 2000 funds, CPA 2000 Interest, and non-CPA 2000 funds used to support CPA 2000 activities.
9.Does interest that is not expended or encumbered return to the state?
Yes. According to the legislation interest generated from JJCPA funds must be used for JJCPA funded programs, therefore JJCPA funds and/or interest from these funds that has not been spent or encumbered by June 30, 2002 will revert to the State General Fund. Review the State Controller's Office encumbrance memo for further information.
(revised 5/23/02)
10.Can interest earned on CPA 2000 funds be used to exceed the .5% administrative cost limit?
No, this limit was established in the legislation.
11.Can other county funds be used to exceed the .5% administrative cost limitation?
Yes, unless otherwise prohibited by that funding source.
Section 5, subsection (d) (2) of the legislation states, administrative overhead costs shall only be charged by the recipient entity, as defined in paragraph (1). Paragraph 1 states a "recipient agency" or "recipient entity" is that entity that actually incurs the expenditures of the SLESF funds allocated. The BOC interprets the recipient to be the county. The legislation is silent on contract services. A county should provide sufficient oversight to limit overhead costs in any sub-contracts and comply with individual county contracting policies.
13.Can audit expenses be claimed?
Yes.
No. Section 7 30063(a) of the legislation states, "The Supplemental Law Enforcement Services Fund (SLESF) in each county or city is to be expended exclusively as required by this chapter. Moneys in that fund shall not be transferred to, or intermingled with, the moneys in any other fund in the county or city treasury, except that moneys may be transferred from the SLESF to the county’s or city’s general fund to the extent necessary to facilitate the appropriation and expenditure of those transferred moneys in the manner required by this chapter".
15.How do we break out CBO programs that serve more than CPA 2000 kids?
Irrespective of the service provider, program expenditures and program outcomes must be tracked and reported only for those juveniles who receive services that were funded in whole, or part, with CPA 2000 funds.
Yes! Consult with your local fiscal managers to ensure proper documentation and tracking processes are in place (Refer to question #15).
17.What type of documentation is required to corroborate that client services were rendered?
Adequate documentation would include sign-up sheets, case notes, meeting agendas and minutes, and/or monthly statements identifying when, where, and who attended, the service provided, and name of the service provider. The county should hold all CBO’s responsible for such documentation. Where CBO’s do not maintain adequate documentation the county is held responsible.
18.Can CPA funds be used for tenant improvements?
Yes, however, CPA 2000 funds cannot be used for any capital construction project. Funds (within a lease agreement) may be used for remodeling existing space and related improvements for offices that will accommodate staff performing CPA 2000 activities.
19.Is there a limit to how much we can spend on fixed assets before getting BOC approval?
No. Unlike the Challenge program which has a $1,000 limit, the CPA program has no limit. It is expected that the County will follow county procedure on fixed assets and will consult their Coordinating Council prior to expending large sums on fixed assets.
20.Will there be a policy manual and/or audit guide developed for CPA 2000 funds?
At this time a policy manual and/or audit guide is not planned for CPA 2000. Depending on future funding, and need, these documents may be developed in the future. The BOC will provide the Challenge and/or Construction Audit Guides for reference upon request and will develop an audit checklist for CPA 2000. When completed, the checklist will be available on the BOC website and mailed to each county.