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JJCPA - FAQ 5


Juvenile Justice Crime Prevention Act

Frequently Asked Questions #5
(1/23/02)


QUESTIONS

  1. Will counties lose the second allocation if all JJCPA dollars, plus interest, from the prior allocation are not spent by June 30, 2002?
  2. Is the second allocation ONLY for 2002/03 expenditures?
  3. Do counties have to wait for plan approval to start using the second allocation monies?
  4. 4.         If a Community-Based Organization (CBO) is being paid from County General Funds, as well as JJCPA funds, does the CBO need to have separate budgets for each fund and separate invoices each month?     Can they submit one budget for the program and then each month invoice the county according to the ratio of funds contributed by each funding source?

    5.                   Can a CBO claim administrative overhead costs and is there a limit?

    6.         When program staff work less than full-time can a county use a simple percentage of an individual’s time versus identifying actual hours that person spends on JJCPA-related activities?

    7.         Would research to expand a current JJCPA program to another area of the county be an appropriate/allowable program expenditure?

    8.         Is it allowable to use JJCPA funds to pay for overtime on an interim basis while we are recruiting for additional staff?

    9.         What is the appropriate use of the interest earned on the JJCPA allocation?

    10.        Can JJCPA funds be used to pay for professional association memberships?

    11.        Can JJCPA funds be paid out for the lease of a building all at once, or is it necessary to make monthly payments?

    12.        How do we show program costs, such as evaluation and training, that cross over more than one program?

    13.        Rather than pay a CBO or other agency each month, can we transfer all of the CBO’s allocation to them when received by the county?

    14.        Can expenditures encumbered in the FY 2001/02 fiscal year, but not actually paid out until after June 30, 2002 be reimbursed with JJCPA funds?

    15.        If we transfer funds from the Probation SLSEF account to the account of another county department that is operating one of the JJCPA programs, do those funds qualify as “encumbered”?

    16.        Can budget modifications be made during the one year liquidation period?

    17.        By what date will the first allocation’s unspent state and interest funds need to be returned to the State Controller? Will we be invoiced or is there a mechanism for returning?

    18.        Who is entitled to the interest earned on CPA funds?

    19.        We are not directly charged and billed for utilities, janitor, and maintenance costs incurred by our General Services Department.   Can we get a bill from General Services and charge this cost to JJCPA?

    20.        Do we need BOC approval to move funds between programs or among the various program components?

    21.        Can JJCPA funds be used for out-of-state training and travel?

    22.        Does JJCPA limit the types of contracts that the county or an agency can enter into, i.e.,  cost reimbursement, unit of service, or flat fee contracts.

    23.               Does the county Board of Supervisors need to approve changes to program outcomes measures?

    24.        When we complete the plan modification budget page how do we show the “current budget” interest if none was allocated to the JJCPA funded program?

    25.        Does the county auditor determine how much interest was made on the JJCPA funds?

    26.        Is there a limit to the amount of JJCPA funds that can be used to offset the administrative costs of county auditor?

    27.        Do we have to show the interest earned on JJCPA funds by fiscal year?

 

 


 

1.         Will counties lose the second allocation if all JJCPA dollars, plus interest, from the prior allocation are not spent by June 30, 2002?

 

Senate Bill 736, Chapter 475, Statutes of 2001 contains language in Section 30063(f) that addresses the subsequent years allocation.   Senator Poochigian, the author has introduced amendments in SB 823 that would amend the affected section and result in no loss of funding, as long as the county submits the required expenditure and outcome data.   Additionally, the Senator has submitted a Journal Letter to the Secretary of the Senate and the Clerk of the Assembly indicating that he did not intend that Section 30063(f) apply to the JJCPA program. 

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2.         Is the second allocation ONLY for 2002/03 expenditures?

 

The second allocation of JJCPA funds was actually forwarded to the counties in late September 2001.   Once the County Plan Modification Application has been completed and approved by the county Board of Supervisors and approved by the Board of Corrections, and if the first allocation and interest has been expended, the county can begin spending its second allocation.  

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3.         Do counties have to wait for plan approval to start using the second allocation monies?

 

Yes.   It is important that you work with the assigned BOC Field Representative/Consultant to assure that all necessary requirements are completed and approved.   Once the county has submitted the final JJCPA Plan Modification to the BOC, it will be approved within 30 days.   All plan modifications are due no later than May 1, 2002.   WE STRONGLY RECOMMEND THAT YOU WORK CLOSELY WITH YOUR BOC ASSIGNED STAFF TO EXPEDITE REVIEW OF YOUR DRAFT DOCUMENTS PRIOR TO SUBMITTING THE RESOLUTION AND APPLICATION TO YOUR BOARD OF SUPERVISORS AND BEFORE FINAL SUBMITTAL TO THE BOC.   Include sufficient time in your schedule for the county Board of Supervisors to review and approve the Plan.

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4.         If a Community-Based Organization (CBO) is being paid from County General Funds, as well as JJCPA funds, does the CBO need to have separate budgets for each fund and separate invoices each month?     Can they submit one budget for the program and then each month invoice the county according to the ratio of funds contributed by each funding source?

 

Program budgets should as accurately as possible estimate how the program will be funded among different funding sources.

 

If you review the BOC online JJCPA Progress Report the county is annually required to report monies in the following 3 areas:

·         State JJCPA funds

·         Interest on State JJCPA funds

·         Other Funding

There are three parts to the question, establishing the budget, documenting expenditures during the service delivery period, and reporting expenditures to the BOC annually. 

 

The approved plan from each county requires that you submit a budget plan that identifies the estimated dollars for each program, as well as identifying other funding sources that may be contributed to the program.

 

Once the plan has been approved, the county needs to develop fiscal reporting systems to accurately capture costs by all of the programs reporting sources.   It is up to the county to decide what the invoice format should look like.   While there are no provisions in the current legislation for a state audit, we would assume that the JJCPA program will be included as part of a county’s annual audit.    The county should also maintain appropriate fiscal oversight over JJCPA funds expended   This requires good accounting principles and appropriate documentation of expenditures.

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5.         Can a CBO claim administrative overhead costs and is there a limit?

If administrative costs were identified in the contract between the county and CBO, such costs could be claimed from JJCPA funds.   Fiscal oversight by the county should be exercised in assuring that costs are reasonable.

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6.         When program staff work less than full-time can a county use a simple percentage of an individual’s time versus identifying actual hours that person spends on JJCPA related activities?

Using a percentage of a person's time, in and of itself, is not sufficient supporting documentation for claiming state funds. Providing a signed time sheet indicating the actual number of hours an employee dedicates to funded activities, in conjunction with other payroll records, is the preferred supporting documentation.

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7.         Would research to expand a current JJCPA program to another area of the county be an appropriate/allowable program expenditure?

Yes.   Many counties have selected additional research and evaluation outcomes, beyond the legislatively mandated ones, that they are measuring.   Research progress reports on funded programs should be periodically provided to the JJCC and BOS.   It would be appropriate for the county to use the program evaluation data to make program related modification or expansion decisions.

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8.         Is it allowable to use JJCPA funds to pay for overtime on an interim basis while we are recruiting for additional staff?

 

Yes, as long as it is consistent with county policy, is not supplanting, is consistent with the goals of the approved JJCPA plan, and is programmatically necessary for delivery of services.

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9.         What is the appropriate use of the interest earned on the JJCPA allocation?

 

The legislation specifies that any interest or other income earned on the investment of Supplemental Law Enforcement Services Funds (SLESF) shall be used only for specified JJCPA program activities.

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10.        Can JJCPA funds be used to pay for professional association memberships?

 

No!

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11.        Can JJCPA funds be paid out for the lease of a building all at once, or is it necessary to make monthly payments?

 

Yes it can be paid all at once as long as the payment is made during the allocation year and for the time period covered by the current JJCPA allocation year.  Prepayment of subsequent year leases may be allowed pursuant to the State Controller's Office encumbrance memo.(revised 5/23/02)

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12.        How do we show program costs, such as evaluation and training, that cross over more than one program?

 

Costs need to be pro-rated across the affected programs and contained within those budgets.

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13.        Rather than pay a CBO or other agency each month, can we transfer all of the CBO’s allocation to them when received by the county?

 

No, the county cannot contract away their administrative oversight responsibility. 

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14.        Can expenditures encumbered in the FY 2001/02 fiscal year, but not actually paid out until after June 30, 2002 be reimbursed with JJCPA funds?

 

The BOC developed encumbrance guidelines to assist counties in determining acceptable encumbrance practices.  The State Controller's encumbrance policies of 5/1/02 supercede the BOC Guidelines. (revised 5/23/02)

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15.        If we transfer funds from the Probation SLSEF account to the account of another county department that is operating one of the JJCPA programs, do those funds qualify as “encumbered”?

 

Yes.   Funds must be expended or encumbered by June 30 for services.  Review the State Controller's Office encumbrance memo for further information. (revised 5/23/02)

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16.        Can budget modifications be made during the one year liquidation period?

 

Review the State Controller's Office encumbrance memo for clarification of this question. (revised 5/23/02)

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17.        By what date will the first allocation’s unspent state and interest funds need to be returned to the State Controller?  Will we be invoiced or is there a mechanism for returning?

 

The State Controller has developed a form and procedure for returning unspent monies. Unspent monies remaining after the one year liquidation period must be returned to the State Controller's Office. (revised 5/23/02)

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18.        Who is entitled to the interest earned on CPA funds?

 

Interest earned on JJCPA funds at the local level (i.e. COPS and JJCPA) must be allocated in the same proportion and for the same purposes as outlined in the legislation.   Specific program allocations for State funds and interest within the JJCPA Plan programs are based on the recommendations of the JJCC and approval of the Board of Supervisors and Board of Corrections.

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19.        We are not directly charged and billed for utilities, janitor, and maintenance costs incurred by our General Services Department.   Can we get a bill from General Services and charge this cost to JJCPA?

 

Typically these types of expenses would be included in overhead and be charged against the .5% allowed by JJCPA for overhead purposes.   In order to charge the JJCPA fund directly for these services or expenses a bill or invoice must be received.   If a bill is not received, or a department is not charged for these expenses, a department cannot estimate the expense and charge the JJCPA program.

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20.        Do we need BOC approval to move funds between programs or among the various program components?

 

Generally that is the county’s decision, but check with your BOC Field Representative to discuss whether there is any programmatic or outcome measures impact that would require additional explanation or justification.   A record of such actions should be maintained and kept with the county’s official JJCPA file.

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21.        Can JJCPA funds be used for out-of-state training and travel?

 

No.   JJCPA funds are to be expended for costs incurred in California.  The BOC encourages counties to assess their training needs and develop collaborations in and between counties to structure training programs within California.  

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22.        Does JJCPA limit the types of contracts that the county or an agency can enter into, i.e.,  cost reimbursement, unit of service, or flat fee contracts.

 

No.   This is a county decision.

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23.        Does the county Board of Supervisors need to approve changes to program outcomes measures?

 

It depends on the nature of the changes.  

 

Board of Supervisors approval will generally not be required if:

·         a deleted outcome measure is not the exclusive outcome measure for a given program goal, or.

·          the deleted outcome measure will be replaced with an alternative outcome measure that addresses the same program goal.

Board of Supervisors approval will generally be required if:

·         a program outcome measure is being deleted, and there are not other outcome measures for the same program goal.

·         numerous outcome measures will be deleted or replaced, irrespective of the nature of the changes.

The BOC recommends that the county provide the JJCC and BOS with  periodic progress reports on the funded programs.

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24.        When we complete the plan modification budget page how do we

show the “current budget” interest if none was allocated to the

JJCPA funded program?

 

If no interest was allocated to an existing JJCPA-funded program then zero (0) is shown in the interest column.   Only report on what was actually allocated.

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25.        Does the county auditor determine how much interest was made on the JJCPA funds?

 

No, the county treasurer is required to make all county investments.

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26.        Is there a limit to the amount of JJCPA funds that can be used to offset the administrative costs of county auditor?

 

Yes, the amount cannot exceed the .5% limit on administrative costs that can be paid with JJCPA funds.

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27.        Do we have to show the interest earned on JJCPA funds by fiscal year?

 

Yes.

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