As professionals in the victim services field, we understand that for victims, staying at home may not be the safest option right now. The KY Justice & Public Safety Cabinet Grants Management Division (GMD) wants to say thank you for continuing to deliver lifesaving services to the most vulnerable within our communities. We understand that this is a time filled with anxiety of the unknown. We thank you for your selfless service and for continuing to respond to those in need.
GMD leadership is gathering information from the CDC, the Cabinet for Health and Family Services, Office for Victims of Crime, Office of Violence Against Women, the Department of Health and Human Services, and the Department of Public Health to address the concerns that are specific to victim service providers and shelter service programs. We encourage programs to contact their local health department for the most updated information and guidance to assist in the decision-making process for their agency. This is the only guidance we have at this time, but we will be updating our guidance as more information becomes available.
Question 1: Will our agency be able to submit reimbursement requests, grant adjustment requests (GANs), etc.?
Answer 1: Yes. In lieu of recent concerns around the spread of COVID-19, we are following the lead of the Governor’s Office and GMD has implemented a telework schedule for staff. GMD has implemented an electronic workflow that accommodates the processing of payments and GANs while working remotely. Please submit all grant reimbursement requests in Intelligrants eGMS per usual, and follow the established GAN Request Process outlined in your award documents and in the attached GAN one-sheeter. GMD team members will be as responsive as possible. Please email GMD team members for the most expedient response. GMD team members will be checking their voice mail and email regularly during this time.
Question 2: Will GMD continue in-person meetings or site visits?
Answer 2: GMD has postponed and/or cancelled all scheduled meetings, site visits, and other in-person meetings until further notice. GMD has begun piloting an Enhanced Desk Review process in order to perform required compliance monitoring remotely during the COVID-19 state of emergency.
Question 3: Will GMD and other partner agencies extend deadlines for initiatives, solicitation submissions, applications, etc.?
Answer 3: At this time, GMD wants to maintain as much consistency as possible, but we have extended deadlines upon request. Office of Justice Programs has communicated that solicitations with application due dates between March 16th and March 31st will have a 2-week extension for submission. OJP program offices are in the process of updating those due dates now. OJP will continue to monitor the situation and determine if additional adjustments to closing dates will be needed. Grants.gov and OJP’s Grants Management System remain open to continue to accept applications.
Question 4: What if we need to temporarily close our shelter or other programs because of the COVID19 virus?
Answer 4: Programs should encourage social distancing per instructions from the Governor’s Office and implement prevention efforts to contain the spread of the virus. All efforts should be made to coordinate alternative placement for new/emergency clients. Shelter management may consider assigning live-in staff members to remain onsite during the quarantine with the shelter clients.
Non-shelter direct service programs such as sexual assault centers and children’s advocacy centers should consider developing an emergency plan to deliver as many services as possible in a remote or mobile manner. GMD encourages all agencies to communicate with their local health department to aid in their decision-making process. Closures and action plans will likely differ community to community.
Should any agency or program need to close its office and provide services remotely, GMD requests that an emergency action plan explaining the changes to service delivery and how services will be delivered be submitted to their assigned Program Manager.
Question 5: What if our agency has a staff member or participant that has contracted COVID-19? What if we are asked to disclose information about our participants? What information can be shared about individuals who have contracted COVID-19, those suspected of exposure to COVID-19, and those with who information can be shared?
Answer 5: TBD *See Question #26 for Resource
Question 6: What if there are interruptions in the performance of work under the grant?
Answer 6: Subrecipients should review the DOJ Grants Financial Guide and the Part 200 Uniform Requirements (2 C.F.R. Part 200, as adopted by DOJ) (see, for example, 2 CFR 200.430 and 2 C.F.R. 200.431, under Subpart E – Cost Principles), and the subgrantee’s established policies, to help in determining how the subgrantee’s personnel costs may be treated during any period(s) of interruption to the performance of work under the award. You should direct any questions about allowability of costs to your grant’s Program Manager, Financial Analyst, or their supervisors.
Question 7: Should I notify GMD about any office or shelter closures?
Answer 7: Yes, please notify GMD about any impending office or shelter closure. See FAQ Question/Answer 4.
Question 8: What should be done with shelter clients in suspected or confirmed COVID-19?
Answer 8: Per the CDC, decisions about whether clients with mild illness due to suspected or confirmed COVID-19 should remain in the shelter or be directed to alternative housing sites should be made in coordination with local health authorities. Similarly, identifying respite care locations for patients with confirmed COVID-19 who have been discharged from the hospital should be made in coordination with local healthcare facilities and your local health department.
Question 9: Can a shelter program begin reducing in shelter participants in order to provide individual rooms for survivors/families should participants need to quarantine?
Answer 9: Please see CDC guidance and resources released by NNEDV (FAQ Question 26). Whenever possible residential housing programs should provide individual quarters per survivor/family. Programs should make every effort to provide emergency services including emergency housing in shelter or via hotel stays.
Question 10: Can programs limit participant transportation to essential travel requests while federal guidance is in place to limit movement to support containment and limit spread of the virus?
Answer 10: Yes. Programs may limit access to transportation assistance to essential transportation needs of participants. Essential travel includes access to safe shelter, medical appointments, work or transportation for necessary groceries/supplies. Federal guidance asks the public to do their part to slow the spread of the coronavirus. “Even if you are young, or otherwise healthy, you are at risk and your activities can increase the risk for others. It is critical that you do your part to slow down the spread of coronavirus.” https://www.whitehouse.gov/wp-content/uploads/2020/03/03.16.20_coronavirus-guidance_8.5x11_315PM.pdf
Per the Department of Family and Children’s Services Guidance For Foster Care Parents and Provider’s, please see below for their guidance for court-ordered visitation:
What do we do about court-ordered visitation? It is the Division's recommendation that in-person court-ordered visitation be suspended and replaced with frequent video conferencing and / or phone calls to ensure children stay safe while remaining connected to their parents during this period. In order to remain compliant with judicial court orders, county DFCS offices will need to immediately work to get local juvenile court approval prior to this temporary practice change occurring.
Question 11: Can programs limit program participants traveling outside of the shelter facility to essential travel, even if participants have their own mode of transportation?
Answer 11: If a program has an approved policy, programs may limit program participants travel outside of the shelter facility to essential travel. Essential travel includes access to safe shelter, medical appointments, work or transportation for necessary groceries/supplies. Federal and state guidance asks the public to do their part to slow the spread of the coronavirus. “Even if you are young, or otherwise healthy, you are at risk and your activities can increase the risk for others. It is critical that you do your part to slow down the spread of coronavirus.” https://www.whitehouse.gov/wp-content/uploads/2020/03/03.16.20_coronavirus-guidance_8.5x11_315PM.pdf
If a participant fails to comply with the policy, the program may involuntarily exit the participant. GMD recognizes the need for agencies to implement measures to protect the safety and well-being of its staff and other participants. If the participant fails to adhere to the policy, the agency may advocate for other emergency housing options.
Question 12: If an agency needs emergency assistance funds for hotel stays or emergency supplies, are funds accessible to programs for emergency needs?
Answer 12: Supplemental funds may be available for emergency requests for client assistance. Please contact your GMD Financial Analyst to obtain additional information about the request process.
Question 13: Can agencies ask victims screening questions such as: Are you feeling ill? Have you been running a fever? Have you traveled outside of the country in the past 30 days? To your knowledge, have you been exposed to COVID-19?
Answer 13: Programs should not screen for coronavirus except for information that is critical to providing essential victim services including, but not limited to, shelter services, medical forensic care, and telehealth mental health services where the COVID-19 State of Emergency may be a trigger. Also, programs should not use health status to discriminate in access to any programs or services.
Question 14: What if our agency is receiving conflicting requirements to comply with grant programs, i.e. screening?
Answer 14: The question has been submitted to federal partners for review. TBD.
Question 15: Can agencies pay their grant funded staff (even those without leave)?
Answer 15: If programs must reduce services due to a health crisis resulting in quarantines, programs should use their existing leave policies to address employee absences. If you don't currently have policies regarding working remotely and paid administrative leave, please develop those policies. Provided your organization has policies in place and all staff (Federally funded and non-Federally funded) are treated equally, we can continue to reimburse the VOCA-funded project even if services are temporarily reduced. Please send any developed policies to your Program Manager.
Question 16: Can agencies use grant program funds to pay overtime?
Question 16: GMD understands the fluidity of the current emergency and will be as flexible as possible with budget adjustment requests to meet agency and client needs. Please submit GAN requests accordingly with any evolving needs. GMD will provide other information and resources as we are able.
Question 17: Can agencies use grant program funds to pay for administrative leave?
Answer 17: Yes, so long as the leave is in compliance with agency policy and available to all staff members, not just federally-funded positions.
Question 18: As colleges/universities are cancelling classes or going online, agencies who depend on volunteer hours for match may have struggles as their student interns/volunteers get sent home and cannot fulfill their practicum hours. Will GMD be flexible with the match requirements on federal awards?
Answer 18: If a program is unable to meet match through volunteers, we would work with them to see if they can meet match in other ways. If not, we may consider approving an emergency match waiver if the situation is well-documented.
Question 19: Should we limit non-essential travel?
Answer 19: GMD strongly encourages that subrecipients limit travel to essential travel for client services. Also see Question/Answer 9.
Question 20: If our agency needs to cancel upcoming travel, will federal funds cover cancellation fees for reserved travel for canceled conferences and training events?
Answer 21: Grantees should contact their Financial Analyst to address issues resulting from postponed or canceled meetings, such as using grant funds to cover hotel or travel related cancellation fees and penalties.
Grantees should try to have the airline reimburse the canceled ticket(s) in cash. However, if the airline will only refund the cancellation as a credit:
· The grantee should apply the credit to a future trip for the same grant or project.
· If that is not possible, the grantee should use the credit for another GMD administered grant program or project and reimburse the original grant or project with the equivalent dollar amount.
· If neither of those options is possible, then the grantee should process the trip as a COVID-19-related cancellation, which GMD approves to be charged to the grant due to this mitigating circumstance.
Question 22: What do programs/shelters do if they run out of cleaning supplies and/or necessary supplies for operation?
Answer 22: If you are unable to find supplies of hand sanitizer or other hygiene and cleaning products please contact your local health department and notify GMD. Agencies may make requests for community support for needed supplies. Agencies may also transfer program participants to available hotels to shelter in place if operational supplies are unavailable. GMD understands the fluidity of the current emergency and will be as flexible as possible with budget adjustment requests to meet agency and client needs.
Question 23: Can programs/shelters request reimbursement for specialized cleaning?
Answer 23: GMD understands the fluidity of the current emergency and will be as flexible as possible with budget adjustment requests to meet agency and client needs. Please submit GAN requests accordingly with any evolving needs.
Question 24: What type of plan should our agency put in place to respond to pandemics?
Answer 24: Please see Attachments I & II for Interim Guidance for Homeless Shelters to Respond to Coronavirus-19, and an example Pandemic Emergency Action Plan.
Question 25: How does my agency cover the crisis line during a shelter in place situation?
Answer 25: An agency may utilize staff members that are working remotely and not serving in the shelter. To ease the burden on on-site staff, programs may plan to forward calls to staff members teleworking. The crisis line should be forwarded to an agency issued cell phone that is provided by the agency. The staff member should answer the phone indicating that the caller has reached a crisis line for (Agency). The agency may develop a rotation for various staff members to respond to crisis line calls.
Question 26: What resources can our agency access for planning and response to COVID-19?
Question 27: Can GMD reimburse expenditures that provide tools to implement remote teleworking for non-essential staff?
Answer 27: GMD understands the fluidity of the current emergency and will be as flexible as possible with budget adjustment requests to meet agency and client needs. Please submit adjustment requests accordingly with any evolving needs.