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Community Prevention Grants Program

Q & A Guide
to the
Community Prevention Grants Program

The Community Prevention Grants Program (hereafer, CPG) provides a structure within which communities can mobilize; conduct multidisciplinary assessments of risk and protective factors and resources; and develop, evaluate, and monitor comprehensive, data-based, collaborative delinquency prevention plans.

State agency staff have posed many questions to the Office of Juvenile Justice and Delinquency Prevention (OJJDP) and its training and technical assistance provider about CPG administration. Because many of the issues raised in these queries apply to numerous states and communities, OJJDP has compiled this Q & A Guide to the Community Prevention Grants Program. This Guide is organized under the following topic areas: State Administration, Subgrantee Eligibility, Budget Development, Subgrantee Administration, and Training & Technical Assistance. The Guide will be updated and expanded on a continuing basis.

State Administration:

1. Question: Does the Title V Guideline (Federal Register, Vol. 59, No. 146, August 1, 1994) contain "guidelines" or "rules"? What is the difference between the two?

Answer: The Title V Guideline is a program guideline and not a rule or regulation. The difference between a rule/regulation and a guideline rests in the process by which they are developed, and in how they are applied or enforced. A rule/regulation has the force and effect of law. A guideline does not. It can be waived by the administering agency. A guideline does, however, establish enforceable requirements and conditions for the receipt of discretionary grant funds.

2. Question: Can a state set limits on allocations to subrecipients? Can a state provide declining allocations in each successive year of a 3-year grant?

Answer: Yes, the Title V Guideline does not limit a state's ability to determine the appropriate maximum (or minimum) amount for each subrecipient to carry out proposed CPG prevention activities. From experience, many states have learned that awarding fewer subgrants, each with more funding, makes preaward planning efforts more worthwhile for communities and enables them to carry out a broader range of prevention activities. The substantial increase in CPG awards to most states since FY1999 has made this approach more feasible. In fact, many states have awarded both a larger number of subgrants to communities and allocated more funding per grant.

Yes, many states provide declining allocations to subrecipients in successive years of 3-year grants, thereby preparing them to sustain their prevention efforts independent of CPG funding once the subgrant ends.

3. Question: Who determines how the elements within a state's request for proposals (RFP) for subgrants are weighted?

Answer: The Title V Program Guideline published in the Federal Register lists only the required elements of a local 3-year delinquency prevention plan, which constitutes a unit of local government's application to the state agency. No guidance is provided on weighting the elements. The State Advisory Group (SAG), in conjunction with the state agency, determines how the elements in an application, as established by the RFP, are to be weighted. The following is a sample assignment of weights (maximum points =100):

a. Provide a thorough assessment of risk factors and resources, including the quantified measurement of the risk factors that will serve as the baseline for determining project performance and outcome. (20 points)

b. Identify key community leaders and members of the Prevention Policy Board (PPB), describe their roles in the comprehensive delinquency prevention strategy, and provide evidence of their support. (10 points)

c. Clearly define the boundaries of the program's neighborhood or community. (5 points)

d. Provide a realistic assessment, including evidence, of the readiness of the community or neighborhood to adopt a comprehensive delinquency prevention strategy. (5 points)

e. Provide a coherent plan, including realistic goals and objectives, to mobilize the community and implement a strategy that will address priority risk factors, including innovative ways of involving the private nonprofit and business sectors in delinquency prevention activities. (25 points)

f. Provide specific strategies for service and agency coordination, including colocation of services at sites readily accessible to children and families in need. (5 points )

g. Provide a strategy for, or evidence of, collaboration with other units of local government and state agencies to develop or enhance a statewide subsidy program to local governments dedicated to early intervention and delinquency prevention. (5 points )

h. Provide a budget outlining the planned expenditures of grant funds and matching resources, including a narrative justifying these expenditures. (10 points)

i. Provide a sound plan for collecting data to measure performance and outcomes.(10 points)

j. Provide written statements of commitment from state or local public agencies to match, in cash or kind, at least 50 percent of the funds awarded. (5 points)

4. Question: Can OJJDP provide an example of a good checklist for monitoring subgrantees for compliance with CPG requirements?

Answer: OJJDP has developed a sample Subgrantee Program Monitoring Checklist as a technical assistance tool for states' consideration. In addition to monitoring subgrantees' fiscal management and adherence to proposed activities (both of which are necessary to monitoring any grant program), a state-level monitor needs to ensure that the subgrantee is properly implementing the CPG model (e.g., active involvement of a Prevention Policy Board, systematic implementation of a comprehensive community- and data-based prevention plan, and collection of data for measuring performance and outcomes of project activities). The sample checklist was developed to assess subgrantee projects' adherence to the CPG model.

Subgrantee Eligibility:

1. Question: My state is out of compliance with one of the core protections, although my locality is in compliance with all four core protections. Will this affect my locality's eligibility for CPG funds?

Answer: OJJDP recognizes that there are situations where a county or city that is in compliance with all four core protections yet the state as a whole is not. In such situations, states should identify those units of local government that are in compliance with all four core protections and only solicit CPG applications from and make awards to them.

2. Question: To be certified as in compliance, must a city applying for a CPG funds show that it is in compliance with the core protections or that the entire county is in compliance?

Answer: To be eligible for CPG funds, a unit of local government must be certified ascomplying with all four JJDP Act core protections. The applicant unit of local government must demonstrate compliance. If the applicant unit of local government is a city, then the city (not the entire county) must be certified by the SAG as complying with all four core requirements of the JJDP Act.

3. Question: Must compliance only be established in the jurisdictions to which youth in the applying city will be sent (e.g., if a child from one city is sent to a facility in another county)?

Answer: In the case of a state, compliance is determined by examining its juvenile justice practices, not the status of compliance of those states to which the home state has sent children for facility placements. However, the certification of a unit of local government is not limited to a specific catchment area within its boundaries. Therefore, the compliance certification must include all facilities that the city operates, contracts for, or uses inside or outside its boundaries. Further, the certification does not apply to facilities operated or controlled by other governmental units within the local governmental boundaries that are not used by the local government.

4. Question: My state has certified applicant units of local government as being in compliance with only the first three of the four JJDP Act core protections. Must units of local government be certified as in compliance with all four core protections to be eligible for CPG funds? Because no numerical requirements are attached to the Disproportionate Minority Confinement (DMC) core requirement, how would a state certify for it?

Answer: Yes, units of local government must be certified by the state as being in compliance with all four JJDP Act core protections to be eligible for CPG funds.

Although no numerical requirement is attached to the DMC core requirement and DMC studies in some jurisdictions are ongoing, units of local government can show that they are actively working on DMC issues as evidenced by, for example, cooperating with the state by supplying local DMC data as requested and, on an ongoing basis, initiating and/or working with the state on local DMC studies and interventions, and by documenting local efforts designed to prevent and/or reduce minority involvement in the juvenile justice system. A state can, therefore, certify local DMC compliance based on the latter's demonstrated efforts in this area, the same criterion used by OJJDP to determine states' DMC compliance.

5. Question: Is there a standard format or form for state certification of compliance with the four core protections?

Answer: No, there is not a standard form. States can choose any format to document their determination that units of local government are in compliance with all four coreprotections and the basis for the determination. Some states use a checklist; others use a form letter much like the one that OJJDP provides to convey determinations of state compliance.

6. Question: In our state, a school district is one of the most important political subdivisions. Can we make CPG subgrant awards to school districts?

Answer: No, a school district is not a 'general purpose political subdivision' as contemplated in the definition of 'unit of local government' in 42 U.S.C. Sec. 5601(8), although it may be a 'political subdivision' under your state's law. It has long been the agency's interpretation that a 'general purpose political subdivision' is one which possesses general jurisdictional powers, (i.e., taxing, lawmaking, and law enforcement). A school district does not have such powers. Accordingly, a school district is not a 'unit of local government' as defined in 42 U.S.C. Section 5601(8) and is not an eligible subgrantee under CPG. However, a unit of local government may contract with a school district for the provision of services.

7. Question: Can we allow our Councils of Governments to apply for CPG monies? We have considered our Councils of Governments to be eligible to apply in the past. These are our regional points of contact with local governments and nonprofits around the state. They are 501(c)(3) (nonprofit) status. They are somewhat of a quasi-governmental entity.

Answer: No, Councils of Governments are not eligible to receive CPG funds from the state because they are not units of local government. However, a unit of local government may contract with a Council of Governments or another appropriate nonprofit entity or public agency for the provision of services.

8. Question: Can a city or county have a for-profit agency implement its CPG activities?

Answer: CPG subgrantees must be units of local government which can, in turn, contract with public or private agencies to provide program administration or program services. The contracting agency can be a nonprofit or a for-profit organization (subject to state law and policy). The general practice of units of local government, however, has been to contract with public or private nonprofit agencies to implement CPG activities.

9. Question: We are part of a geographic area composed of five towns with a total population of 5,000. Youth in all five towns attend the same high school. If one of the towns takes the lead and be the grant applicant, can that town propose to deliver CPG services to all five towns?

Answer: Yes, you propose an excellent idea which should work well for your towns. Please confirm that the boundaries of the communities are described clearly in theapplication and the PPB includes a balanced representation from each of the five towns.

10. Question: What is the appropriate population size for a unit of local government? Is there an optimal size for CPG funding?

Answer: No, there is no appropriate, optimal, or required population size related to CPG for units of local government. OJJDP encourages states to work with diverse local governments, both urban and rural, large and small.

11. Question: Are all 200 plus Indian tribes in our state, or only those tribes performing law enforcement functions, eligible for CPG funds? Sovereignty is an important issue here, and we need to have an accurate answer.

Answer: Yes, all federally recognized Indian tribes are considered units of local government and are eligible to apply.

The Bureau of Indian Affairs and OJJDP take the position that all federally recognized Indian tribes perform some form of law enforcement function. The JJDP Act defines "law enforcement and criminal justice" as any activity pertaining to crime prevention, control, or reduction or the enforcement of criminal laws, including but not limited to police action to prevent, control, or reduce crime or to apprehend criminals; activities of courts having criminal jurisdiction and related agencies (including prosecutorial and defender services); activities of corrections, probation, or parole authorities; and programs relating to the prevention, control, or reduction of juvenile delinquency or narcotic addiction (Sec. 103, Subsection 6).

12. Question: Can a tribe or tribal organization whose tribal jurisdiction encompasses several cities apply for CPG funds when one of the cities is a third year CPG subgrantee?

Answer: The tribe is eligible to apply for CPG funds if its plan (either for the entire tribe or for a tribal target area) is designed and based on data for the entire tribal entity and the target area and is not merely a continuation of the services provided by a current CPG subgrantee city. The same rule would apply if the applicant was a consortium of cities.

13. Question: Is it permissible for a tribe to propose CPG activities to serve tribal youth only? We are concerned that this may constitute discriminatory practice.

Answer: Yes, a tribe may propose CPG activities to serve only tribal youth if its community data analysis supports this need. Proposing activities for a particular racial/ethnic group to meet documented needs in culturally competent ways does not constitute discriminatory practice, particularly when services are alsoavailable to youth of other racial groups in the same community, as documented in the same community data analysis.

Related to this question, it is important to note that the Title V Guideline (FR., P. 39207) encourages State Advisory Groups, while considering applications for awards, to be sensitive to the unique needs of rural areas and Native American tribes, including the provision of special consideration in the competitive process.

14. Question: Is a past or current CPG subgrantee eligible for an additional subgrant to support a new project with a new focus?

Answer: The Title V Guideline (FR., p. 39209) specifies that states will award grants to units of local government in annual increments covering not more than 12 months each, with overall project periods of 12 to 36 months. This 3-year limit is designed to maximize, over time, the number of units of local government implementing prevention strategies with CPG funds. Therefore, the general rule is that states should not award the same unit of local government another CPG award to support a new project. Instead, states should encourage all units of local government to apply for CPG funds and ensure that all interested ones have the opportunity to compete for them.

Hawaii is an exception since it has only four counties. Hawaii would have already run out of eligible subgrantees if its units of local government were not allowed to receive more than one round of CPG funds. Even in this case, the applicant unit of local government should propose data-based prevention activities for different target areas within its jurisdiction in its subsequent CPG applications.

In sum, each state is advised to promote the CPG statewide and facilitate the development of as many CPG communities as possible. Awarding the same unit of local government a new CPG subgrant should be an exception, to be approved by OJJDP on a case-by-case basis. States that have difficulties attracting different units of local government to apply for CPG funds should seek technical assistance in marketing the CPG Program.

15. Question: Can a unit of local government and one of its local subdivisions apply for CPG funds announced in either the same or subsequent announcements? For example, can Baltimore County, Maryland, and Baltimore City, which is part of Baltimore County, both respond to the same CPG RFP?

Answer: All units of local government, provided they have met other eligibility requirements, are potential CPG applicants. That the units' populations and land boundaries possibly overlap is not a limitation to participation in the program.

In the case of Baltimore County and Baltimore City in Maryland (each considered to be a unit of local government by the statutory definition), for example, each could respond to the same RFP. However, OJJDP recommends that states encourage such applicants to communicate and coordinate activities with each other to avoid supplication and enhance program outcomes. States, when reviewing applications, should look for evidence of such coordination.

Budget Development:

1. Question: What is the rationale for requiring the state or local subgrantees to provide a match of 50 percent of the amount of the grant?

Answer: The purpose of the 50 percent match requirement is to expand program service capacity, encourage communities to collaborate through resource development and sharing, and secure additional state and/or unit of local government resources to sustain the project over the long-term. The match may be comprised of cash or in-kind contributions or services. Match is required by Section 505(b)(7) of the JJDP Act.

2. Question: Can a nonprofit organization (or other private agencies) providing services under a contract with a unit of local government provide the required match?

Answer: Yes, cash or an in-kind match provided by a third party, such as a volunteer or a public or private agency, may count toward the required match.

It is important to note that states and units of local government are prohibited from requiring a cash or in-kind match from private nonprofit agencies designated by recipient units of local government as CPG implementing agencies. However, policy has allowed for cash or in-kind contributions to be volunteered by private nonprofit agencies and corporations. It is our expectation that this policy allowing third party contributions will facilitate the participation of more communities in the program. Nevertheless, OJJDP maintains the importance of state and local cash and in-kind match to the sustainability of CPG projects after Federal funding ceases.

3. Question: How is a match documented both in the local and state applications and reports?

Answer: Chapter 3 of the Office of Justice Programs Financial Guide states: Grant recipients and their subrecipients must maintain records which clearly show the source, the amount, and the timing of all matching contributions. For all block/formula funds, the state has primary responsibility for subrecipient compliance with the requirements. Therefore, the state must ensure that the proposed match from each subgrantee unit of local government is provided, and that the total match from all subgrantees within the state adds up to the 50 percent match amount articulated in the state's CPG application to OJJDP.

4. Question: How much is the standard charge for in-kind volunteers? In other words, when a unit of local government proposes a match, what is allowable (or just standard practice) to use as an hourly rate for volunteers? Does some kind of Federal standard exist to shed light on this issue?

Answer: There is no Federal standard charge or rate for the value of donated services. The nature of donated services varies greatly; therefore, their values vary. Below is a customary way of calculating the value of such services.

To calculate in-kind contributions of volunteers, one needs to take into account the activities performed by the volunteers and how much it would have cost the subgrantee unit of local government if such activities were performed by paid staff. For example, if a social worker volunteers his/her professional services for a CPG program for 5 hours per week, the in-kind contribution amount for this volunteer per year is:

The agency hourly rate for a social worker ($X) x 5 hrs x 52 weeks

If a retired social worker chooses to perform clerical work for a CPG program for 5 hours per week, the in-kind contribution of this clerical volunteer per year is:

The agency hourly rate for a clerk ($X) x 5 hours x 52 weeks.

Fringe benefits should be added when applicable. For example, if the same social worker volunteers his/her professional services 25 hours per week, the in-kind contribution of this volunteer per year is:

The agency hourly rate for a social worker ($X) x 25 hrs x 52 weeks x 1.30 (In general, the average fringe rate is about 30 per cent of a total salary cost.)

5. Question: Can a unit of local government's CPG application include administrative costs or indirect costs?

Answer: Yes, a CPG application can include administrative costs—expenses associated with administering a project, such as salaries and fringe benefits to cover costs of personnel related to the project, travel, training, evaluation, telephone, equipment, and printing.

On the other hand, "indirect costs are costs of an organization that are not readily assignable to a particular project, but are necessary to the operation of the organization and the performance of the project." "In order to be reimbursed for indirect costs, a recipient must first establish an appropriate indirect cost rate" (Office of Justice Program Financial Guide, Chapter 17: Indirect Costs).Administrative costs are not synonymous with indirect costs. Your state's CPG applications to OJJDP cannot include indirect costs as defined. This restriction does not apply to subrecipients.

6. Question: Does CPG require an evaluation? Can the costs of the evaluation be included in the budget?

Answer: Yes, an evaluation plan is a required element of a local 3-year delinquency prevention plan.

Yes, the cost of the evaluation can be included in the budget. In fact, some states require applicant units of local government to include evaluation costs in their proposed budget to ensure sufficient dedicated resources to conduct an evaluation as planned. OJJDP considers this to be a sound practice.

7. Question: The Title V Guideline states: "CPG funds cannot be used for construction; land acquisition; or supplantation of Federal, state, or local funds supporting existing programs or activities." Below are three scenarios that have been encountered by state agencies. Are they considered supplanting and, thus, in violation of the Guideline?

Answer: Background: The OJP Financial Guide (p.22) states: "Federal funds must be used to supplement existing funds for program activities and not replace those funds which have been appropriated for the same purpose." (Emphasis added.) The key word here is "same." Further, all proposals for using CPG funds to pay for existing positions in a unit of local government and/or in a private nonprofit agency serving as a CPG implementing agency require utmost scrutiny in preaward application review, post-award monitoring, and audits by the state agency to ensure that the proposed positions are, in fact, performing grant related functions and enhancing CPG activities. Applicant units of local government must provide a written certification to the state agency at the time of application that CPG funds will not be used to supplant local funds.

Question A: Is it considered supplanting when the applicant county proposes to use CPG funds to pay 50 percent of the personnel cost of an existing full-time secretary in the county school district which will be the CPG implementing agency?

Answer: Unless there is clear documentation of a real restructuring of this position and documentation of the actual use of the position for CPG (through audits of time sheets, for example), it is likely that supplanting is taking place. States are advised to avoid such situations.

Question B: Is it considered supplanting when the applicant county proposes to use CPG funds to pay portions of personnel costs of several existing positions in a private nonprofit organization that will be designated by the county as a CPG implementing agency?

Answer: This scenario is similar but even more complicated than Scenario A because it requires the state agency to audit an agency at a different level than the county, which will require enhanced oversight. States are advised to carefully document such situations in order to avoid supplanting.

Question C: Is it considered supplanting when the applicant county proposes to use funds to pay 50 percent of the personnel cost of an existing full-time secretary in the county department of transportation so this position could then be restructured to provide 50 per cent of the time to the county department of human services to support the proposed CPG activities and to continue clerical support to the county department of transportation for the remaining time?

Answer: If the county department of human services, by using funds to pay 50 percent of the salary for a full-time secretary position, would gain heretofore nonexistent clerical support to the proposed activities and, at the same time, the county department of transportation would lose 50 per cent of that secretary's services, the proposed use of funds would not be considered supplanting. However, a certification of nonsupplanting at the time of the application and close postaward monitoring and audit by the state agency on an ongoing basis would be required.

8. Question: A recipient would like to use funds to remodel a building (currently used as a bar) for use as a teen center. The remodeling would include interior cosmetic repairs and possible roof replacement. Is this an appropriate use of funds? We understand that construction is not an allowable expense under CPG, but this would only be remodeling.

Answer: According to the Title V Guidelines (FR., p.39209), CPG funds cannot be used for construction. The OJP Financial Guide (p.77) specifies that "under the JJ Act (OJJDP), construction means the acquisition, expansion, remodeling, and alteration of existing buildings and initial equipment of any such buildings or any combination of such activities." In sum, CPG funds cannot be used for construction, which includes remodeling.

However, under certain circumstances, namely, when "costs are incurred as an incidental and necessary part of a program and are for renovation, remodeling, maintenance, and repair costs which do not constitute capital expenditures," Federal grant funds may be used but may not exceed 10 percent of total construction project costs (the OJP Financial Guide, p. 78). In addition, if Federal funds are used to change the use of a structure, in this case from a bar to a teen center, then an Environmental Impact Review must be completed by the Federal government. This will take a minimum of 6 to 8 months to complete.

In sum, given the prohibition against construction, including renovation and the limited and potentially time consuming exceptions available, we suggest that the use of CPG funds for the stated purpose is not a viable option. Instead, the community might consider generating revenue to finance the renovation from a community fundraising project, donated work and materials from the business community, and combinations of other resources. This might also be a good way to satisfy the 50 percent match requirement.

Subgrant Administration:

1. Question: The state is in the process of putting together next year's CPG RFP. The RFP authorizes the following types of activities as eligible for funding: (1) to form coalitions within communities that mobilize and direct delinquency prevention efforts; (2) to identify known delinquency risk factors present in affected communities; (3) to identify protective measures that counter identified risks and to develop local comprehensive delinquency prevention plans that strengthen these protective measures; (4) to develop local, comprehensive delinquency prevention strategies that coordinate Federal, state, local, and private resources to establish a client-centered continuum of services for at-risk children and their families; and (5) to implement delinquency prevention strategies, monitor their progress, and modify the strategies as needed. The RFP does not specifically state that selected grantees must provide direct services to youth. Is this a must?

Answer: CPG funds are intended to be used for service delivery (the Title V Guideline, FR., P. 39211). The first four activities included in the draft RFP are not service delivery projects but, rather, planning activities for which CPG funds cannot be used. Community prevention plans resulting from these planning activities would support an application for CPG funds. Guided by these community prevention plans, participating communities may implement a broad range of prevention activities using CPG funds. Some examples are nurse home visitation and preschool/parent training programs, mentoring, afterschool activities, tutoring, truancy and dropout reduction, substance abuse prevention, gang prevention outreach, and police/probation teams. Therefore, the RFP must be revisedaccordingly. OJJDP can supply sample CPG RFPs for state reference and use.

2. Question: Each CPG subgrantee may be funded in 12-month increments for up to 3 years. What is the rationale for this 3-year limit?

Answer: CPG funds are intended to be seed monies for program startup. Through the 3-year funding limit, OJJDP intends to provide more opportunities for communities to receive CPG funds and embrace community mobilization and data-based delinquency prevention planning and implementation.

3. Question: Is it permissible for CPG projects to be continued at the end of the 3-year funding period using other funding (e.g., state dollars)?

Answer: Yes, states and localities are encouraged to continue successful CPG strategies, after program funding ends. Example sources of continuation funds are: State general funds designated for delinquency prevention, county or city general funds, JJDP Act Formula Grants funds, and other public and private funds. When using JJDP Formula Grants program funds, states must be sure that this prevention expenditure is consistent with their comprehensive JJDP 3-year plan. Note that, like CPG, the JJDP Formula Grants program also has time limitations. Most states set a 3-year limit for consecutive funding under a single award.

4. Question: Does OJJDP gauge success by whether a community continues its CPG project at the end of the funding period?

Answer: Yes, one of the many indicators of success for a CPG project is the community's ability to continue it beyond the 3-year funding period. Continuation suggests that the project was effective enough to garner private and/or public funding. It is helpful if states follow their former subgrantees to see if the projects continue. OJJDP's management and evaluation contractor, Caliber Associates, contacts states at the end of each year to collect such information for the Annual Title V Report to Congress.

5. Question: Several subgrantees did not spend all of their CPG funds during the 12-month period of their second year and would like to extend those funds 1 to 6 months. (Each project varies.) First, is this allowed, and second, will it affect the grant period for third year funding? (i.e., if the project has already been funded for 30 months due to extending its second year of funds, can the third year fund period only be 6 months?) The Title V Guideline authorizes, "annual increments covering not more than 12 months each, with overall project periods of 12 to 36 months." The Guideline doesn't mention grant extensions, which seem to have become almost a standard practice.

Answer: In general, states may approve grant extensions for their subgrantees in the sameway that OJJDP approves grant extensions for awards to state agencies.

A state can extend a subgrant as long as the subgrantee justifies, in writing, the need for an extension and the state considers the reason and the length of the extension both justifiable and fiscally prudent. In other words, the need may not be the result of unsatisfactory and inefficient performance by the subgrantee. Also, states should be wary of repeated requests for extensions on the same award because such requests, unless caused by exceptional circumstances, may signal a lack of planning, poor administration, and/or other potentially serious problems on the part of the subgrantee.

An extension for the second year award should not affect the grant period of the subgrantee's third year award. In other words, if the state has determined that the subgrantee's need for an extension is due to extenuating circumstances and is, therefore, justified, the state needs not penalize this subgrantee by shortening its third year award, provided that the state has determined that the project is worthy of continuation into the third year.

The Title V Guideline specifies that each project may be funded in 12-month increments for up to 3 years. It does not address special circumstances that require extensions because most grants, if managed well and without extenuating circumstances, do not need extensions. Therefore, if grant extensions become a standard practice in a state, this should be a cause for concern. There may be areas in which the state agency and OJJDP can assist subgrantees, through technical assistance, to reduce extension requests.

Training & Technical Assistance:

1. Question: Must the Prevention Policy Board be in place before a community can receive CPG training?

Answer: Yes. Although states can choose to use different research-based prevention frameworks for training, the Prevention Policy Board, being the training recipient, needs to be formed before the training takes place. OJJDP encourages the use of existing similar boards to meet this CPG requirement. The first training in OJJDP's current CPG training curriculum is Community Team Orientation, provided for prevention policy boards in their respective communities. Communities interested in CPG funds should each first organize/designate a Prevention Policy Board before requesting training. Communities that experience difficulties in organizing/designating a viable Prevention Policy Board may request technical assistance to overcome these difficulties.

2. Question: If requests for training are received from two different communities in different parts of the state, can training be provided at each community's location at different times during the year?

Answer: It depends on the training. Communities request training to better prepare themselves to respond to their state's RFP. Therefore, they are likely to request training within the same time frame. The first training, Community Team Orientation Training, is now conducted at individual community sites in order to maximize the participation of the community leaders. However, the Data Collection and Analysis Training and the Promising Programs and Plan Development Training are usually provided to groups of communities for reasons of cost-efficiency.

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