Guidance for Funding Recipients
The Office of Grants and Research is committed to maintaining public trust and confidence with the millions of state and federal grant dollars entrusted to this organization.
As the State Administering Agency (SAA) for federal funds received from the Department of Justice, Federal Emergency Management Agency and National Highway Traffic Safety Administration, as well as the Public Safety and Security Secretary’s designee for state public safety grants awarded by the legislature, the Office of Grants and Research is responsible for ensuring that these funds are used for their intended purpose and in compliance with all federal and state rules and regulations.
Luxury items
Luxury items are strictly prohibited from state and federal grant awards. For example, jewelry, luxury vehicles, items for personal use, and the like are strictly unallowable.
The guidelines specifically enforce this through a few key principles:
- Reasonable Costs: A cost is considered reasonable if it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
- Luxury Travel Prohibitions: Upgraded travel is heavily restricted. For instance, federal funds typically only cover the least expensive class of travel (economy). First-class flights, luxury hotel suites, apartment rentals, and high-end dining are unallowable.
- Entertainment and Gifts: The Uniform Guidance expressly prohibits the use of federal funds for entertainment, amusement, and social activities. Items like promotional materials, mementos, or gifts are generally considered unallowable.
What to Do Instead
Before making purchases, organizations should check the specific terms and conditions of their grant award and consult with their assigned OGR program coordinator for review and approval.
Overtime
Some grant programs allow recipients to request funds for first responder or contractor overtime. If awarded grant funding for overtime costs, OGR will provide additional information and reporting forms at the time an award is made.
OGR defines overtime as the additional costs that result from state and local first responders working over and above their weekly full-time/part-time schedule as a direct result of their performance of approved activities related to the project receiving grant funding.
Grant funds may only be used to pay overtime for actual hours spent working on grant-related activities. If a union contract requires that officers be paid for a minimum number of hours during an overtime shift, only the actual hours worked on the grant funded project may be charged against the grant. The remaining portion must be paid out of the department’s own budget. For example, an officer working two hours of overtime on a grant-funded project may only charge the grant award for two hours of overtime. If the officer’s union contract requires that the department pay a minimum of four hours for an overtime shift, the department is only allowed to charge two hours of overtime against the grant. The remaining amount must be paid out of the department’s own budget.
Departments found violating this policy will be subject to immediate termination of a grant award and must return all misspent funds to OGR.
Overtime rates charged to a grant award must be consistent with the subrecipient’s established overtime policies and applicable wage laws. If an agency does not have an established overtime policy, rates must be calculated in accordance with federal and state laws and applied consistently across grant funded and non-grant funded activity.
Grant-funded overtime may not be created or manipulated in order to pay a higher rate than would otherwise apply. Subrecipients shall not approve, schedule, or encourage the use of paid time off in a manner designed to shift grant-funded activities into overtime status when it would not be otherwise. For example, the activity would otherwise fall within an officer’s regular hours but for the use of paid time off earlier in the pay period.
Each state and federal grant program offered by OGR has different, program-specific rules related to overtime and backfill. Please refer to the specific grant program for information on what is and is not allowable. Subrecipients should refer to their OGR program coordinator or their own department or organization’s legal counsel for additional guidance.
Reporting Waste, Fraud or Abuse
It is the responsibility of each grant recipient to report alleged waste, fraud, or abuse of state or federal grant funds. This includes any alleged violations, serious irregularities, sensitive issues, or overt or covert acts involving the use of public funds in a manner not consistent with legislative statutes, related laws and regulations, and appropriate guidelines for purposes of the grant. Reports can be made to the Massachusetts Inspector General or Office of the State Auditor.