Project Safe Neighborhoods: Community Engagement and Media Outreach Technical Assistance Program, FY 2004

Other Requirements

Civil Rights Compliance

All recipients of federal grant funds must comply with nondiscrimination requirements contained in federal laws. If a court or administrative agency makes a finding of discrimination against a recipient of funds on grounds of race, color, religion, national origin, gender, disability, or age after a due process hearing, the recipient must forward a copy of the finding to the Office for Civil Rights of the Office of Justice Programs.

Limited English Proficiency

National origin discrimination includes discrimination on the basis of limited English proficiency (LEP). To ensure compliance with Title VI and the Safe Streets Act, recipients are required to take reasonable steps to ensure that LEP persons have meaningful access to their programs. Meaningful access may entail providing language assistance services, including oral and written translation when necessary. The U.S. Department of Justice has issued guidance for grantees to assist them in complying with Title VI requirements. The guidance document can be accessed on the internet at www.lep.gov, by contacting OJP's Office for Civil Rights at 202–307–0690, or by writing to the following address:

Office for Civil Rights
Office of Justice Programs
U.S. Department of Justice
810 Seventh Street NW., Eighth Floor
Washington, DC 20531

Faith-Based and Community Organizations

It is OJP policy that faith-based and community organizations that statutorily qualify as eligible applicants under OJP programs are invited and encouraged to apply for assistance awards. Faith-based and community organizations will be considered for awards on the same basis as any other eligible applicants and, if they receive assistance awards, will be treated on an equal basis with all other grantees in the administration of such awards. No eligible applicant or grantee will be discriminated against on the basis of its religious character or affiliation, religious name, or the religious composition of its board of directors or persons working in the organization.

Anti-Lobbying Act

The Anti-Lobbying Act (18 U.S.C. § 1913) recently was amended to expand significantly restrictions on the use of appropriated funding for lobbying. This expansion also makes the anti-lobbying restrictions enforceable via large civil penalties, with civil fines between $10,000 and $100,000 for each individual occurrence of lobbying activity. These restrictions are in addition to the anti-lobbying and lobbying disclosure restrictions imposed by 31 U.S.C. § 1352.

The Office of Management and Budget (OMB) is currently in the process of amending the OMB cost circulars and the common rule (codified at 28 C.F.R. Part 69 for Department of Justice grantees) to reflect these modifications. However, in the interest of full disclosure, all applicants must understand that no federally appropriated funding made available under this grant program may be used, either directly or indirectly, to support the enactment, repeal, modification, or adoption of any law, regulation, or policy, at any level of government, without the express approval by OJP. Any violation of this prohibition is subject to a minimum $10,000 fine for each occurrence. This prohibition applies to all activity, even if currently allowed within the parameters of the existing OMB circulars.

Confidentiality and Human Subjects Protection

U.S. Department of Justice regulations (28 C.F.R. Part 22) require applicants for BJA funding to submit a Privacy Certificate as a condition of approval of any grant application or contract proposal that contains a research or statistical component under which personally identifiable information will be collected. In addition to the regulations in Part 22, regulations concerning protection of human subjects are set forth in 28 C.F.R. Part 46. In general, 28 C.F.R. Part 46 requires that all research involving human subjects conducted or supported by a federal department or agency be reviewed and approved by an Institutional Review Board before funds are expended for that research.

General information regarding Confidentiality and Human Subjects Protection can be found on the National Institute of Justice web site. Sample formats of the Privacy Certificate, Transfer Agreement, and Single Project Assurance for submission to BJA can be found on the OJP web site.