# Delinquency Prevention Program Guideline

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URL: https://www.frixlaw.com/law-library/documents/fr%3A94-18650

## Record

- **Collection:** Federal Register
- **Document type:** Uncategorized Document
- **Published:** August 1, 1994

## Text

SUMMARY: The Office of Juvenile Justice and Delinquency Prevention
(OJJDP) published a proposed guideline for the Title V Delinquency
Prevention Program on February 11, 1994, and solicited public comments.
Based on the analysis of those public comments, OJJDP is issuing this
final guideline. This Program is of interest to all Federal, State,
local, and private organizations involved with prevention planning and
services for children, youth and families.

DATES: This final guideline is effective on August 1, 1994.

ADDRESSES: Office of Juvenile Justice and Delinquency Prevention, Room
742, 633 Indiana Avenue, N.W., Washington, DC 20531

FOR FURTHER INFORMATION CONTACT: Paul E. Steiner, Social Science
Program Specialist, State Relations and Assistance Division, Office of
Juvenile Justice and Delinquency Prevention, at the above address.
Telephone (202) 307-5924.

SUPPLEMENTAL INFORMATION: Section 504(1) of the JJDP Act directs OJJDP
to issue ``such rules as are appropriate and necessary to carry out''
the Title V--Incentive Grants for Local Delinquency Prevention
Programs.

Changes to Proposed Guideline

The following changes are made to the proposed guideline. New
language is italicized.
Throughout the guideline, references to ``units of local
government'' are changed to ``units of general local government.''
The following sentence is added to the last paragraph under ``Local
Subgrantee Qualifications'': State Advisory Groups may not arbitrarily
exclude an eligible unit of general local government from competing for
Title V funds.
Under ``Application Requirements for State Agencies,'' the first
sentence is amended as follows: State agencies must provide evidence of
the State Advisory Group's authority to approve the award of Title V
subgrants or, where a separate supervisory board is vested with such
authority, to review and recommend approval to the board. No Title V
subgrants can be made to a unit of general local government absent the
approval or recommendation of the State Advisory Group.
Under ``Application Requirements for State Agencies,'' the
following paragraph is inserted after the fifth paragraph of that
section: The application must include a time-task plan providing a
description of the major tasks which the State will employ to implement
the Title V program, and the timeframes for completing each of those
tasks.
Under ``Application Requirements for State Agencies'' the fourth
paragraph is amended as follows: 2. To monitor and assure the audit of
subgrants for performance, outcome, and fiscal integrity, including
cash and in-kind match, as specified in the current edition of the
Office of Justice Programs Guideline Manual M-7100, ``Financial and
Administrative Guide for Grants.''
The first sentence under ``Process for Subgrant Award and
Administration'' is amended to read: State agency grantees shall use
essentially the same process for making Title V subawards as that used
for the Formula Grant awards, with the State Advisory Group
establishing applicant eligibility criteria to target specific types of
communities, if needed, and making or recommending the final decision
on funding individual applications.
Under ``Application Process for Units of general local
government,'' subsection 3. ``Local Three-Year Delinquency Prevention
Plan,'' the following sentence is inserted between the second and third
sentence of the second paragraph of the subsection: The applicant
should also assure that the PPB, to the extent possible, contains one
or more members under the age of twenty-one, one or more parents or
guardians with children who have had contact or are at risk of having
contact with the juvenile justice system, and an overall membership
that generally reflects the racial, ethnic, and cultural composition of
the community's youth population.
Under the section titled ``Application Process for Units of General
Local Government,'' subsection 3. ``Local Three Year Delinquency
Prevention Plan,'' the eleventh paragraph (paragraph j.) is amended to
read: A description of how the PPB will provide general oversight for
developing the plan, approve the plan prior to submission to the State,
and make recommendations to the responsible local agency for the
distribution of funds and evaluation of funded activities.
Under the section titled ``Duration of Grants and Continuation
Funding,'' the following changes are made: (1) The following sentence
is stricken: Grants may be awarded for project periods of 12 to 36
months, with initial awards of up to one year. The following two
sentences replace the stricken sentence: OJJDP will award grants to
States for a project period beginning on the date of award and ending
on September 30, 1996. States will award grants to units of general
local government in annual increments covering not more than 12 months
each, with overall project periods of 12 to 36 months; and (2) in the
second sentence the word ``continuation'' is stricken and replaced with
Subsequent years'. At the end of that sentence, ``subsequent fiscal
years'' is stricken.

Background

A new program was authorized in the 1992 amendments to the Juvenile
Justice and Delinquency Prevention Act of 1974, as amended, (hereafter
``the Act'' or ``the JJDP Act'') in Title V, Sections 501-506,
``Incentive Grants for Local Delinquency Prevention Programs Act.'' For
Fiscal Year 1994, Congress appropriated $13 million for initial
implementation of Title V.
Prevention has been one of the primary goals of the Act since its
enactment in 1974. The premise is that preventing delinquent behavior
is a much more cost-effective means of reducing juvenile crime than
attempting to rehabilitate adjudicated delinquents. Prevention is also
a much more cost-effective way to deal with juvenile delinquency. In
addition to reducing the human and financial losses caused by crime,
effective delinquency prevention also reduces the need for costly
juvenile justice system processing and adjudication. Each year,
juvenile courts handle approximately 1.4 million delinquency and status
offense cases, resulting in nearly 130,000 out-of-home placements. On
any given day, approximately 90,000 juveniles are held in juvenile
detention, correctional and shelter facilities. Nationally, nearly $2
billion a year is spent operating these facilities. The average annual
cost of confining a juvenile in a training school exceeds $45,000 in
many States. The cost for intensive, private residential treatment for
a serious juvenile offender can run as high as $100,000 per year. The
cost for construction of secure facilities for juveniles is currently
about $100,000 per bed.
In order to be eligible to fully participate in the Formula Grants
Program of the JJDP Act, States must develop and adhere to policies,
practices, and laws which deinstitutionalize status offenders and
nonoffenders, separate adults and juveniles held in secure
institutions, and eliminate the practice of detaining or confining
juveniles in adult jails and lockups. In addition, States must address
efforts to reduce the disproportionate representation of minority
juveniles in secure facilities, where such condition exists. These four
goals (deinstitutionalization of status offenders, separation, jail
removal, and disproportionate minority confinement) are commonly called
the Formula Grants Program ``mandates,'' and are a major focus of
States' Federally funded efforts under the Act. In order to meet
statutory requirements for compliance, approximately 70% of the States
at one time or another have devoted 100% of all available formula grant
funds toward meeting the mandates. Thus, many States have been limited
in the amount of JJDP Act funds that could be devoted to prevention.
Title V of the JJDP Act is designed to provide a dedicated fund
source for States to award grants for delinquency prevention and early
intervention programs for local communities, provided that the
applicant unit of general local government, or combination thereof, is
in compliance with the JJDP Act mandates.
Congress has structured the Title V Delinquency Prevention Program
to support such units that have formulated a community-wide strategy to
address the prevention of delinquency. A community will be required to
have a prevention strategy based on assessment of risk factors
associated with the development of delinquent behavior in the
community's children.
Title V authorizes the Administrator of OJJDP to make grants to a
State, to be transmitted through the State Advisory Group, to units of
general local government for delinquency prevention programming. The
State agency which administers the JJDP Act Formula Grant in each State
will be eligible to apply for funding and receive an amount determined
by a formula based on the State's population of youth under the maximum
age of original juvenile court delinquency jurisdiction, with a minimum
allocation of $75,000 per State and $25,000 per Territory.
States will invite units of general local government that meet the
statutorily mandated eligibility requirements, and as further limited
by the State Advisory Group, to apply for funding. In order to be
eligible, local applicants must: (1) Be certified by the State Advisory
Group to be in compliance with the JJDP Act Formula Grants mandates;
(2) designate or convene a local Prevention Policy Board; and (3)
develop a local, comprehensive delinquency prevention plan.

Approach

Many past delinquency prevention planning and programming efforts,
while well intentioned, have been unsuccessful because of their
negative focus on attempting to prevent juveniles from misbehaving.
Another weakness of past delinquency prevention efforts is their narrow
scope, generally focussing on only one or two aspects of a child's life
such as individual behaviors or family problems. Successful delinquency
prevention strategies must be positive in their orientation and
comprehensive in their scope.
Positive approaches that emphasize opportunities for healthy
social, physical and mental development and take into account
individual, family, peer group, school, and community influences on a
child's development have been shown to have a much greater likelihood
of success.
Risk-focused delinquency prevention is a comprehensive approach
based on the premise that in order to prevent a problem from occurring,
the factors that contribute to the development of that problem must be
identified and addressed.
Research conducted over the past half century has clearly
documented five categories of risk factors for juvenile delinquency:
(1) Individual characteristics such as alienation, rebelliousness and
lack of bonding to society; (2) family influences such as parental
conflict, child abuse, poor family management practices, and family
history of problem behavior (substance abuse, criminality, teen
pregnancy, and school dropouts); (3) school experiences such as early
academic failure and lack of commitment to school; (4) peer group
influences such as friends who engage in problem behavior (minor
criminality, drugs, gangs and violence); and (5) neighborhood and
community factors such as economic deprivation, high rates of substance
abuse and crime, and neighborhood disorganization.
To counter these risk factors, protective factors must be
introduced. Protective factors are qualities or conditions that
moderate a juvenile's exposure to risk. Research indicates that
protective factors fall into three basic categories: (1) Individual
characteristics such as a resilient temperament and a positive social
orientation; (2) bonding with pro-social family members, teachers,
adults, and friends; and (3) healthy beliefs and clear standards for
behavior. While individual characteristics are difficult to change,
bonding and clear standards for behavior work together and can be
changed. To increase bonding, children must be provided with: (1)
Opportunities to contribute to their family, school, peer group and
community; (2) skills to take advantage of opportunities; and (3)
recognition for efforts to contribute.
At the same time, parents, teachers and communities need to set
clear standards regarding pro-social behavior.
A risk-focused delinquency prevention approach calls on communities
to identify the risk factors to which their children are exposed.
Risked-focused delinquency prevention provides communities with a
conceptual framework for prioritizing the risk factors in their
community, assessing how their current resources are being used,
identifying resources which are needed, and choosing specific programs
and strategies that directly address those risk factors through the
enhancement of protective factors.
This approach requires a commitment by and participation of the
entire community in developing and implementing a comprehensive
strategy. While the roles of governmental agencies in this strategy
will vary, it is essential that the citizens of the community create a
diverse and representative coalition in which public officials and
agencies are equal members with private citizens and agencies. It is
this coalition which leads the community's prevention strategy in
addressing the needs of children and their families at risk.
Another key component of this approach is the coordination and use
of existing programs and resources. A community-wide prevention
strategy must inventory available State, local, private, and Federal
resources, and develop vehicles for making these resources and programs
readily accessible to children and families in need. Thus, applicants
for Title V funds are encouraged to coordinate this prevention effort
with other Federally funded efforts.

Target Population

The Title V Delinquency Prevention Program is based on a program
design which addresses those risk factors which are known to be
associated with delinquent behavior. The program seeks to address these
factors at the earliest appropriate stage in each child's development.
The target population is all at-risk children in a given community.
Funds awarded under this program will be used to address delinquency
risk-factors in communities, and as such may be used to fund
ameliorative services for at-risk children.

Funding Structure

Title V, Section 505 of the Act, authorizes the Administrator of
OJJDP to make grants to a State, to be transmitted through the State
Advisory Group, to units of general local government.

Technical Assistance

Because the Title V Delinquency Prevention Program is based on a
risk-focused program structure, OJJDP will make training and technical
assistance on risk-focused prevention available to representatives of
units of general local government through the State agency
administering the program.

Program Goal

The goal of this program is to reduce delinquency and youth
violence by supporting communities in providing their children,
families, neighborhoods, and institutions with the knowledge, skills,
and opportunities necessary to foster a healthy and nurturing
environment which supports the growth and development of productive and
responsible citizens.

Program Objectives

The objectives of the program are:
1. To form coalitions within communities to mobilize the community
and direct delinquency prevention efforts;
2. To identify those known delinquency risk factors which are
present in communities;
3. To identify protective factors which will counteract identified
risk factors, and develop local comprehensive, delinquency prevention
plans to strengthen these protective factors;
4. To develop local comprehensive, delinquency prevention
strategies which use and coordinate Federal, State, local and private
resources for establishing a client-centered continuum of services for
at-risk children and their families;
5. To implement the delinquency prevention strategies, monitor
their progress, and modify the plans as needed.

Basic Program Design

The program will be implemented in two phases: the pre-award
planning phase and the implementation phase. Applicant units of general
local government may modify or enhance existing prevention planning
boards, plans and strategies to meet the requirements for Title V
funding.

Planning Phase

The planning phase for each local applicant will occur prior to
the award of funds and consist of the designation or formation of a
local policy board to direct the project, and the development of a
three-year delinquency prevention plan. OJJDP is making training and
technical assistance available through the State agency to interested
potential local applicants during this phase. Eligible State agencies
may apply for and receive Title V awards from OJJDP based on this final
Title V Guideline.

Implementation Phase

The implementation phase will begin with the award of subgrants to
units of general local government. Technical assistance will continue
to be available to grantees.

Funding Structure and Grantee Qualifications

Title V authorizes the Administrator of OJJDP to make grants to
States to be transmitted through the State Advisory Groups to qualified
units of general local government or combinations thereof. The State
Advisory Group is the board appointed by the chief executive officer of
the State, as provided by Section 223(a)(3) of the Act (Section 503). A
unit of general local government means any city, county, town, borough,
parish, village, or other general purpose political subdivision of a
State, and any Indian tribe which performs law enforcement functions as
determined by the Secretary of the Interior. . . (Section 103(8)).
OJJDP will award grants to States based on a formula determined by
each State's relative population of youth below the maximum age limit
for original juvenile court delinquency jurisdiction. The States will
subgrant the funds to qualified units of general local government based
on a competitive process. Jurisdictions that do not have discrete units
of general local government may award funds directly to governmental
agencies or private nonprofit organizations to implement projects in
furtherance of the jurisdiction's own comprehensive prevention
strategy.
All Title V funds must be matched by recipient units of general
local government or by the State with 50% of the amount of the grant.
This match may be provided in cash or the value of in-kind
contributions or services. States are encouraged to supplement Title V
funds with Formula Grant funds. However, Formula Grant funds cannot be
used as match for Title V funds.

State Grantee Qualifications

Each State, as defined in Section 103(7) of the Act, is eligible to
apply for Title V funds, provided that it has a State agency designated
by the chief executive under Section 299(c) of the Act, and a State
Advisory Group appointed pursuant to Section 223(a)(3) of the Act. The
applicant State agency must provide an assurance that the State
Advisory Group has or will have the sole authority, consistent with
State law or policy, to approve or recommend approval of Title V
subgrants to units of general local government, pursuant to the
provisions of this program guideline.

Local Subgrantee Qualifications

In order for a unit of general local government to be eligible to
apply for Title V funds, such unit, or each unit applying in
combination, must be certified by the State Advisory Group as in
compliance with Sections 223(a)(12)(A), 223(a)(13), 223(a)(14), and
233(a)(23) of the JJDP Act. If a State is not currently in full
compliance with any of the first three of these mandates, i.e. the
quantifiable mandates, or is in full compliance with de minimis
exceptions, only those units of general local government which are
within the de minimis parameters provided in 28 CFR 31.303(f)(6)(i) and
(f)(6)(iii)(A), based on the locality's most current census data, may
be deemed in compliance with the mandates of Sections 223(a)(12)(A),
(13), and (14).
In order to be in compliance with Section 223(a)(23), the State
Advisory Group must certify that the unit of general local government
is cooperating in data gathering and analysis to determine if
disproportionate minority confinement exists, or if it is known to
exist within the boundaries or jurisdiction of the unit of general
local government, the unit has made or is making an adequate effort
toward addressing, or assisting the State to address, this issue.
The State Advisory Group will competitively award, or recommend for
award, Title V grants to units of general local government based on how
well competing units meet the competitive criteria set forth below
under Priority Consideration for Funding. State Advisory Groups may not
arbitrarily exclude an eligible unit of general local government from
competing for Title V funds.

Application Process--Eligible State Agencies

All State agencies designated by the chief executive under Section
299(c) of the Act are eligible to apply for Title V funds. A list of
these agencies and the allocations of funds to the State for a
particular fiscal year may be obtained from OJJDP.

Application Requirements for State Agencies

State agencies must provide evidence of the State Advisory Group's
authority to approve the award of Title V subgrants or, where a
separate supervisory board is vested with such authority, to review and
recommend approval to the board. No Title V subgrants can be made to a
unit of general local government absent the approval or recommendation
of the State Advisory Group. Examples of such authority would be an
executive order, a statute, a formal resolution of the State Advisory
Group, a formal resolution of the supervisory board which the State
Advisory Group advises, or a written agreement between the State agency
and the State Advisory Group.
The application must also include an assurance that the State
Advisory Group and the State agency will establish written subgrantee
eligibility criteria, described above under Local Subgrantee
Qualifications, and competitive criteria based on the criteria
described below under Priority Consideration for Funding. The State may
issue additional criteria, including criteria designed to focus
delinquency prevention efforts toward those areas of the State
displaying the greatest need of comprehensive delinquency prevention
planning and programs.
Furthermore, the application must provide the following
administrative assurances:
1. To report on all subgrant awards, within thirty days of award,
on the OJJDP form, ``Individual Project Report, Part I: Initial Report
of Funding'';
2. To monitor and assure the audit of subgrants for performance,
outcome and fiscal integrity, including cash and in-kind match, as
specified in the current edition of the Office of Justice Programs
Guideline Manual M-7100, ``Financial and Administrative Guide for
Grants'';
3. To collect quarterly progress and data reports, and forward
semi-annual summary reports to OJJDP.
The application must include a time-task plan providing a
description of the major tasks which the State will employ to implement
the Title V program, and the timeframes for completing each of those
tasks.
All awards will be conditioned with additional requirements which
are standard for recipients of Federal grants.
State agencies which demonstrate a need to do so in their
applications to OJJDP, may use up to 5% of the State's Title V
allocation for the costs of administering the Title V subgrants and
support for State Advisory Group activities related to Title V. A
budget narrative must explain how the administrative funds will be
spent, including provision of the required match by the State.

State Application Deadline

State applications are due to OJJDP not later than 60 days after
the effective date of this guideline.
Technical Assistance Role of State Agency and State Advisory Group:
In their capacities as the primary planning vehicles for juvenile
justice and delinquency prevention programs within the State, the State
agency and the State Advisory Group are encouraged to assume a role as
a technical assistance resource for local subgrantees, as well as
serving as a resource and information clearinghouse for all prevention
activities in the State. The data and strategies developed on the local
level should be incorporated in the State Advisory Group's and State
agency's statewide, comprehensive planning efforts, as required by
Section 223 of the Act. To this end, State agencies and State Advisory
Groups are strongly encouraged to participate in risk-focused
prevention training and technical assistance made available by OJJDP.

Process for Subgrant Award and Administration

State agency grantees shall use essentially the same process for
making Title V subawards as that used for Formula Grant awards, with
the State Advisory Group establishing applicant eligibility criteria to
target specific types of communities, if needed, and making or
recommending the final decision on funding of individual applications.
This includes the Request for Proposals, competitive review of
applications, and award of subgrants. Likewise, State agencies will
monitor Title V subgrants in a similar manner as the Formula Grant
subgrants, including the collection and reporting of data required by
this program guideline.
In considering applications for awards, State Advisory Groups
should be sensitive to the unique needs of rural areas and Native
American tribes, including provision of special consideration in the
competitive process.
All subgrants should be awarded within 180 days after receipt of
the award from OJJDP.

Application Process for Units of General Local Government

1. Pre-application Certification of JJDP Act Compliance

Units of general local government must obtain a certification of
compliance from the State Advisory Group prior to applying for an award
of funds.

2. Delinquency Prevention Training

OJJDP is making training in risk-focused prevention available to 45
sites across the nation during fiscal year 1994. The only cost
associated with this training for participants will be transportation
and lodging, if necessary. Facilities for the training will be provided
by the States or localities. Training is designed to assist communities
in preparing the three year plans required for Title V funding. The
initial training will consist of a one day introduction to the theories
and strategies of risk-focused prevention planning. Units of general
local government considering applying for Title V funding are strongly
urged to take advantage of this training opportunity and send key
community leaders to the initial training. A subsequent three day
workshop will be held for planning teams from local Prevention Policy
Boards to complete a risk and resource assessment. OJJDP has advised
the State agencies on the process for units of general local government
to participate in this training.

3. Local Three-Year Delinquency Prevention Plan

Each unit of general local government's application to the State
agency must include a three-year plan describing the extent of risk
factors identified in the community and how these risk factors will be
addressed. A written explanation of the risk factors and protective
factors can be obtained from the State agency grantee. The plan must,
at a minimum, contain the following elements:
a. The designation or formation of a local Prevention Policy Board
(PPB) consisting of no fewer than 15 and no more than 21 members from
the community, representing a balance of public agencies, private
nonprofit organizations serving children, youth, and families, and
business and industry. Such agencies and organizations may include
education, health and mental health, juvenile justice, child welfare,
employment, parent, family, and youth associations, law enforcement,
religion, recreation, child protective services, public defenders,
prosecutors, and private manufacturing and service sectors. The
applicant should also assure that the PPB, to the extent possible,
contains one or more members under the age of twenty-one, one or more
parents or guardians with children who have had contact or are at risk
of having contact with the juvenile justice system, and an overall
membership that generally reflects the racial, ethnic, and cultural
composition of the community's youth population. A specific local
agency or entity must have responsibility for support of the PPB;
b. Evidence of commitment of key community leaders to supporting a
comprehensive, delinquency prevention effort. Key leaders may include
public and private individuals in key leadership and policy positions
who are instrumental in effecting policy changes, controlling
resources, and mobilizing the community;
c. Definition of the boundaries of the program's neighborhood or
community;
d. An assessment of the readiness of the community or neighborhood
to adopt a comprehensive delinquency prevention strategy;
e. An assessment of the prevalence of specific, identified
delinquency risk factors in the community, including the establishment
of baseline data for the risk factors. The assessment of risk factors
must result in a list of priority risk factors to be addressed, as
determined and approved by the PPB;
f. Identification of available resources and promising approaches,
including Federal, State, local, and private, and a description of how
they address identified risk factors, and an assessment of gaps in
needed resources and a description of how to address them;
g. A strategy, including goals, objectives, and a timetable, for
mobilizing the community to assume responsibility for delinquency
prevention. This should include ways of involving the private nonprofit
and business sectors in delinquency prevention activities;
h. A strategy, including goals, objectives, and a timetable, for
obtaining and coordinating identified resources which will implement
the promising approaches that address the priority risk factors. This
strategy must include a plan for the coordination of services for at-
risk youth and their families;
i. A description of how awarded funds and matching resources will
be used to accomplish stated goals and objectives by purchasing of
services and goods and leveraging other resources. This should include
a budget which lists planned expenditures;
j. A description of how the PPB will provide general oversight for
developing the plan, approve the plan prior to submission to the State,
and make recommendations to the responsible local agency for the
distribution of funds and evaluation of funded activities;
k. A plan for collecting data for the measurement of performance
and outcome of project activities.

Priority Consideration for Funding

Only local government applicants certified by the State Advisory
Group as in compliance with the mandates of the Act, that have convened
a PPB, and have submitted a three year plan will be eligible for
funding. In considering applications for funding, State Advisory Groups
will give priority to eligible applicants which:
a. Provide a thorough assessment of risk factors and resources,
including the quantified measurement of the risk factors which will
serve as the baseline for determining project performance and outcome;
b. Identify key community leaders and members of the PPB, describe
their roles in the comprehensive delinquency prevention strategy, and
provide evidence of key community leaders support;
c. Clearly define the boundaries of the program's neighborhood or
community;
d. Provide a realistic assessment, including evidence, of the
readiness of the community or neighborhood to adopt a comprehensive
delinquency prevention strategy;
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;
f. Provide specific strategies for service and agency coordination,
including collocation of services at sites readily accessible to
children and families in need;
g. Provide a strategy for or evidence of collaborating with other
units of local of government and State agencies to develop or enhance a
statewide subsidy program to local governments that is dedicated to
early intervention and delinquency prevention;
h. Provide a budget outlining the planned expenditures of grant
funds and matching resources, including a budget narrative justifying
these expenditures;
i. Provide a sound plan for collecting data for measuring
performance and outcome;
j. Provide written statements of commitment from State or local
public agencies to match in cash or kind, at least 50% of the funds
awarded.

Local Application Deadline

The State Advisory Group will determine the application deadline.
However, all local subgrant awards should be made within 180 days after
the date that the State agency was awarded Title V funds.

Local Grant Administrative Requirements

After receipt of the award, local grantees will provide all
required reports and data to the State agency, describing
implementation of the program. Technical assistance for program
implementation will be available upon request through the State agency.

Evaluation

OJJDP will collect and analyze data collected by each grantee for
the purpose of developing national summary reports on the performance
and outcome of the local prevention efforts. This evaluation will
examine performance in meeting stated objectives as well as the outcome
of the project's activities. In order for this evaluation to be
meaningful, it is essential that, to the greatest extent possible, the
local three year comprehensive delinquency prevention plans contain
quantified objectives and baseline measurements of the identified risk
factors.

Allocation of Title V Funds to States

The Title V Delinquency Prevention Program has a F.Y. 1994
appropriation of $13 million available for awards to States to support
programs of units of general local government. Allocations are
available to States based on the number of juveniles in the State who
are subject to original juvenile court delinquency jurisdiction based
on State law, with a minimum allocation of $75,000 for States and the
District of Columbia and $25,000 for Territories and Possessions. A
list of the allocations for States is available from OJJDP. The
allocations for States not participating in this program in F.Y. 1994,
or subsequent years, will be withheld for use in F.Y. 1995, or
subsequent years, pursuant to the Title V Delinquency Prevention
Program guidelines issued for that year.

Size of Awards to Units of General Local Government

The size of the award to each unit of general local government, or
combination thereof, and the total number of awards will be determined
by the State Advisory Group, based upon the amount of funds allocated
to the State and the quality of the local three-year prevention plans.

Duration of Grants and Continuation Funding

OJJDP will award grants to States for a project period beginning on
the date of award and ending on September 30, 1996. States will award
grants to units of general local government in annual increments
covering not more than 12 months each, with overall project periods of
12 to 36 months. Subsequent years' funding will be contingent upon
satisfactory performance and the availability of funds. Future funding
is dependent upon Congressional action.
Restrictions on Uses of Funds: Title V funds cannot be used for
construction, land acquisition, or supplantation of Federal, State, or
local funds supporting existing programs or activities.

Responses to Public Comments

Twenty-seven comments to the proposed guideline were received. A
summary of the comments and OJJDP's responses follow. In many
instances, the summary comments listed below incorporate specific
comments from more than one respondent.
Comment. The guideline appears to focus on risk factors and
reducing delinquency without providing adequate emphasis to protective
factors and positive youth outcomes. A prevention approach which is
protection focused or risk and protection focused seems more in line
with OJJDP's strategy.
Response. The structure of the Title V program is based on
identifying risk factors that can lead to the development of
delinquency and violence in children and youth, and developing
strategies to eliminate or ameliorate the risk factors. A key component
of this strategy is to provide the protective factors which serve to
buffer children and youth from the damaging effects of risk factors.
To better express this strategy, the Title V program will be
referred to as a risk and protection focused strategy.
Comment. The guideline should refer to children and youth, and
emphasis should go to youth eleven years and older, since this
population most often lacks positive alternatives in their communities.
What age is the program targeting? Would programs for parenting
skills and early infant bonding be appropriate? The program needs to
place more emphasis on parental responsibility and skills training.
Response. The guideline states that ``the program seeks to address
these (risk) factors at the earliest appropriate stage in each child's
development.'' The Title V program is structured to accommodate what
each individual community has identified as the best strategy to reduce
risk factors and increase protective factors. For some communities this
may require emphasizing the ages of zero to three, for others it may
mean eleven years and older, and in others it may require a focus on
adolescents.
Comment. The clear thrust of the proposed guideline is toward
primary prevention. Given the increasing emphasis on primary and
secondary prevention in funding proposals now before Congress, OJJDP
should make clear in the final guideline that in communities where the
greatest need is for tertiary program, those communities are also
encouraged to apply for these funds.
Response. OJJDP formulated the Title V program based on a risk and
protection focused strategy. This decision was based on OJJDP's
research and demonstration program experience, as well as the
provisions of Title V. While the risk and protection focused strategy
stresses secondary prevention, the comprehensive planning process
employed by communities may also yield tertiary and primary prevention
programs.
The three levels of prevention (primary, secondary, and tertiary)
usually overlap to some degree, especially in a risk and protection
focused strategy such as that employed in the Title V program. The risk
and protection focus of the strategy analyzes and addresses the root
causes of problem behavior and violence which can affect all children
(primary prevention), including those who have been identified as at-
risk (secondary prevention), and those who have committed offenses and
have been referred to the juvenile justice system (tertiary
prevention).
Section 505(a) under Title V states that grants may be used for
``delinquency prevention programs and activities for youth who have had
or are likely to have contact with the juvenile justice system,
including the provision to children, youth and families of: (1)
Recreation services; (2) tutoring and remedial education; (3)
assistance in the development of work skills; (4) child and adolescent
health and mental health services; (5) alcohol and substance abuse
prevention services; (6) leadership development activities; and (7) the
teaching that people are and should be held accountable for their
actions.'' Information and technical assistance on these and other
prevention programs and strategies are available from OJJDP.
Comment. Gender-specific services should be part of every
community's comprehensive strategy.
Response. Through the risk and resource assessment, each community
will have an opportunity to analyze service gaps and address those gaps
with programs and strategies which have had positive or promising
results. OJJDP is making technical assistance and training available to
States and localities who would like to enhance their assessment skills
in analyzing service gaps.
Comment. The guideline should list attention deficit disorder and
lack of support for parents with children with disabilities as risk
factors.
Response. The risk factors cited in the training that OJJDP is
providing for potential Title V applicants includes three school
related factors: Early and Persistent Antisocial Behavior, Academic
Failure in Elementary School, and Lack of Commitment to School.
Learning disabilities can be related to each of these risk factors.
Comment. A sixth program objective should be added which focuses on
methodology. This would provide a basis for improving professional
practice within and among the organizations working with youth.
Response. Although the guideline does not require a specific
methodology for planning or programming, it does provide general
guidance on methodology along the lines of a risk and protection
focused strategy. The training and technical assistance that is
available through OJJDP provides a means of improving professional
practice.
Comment. Will private non-profit agencies have difficulty in being
subgranted funds if a local unit of government does not wish to apply
but does wish to participate?
Response. Section 505(a) under Title V of the Juvenile Justice and
Delinquency Prevention Act (JJDP Act) authorizes the Administrator to
``make grants to a State, to be transmitted through the State Advisory
Group, to units of general local government * * *'' The only means by
which private non-profit organizations can receive Title V funds would
be through service contracts with units of general local government.
Comment. Are school districts eligible to apply for Title V funds?
Response. Section 503 of the JJDP Act provides for only units of
general local government to be the applicants for Title V funds. A
school district is not a unit of general local government.
The proposed guideline did not consistently use the term ``unit of
general local government.'' The final guideline is amended to use this
term consistently.
Comment. The guideline appears to grant sole authority to award
grants to the State Advisory Group. How will the awards be made if
State statute does not grant the State Advisory Group such authority?
If the Governor signs the grant, must the State Advisory Group approve
the award?
Response. The guideline, under ``State Grantee Qualifications,''
has been revised to require the State agency applicant to provide an
assurance that the State Advisory Group has the sole authority,
consistent with State law or policy, to approve or recommend the award
of Title V subgrants.
Comment. Can private not-for-profit organizations participate in
public-private partnerships with operational prevention coalitions?
Response. Under the Title V program, a unit of general local
government could vest a public-private organization with significant
responsibility for implementation of the program. However, the local
government would still be responsible to the State for administering
any Title V funds.
Comment. Municipalities with populations in excess of 3 million
should be eligible to receive grants directly from OJJDP.
Response. Section 505 of the JJDP Act authorizes the Administrator
to ``make grants to a State, to be transmitted through the State
Advisory Group to units of general local government.''
Comment. The formula for allocating funds to States should be
amended to include all youth up to 18 years of age, regardless of the
maximum age of original juvenile court delinquency jurisdiction.
Response. Because a community can only prevent delinquency in a
juvenile who is subject to a juvenile court's delinquency jurisdiction,
the most logical and appropriate means for allocating Title V funds is
to use a formula determined by each State's relative population of
youth below the age limit for original juvenile court delinquency
jurisdiction.
Comment. Regional plans for Title V should be permitted.
Response. The guideline allows for combinations of units of general
local government to apply for Title V funds. However, the regional plan
which is the product by such a regional collaboration must define the
boundaries of the target neighborhoods or communities.
Comment. States will be implementing the Title V program using
varying timetables and strategies. OJJDP should require the States'
applications to include a time-task plan.
Response. This requirement has been added Under ``Application
Requirements for State Agencies,'' in the guideline.
Comment. Four respondents indicated that the match requirement was
too onerous for small communities and private nonprofit organizations.
The respondents recommended that a reduced level of match be allowed.
Response. Title V requires that ``the unit or State has agreed to
provide a 50% match of the amount of the grant, including the value of
in-kind contributions, to fund the activity.'' (Section 505(b)(7)).
This provision provides some flexibility in the match requirement.
First, the match, which is 50 cents on the dollar, has to be made for
every dollar granted to the local level. However, the State can provide
a portion of the funding through State program dollars. Second, the
match can be made in cash or in-kind. In-kind match is discussed in a
separate response.
It should be noted that the Title V provision does not require a
match from any agency other than the State or the unit of general local
government. It is the responsibility of the unit of general local
government to provide the match, not nonprofit service providers.
Comment. Two respondents recommended that in certain instances, the
match requirement should exclude in-kind match and require a cash match
only.
Response. Congress intended the in-kind match provision to allow
flexibility in providing local resources. Although the in-kind match
provision may require more diligence on the part of the State in
assuring that the match requirement is met, the State cannot restrict
the match to cash because this is a benefit provided to local
recipients by statute.
Comment. The guideline should require that local applications
provide formal interagency agreements which promote ``contractual''
agreements vs. ``intentional'' agreements.
Response. The guideline allows for statements of commitment in
order to give the State flexibility in determining what form those
statements of commitment should take. Given the timeframes for the
planning process in the guideline, it may not be possible for a
locality to obtain formal interagency agreements prior to submission of
the plan.
Comment. Can the State Advisory Group limit the availability of
funds to a specific local government or a specific set of risk factors?
Response. The State Advisory Group and State agency may issue
funding guidelines which focus available funds on areas with the
greatest need. If a State chooses this approach, the award of funds is
to still be determined through a competitive process that solicits
proposals from areas which meet criteria established by the State
Advisory Group. It is possible that these criteria may result in a
limited number of units of general local government being eligible to
apply.
In targeting communities with particular needs for purposes of
soliciting proposals, the State Advisory Group may include specific
risk factors in the targeting criteria. However, applicants must still
analyze the incidence of all risk factors in their local comprehensive
plans.
The State Advisory Group and the State agency may not limit the
competition based solely on criteria which are not related to juvenile
crime or other indications of need. For example, the State Advisory
Group may not limit competition to particular communities based solely
on population size. To do so would result in the arbitrary exclusion of
communities from competition in the Title V program. The guideline is
revised under ``Local Subgrantee Qualifications'' to reflect this
requirement.
Comment. The timeframes allowed in the guideline for the
development of local comprehensive plans are too restrictive,
especially if a locality does not have any available planning
resources. What happens if a local applicant cannot meet the 180 day
deadline? OJJDP should allow States to award the first and second year
of Title V funds through one RFP process after the new Federal fiscal
year.
Response. The guideline states that ``all subgrant awards should be
made within 180 days after receipt of the award from OJJDP.'' OJJDP
intends this 180 day timeframe to serve as a target date, particularly
in States where localities are developing their Title V prevention
plans on a base previously established through other risk-focused
prevention planning efforts. OJJDP recognizes that some States and
localities are new to prevention planning, and more time will be
required to develop comprehensive three year plans. OJJDP is providing
technical assistance and training to States and localities to enhance
their ability to implement the Title V program in the most expeditious
manner possible without sacrificing quality.
Comment. The guideline suggests that Title V funds should be used
in conjunction with the JJDP Act Formula Grant funds. The time frame
for these two planning cycles do not coincide.
Response. Title V requires three year local plans and the Formula
Grant requires three year State plans. OJJDP encourages the State
Advisory Groups and State agencies to develop a mechanism whereby the
local plans can be integrated in the State plan.
The proposed guideline, under ``Duration of Grants and Continuation
Funding'' has been revised to more accurately describe the grant award
process by providing that ``OJJDP will award grants to States for a
project period beginning on the date of award and ending on September
30, 1996. States will award grants to units of general local government
in annual increments covering not more than 12 months each, with
overall project periods of 12 to 36 months.''
Comment. Will Title V funds be available in to States in future
years?
Response. OJJDP will make future years' Title V funds available to
States and localities through the process described in the guideline,
pending satisfactory performance and availability of funds. OJJDP will
determine satisfactory performance of State grantees and the States
will determine satisfactory performance of local grantees.
Comment. The Title V program should be coordinated with other
similar Federal programs, such as the Family Preservation Act.
The guideline should require local applicants to document
collaboration with other Federal programs.
Response. OJJDP strongly encourages coordination with other
Federal, State and local programs. OJJDP is working with the U.S.
Department of Health and Human Services to establish mechanisms to
facilitate coordination with the Family Preservation and Support
Services provision and other programs which use a community coalition
planning approach to prevention. In addition, OJJDP will provide
technical assistance and training to States and localities on accessing
and collaborating with other Federal programs.
The guideline indicates that a ``key component of the prevention
approach is the coordination and use of existing resources.'' The
guideline encourages applicants to coordinate this effort with other
Federally funded programs.
Comment. Who signs the local application? The highest elected local
official?
Response. The local application may be signed by any official
authorized to do so by the applicant unit of general local government.
Comment. Can a county, and municipalities within a county, both be
eligible to apply?
Response. Yes, provided that funding is contingent upon
coordination of the respective plans.
Comment. Can Title II, Part B Formula Grant funds be used to help
localities develop local plans?
Response. Yes. The use of Formula Grant program funds for the
development of local delinquency prevention plans is a permissible
expenditure of these funds.
Comment. What if a local plan is missing one of the required
elements?
Response. The local plan must contain all the required elements
listed in the guideline before the locality can receive Title V funds.
Comment. It is not clear whether the funds can be used for service
delivery or planning.
Response. Title V funds are used for service delivery.
Comment. The guideline refers to the ``Communities that Care''
model of risk-focused prevention. Can grant recipients employ other
risk-focused prevention models?
Response. Yes. Localities may base their three year plan and
strategy on other delinquency prevention models, provided that they are
based on a risk and protection focused model that uses: (1) The
analysis of risk factors which are grounded in sound theory and
positive research results, and (2) protective factors which have a
sound theoretical basis and positive or promising research results.
OJJDP is offering training and TA on risk and protection focused
prevention which permits States and localities to use any risk and
protection focused model.
Comment. We interpret the Title V audit requirements to be
different than that of an A-128 audit.
Response. The provisions of OMB Circulars A-128 and A-133 apply to
Title V funds.
Comment. The guideline indicates project periods for local grants
of 12 to 36 months. It may be beneficial to allow for up to a 60 month
project period to facilitate the measurement of outcomes of the
projects.
Response. Title V is designed as a long term program. Based on the
experience of communities that are implementing prevention programs of
similar design, we anticipate that three to five years is not an
unreasonable time to expect a community coalition, such as the Title V
Prevention Policy Board, to establish itself as a viable organization
with the influence necessary to help effect system change.
In the proposed guideline, OJJDP has provided a 12-36 month
timeframe to provide flexibility for accommodating a wide range of
community planning and coalition building experience by local Title V
grant recipients. Some communities may only need a one year period to
augment on-going risk focused prevention activities. For other
communities, this may be their first attempt at this type of
comprehensive prevention planning and programs. In addition, this
timeframe will facilitate integrating the planning for Title V with
that of the Formula Grants program.
In general, the use of Title V funds is intended to provide an
incentive to plan and implement delinquency prevention programs at the
local level. States may wish to provide competitive Title II funding
for local prevention programs following Title V funding, and local
grantees can seek funds for expansion from a range of State, Federal,
and foundation sources.
The guideline requires the collection of performance and outcome
data. OJJDP encourages States and local grantees to continue collecting
this data for their prevention programs to measure outcomes beyond the
period of Title V funding. OJJDP is also planning to continue
collecting and analyzing data for selected jurisdictions through an on-
going national evaluation of Title V.
Comment. Funding formulas have favored urban over suburban
communities. The opportunity for equal programming throughout the State
would be most desirable or at least a funding formula created that
allows suburban communities to compete with like communities.
Response. Under the guideline, States have the discretion to target
those communities in the State with the greatest need. The judgment the
State Advisory Group can best determine whether to limit the
competition for the grants to specific, targeted communities or to
conduct a statewide competition. Given the limited amount of Title V
funds available to each State and the local competition requirements,
distribution of funds based on a population formula would not be
feasible. The State Advisory Group and State agency could, however,
conduct competitions among applicants of specific types of geographic
areas (urban, suburban, rural).
Comment. The guidelines should specifically prohibit or discourage
the withdrawal of community funds from agencies to provide the match
for Title V programs, especially in cases where collaborative efforts
between agencies and government would serve the same purpose and
clients.
Response. The guideline prohibits using Title V funds to supplant
Federal, State, or local funds supporting existing programs. The
guideline encourages collaboration of agencies and services. The
planning process for Title V is designed to produce a more effective,
efficient and responsive service system for children, youth and
families. The locality can best determine how to design, coordinate,
and fund programs to achieve this outcome, provided that the Title V
funds are not used to replace funds for existing programs.
Comment. The guideline requires a great deal of local planning
before localities can become eligible for funding. This provides little
incentive for many units of general local government to engage in such
efforts without a strong probability of being funded.
In order to reduce the burden on the local communities, a process
for awards should be employed wherein communities first apply to the
State Advisory Group, and then develop their plans after there is a
much greater chance of being funded.
Another option would be for OJJDP to mandate that localities should
build upon existing plans, where they exist.
Response. During the initial implementation of the Title V program,
some localities will have the experience to initiate and develop a
three year plan in a short timeframe. In order to establish effectively
operating programs during this first year, State Advisory Groups may
want to consider giving priority to applicant communities that have the
capacity to develop strong plans. For instance, a State Advisory Group
may target communities that already have planning boards involved in
broad-based prevention planning.
OJJDP encourages localities to build upon existing prevention plans
which are based on a risk and protection factor approach.
Comment. OJJDP should encourage or mandate that whenever possible,
localities must designate existing coalitions or boards, with
prevention responsibilities similar to those required by Title V, as
the Prevention Policy Board.
It may be difficult to convene a representative Prevention Policy
Board of not more than 21 members. Can the Prevention Policy Board
exceed 21 members?
Response. The guideline requires the local applicants to designate
or form a Prevention Policy Board. OJJDP encourages the use of existing
similar boards to meet the Title V requirements. This would facilitate
coordination of funding sources and collaboration among agencies and
governments.
Title V expressly requires that the board membership consist of not
less than 15 and not more than 21 members. Localities may convene
boards of more than 21 members for broad-based prevention planning, but
recommendations and other actions regarding the Title V three year plan
and funds can only be made by a specified board (or committee of a
larger board) comprised of 15 to 21 members.
Comment. Six respondents indicated that specified groups of people
need to be represented on Prevention Policy Boards including youth,
families with or parents of children in the system or at risk
(consumers of prevention services), and members that reflect the
racial, ethnic and gender composition of the community's youth
population.
Response. The additional representation described by these six
respondents furthers the goal of having representative local boards.
However, overly prescriptive Board requirements reduce local
flexibility, particularly in the use of existing planning bodies.
Therefore, OJJDP has modified the guideline to encourage the inclusion
of these interests on the Prevention Policy Boards, to the maximum
extent possible.
Comment. Youth development organizations should be included in the
planning process and considered as a primary existing resource for
prevention services--they have extensive experience in primary
prevention programs.
Response. All human services agencies that in any way deal with
children, youth, and families, including youth development
organizations, should be involved in the planning process and
considered as resources to assist in implementation of the local
prevention plan. Technical assistance to States and localities is
available through OJJDP to help in identifying and accessing prevention
resources, including youth development organizations.
Comment. Can a Prevention Policy Board consisting of a private
nonprofit organization and a local government apply for grant funds? If
allowable, must the local government administer the funds?
Response. Prevention Policy Boards are not eligible to apply for a
Title V grants from the States. Only units of general local government
are eligible.
A private nonprofit organization and a unit of general local
government could enter into a partnership to implement the Title V
program, provided that the unit of general local government is the
applicant and all Federal fund administrative requirements are met.
Comment. The exact duties of the Prevention Policy Board are not
clear. The Board should be charged with the development of the local
prevention plan.
Response. One purpose of the Board is to provide a vehicle for
community commitment to and involvement in making the community a
healthy place for the development of children and youth. Involving the
Board in the development of the plan is one way of gaining that
commitment and involvement.
The guideline has been amended to require a description of how the
Prevention Policy Board will provide general oversight for developing
the plan, approve the plan prior to submission to the State, and make
recommendations to the responsible local agency for the distribution of
funds and evaluation of funded activities.
Each Prevention Policy Board is encouraged to develop by-laws in
concert with the responsible local agency to define its duties and how
it will operate. Technical assistance is available through OJJDP for
Board development.
Comment. The Prevention Policy Board should be charged with the
mission of producing positive outcomes for youth, not just delinquency
prevention.
Response. OJJDP is promoting risk and protection focused
delinquency prevention as a promising strategy for the Prevention
Policy Board to use in addressing the complex and varied sources of
delinquent behavior in children and producing positive outcomes for
youth.
Comment. Will OJJDP provide application kits for States?
Response. A sample State application is available from OJJDP.
Comment. The training on risk focused prevention is an excellent
idea. However, given the limited resources available to localities to
travel to the training, the training should be targeted on the
localities which have been selected to receive grants. Also, a training
for trainers would develop in-state capacity to deliver training in a
more cost-effective manner. The use of teleconference training should
also be considered.
Response. The purpose of the training is to introduce key community
leaders to risk and protection focused prevention, and enhance the
localities knowledge and skills in prevention planning. Planning must
occur before grants are awarded.
OJJDP hopes to provide training for State training teams in fiscal
year 1995. OJJDP is also examining the use of teleconferencing as a
vehicle for the more efficient delivery of training.
Comment. OJJDP should take an aggressive stance on the delivery of
technical assistance.
Response. OJJDP is developing a capacity, through its Part B
technical assistance contract, to provide technical assistance to every
community which is developing or implementing a delinquency prevention
plan.
Comment. What is the role of the State Advisory Groups in
implementing the Title V program?
Response. The role of the State Advisory Group is to establish
program eligibility criteria, establish procedures for submission and
review of local applications, and approve or recommend approval of
Title V subgrant awards.
Comment. OJJDP should provide examples of prevention plans which
meet the OJJDP requirements.
Response. OJJDP is making resource material on prevention,
including sample plans, available through the Juvenile Justice
Clearinghouse, 1600 Research Boulevard, Rockville, MD 20850, Telephone
(800) 638-8736.
Comment. If a prevention project serves a specific service
catchment area within the boundaries of a unit of general local
government, is the compliance certification limited only to the
catchment area or the entire area within the boundaries of the unit of
general local government? Is certification limited to only those
facilities operated by the local government, exclusive of facilities
located within the boundaries of the local government but operated by
other governments?
Response. In order to be eligible to receive Title V funds, a unit
of general local government must be certified by the State Advisory
Group as in compliance with the JJDP Act mandates. The compliance
certification applies to all facilities operated or contracted by the
unit of general local government. The certification is not limited to a
specific catchment area within the boundaries of the unit of general
local government. Likewise, the certification must also include any
facilities that the unit of general local government operates,
contracts for, or uses inside or outside its boundaries. However, 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.
Comment. Compliance with the Disproportionate Minority Confinement
mandate is difficult to assess since it is just beginning to unfold in
many jurisdictions.
The guidelines need to specify how the State Advisory Group's
should certify unit of general local government compliance with the
Disproportionate Minority Confinement where the Phase II Study has yet
to be completed.
Response. The inclusion in Title V of the provision requiring local
compliance with the mandates reflects an intent to use Title V funds as
an inducement to bring localities into compliance. The State Advisory
Groups and the State agencies should use this provision to gain the
cooperation and commitment of units of general local government to
assess and address disproportionate minority confinement. To certify a
unit of general local government on disproportionate minority
confinement compliance, the State Advisory Group must determine that
the level of cooperation and commitment is satisfactory to support
efforts to achieve the goals of the disproportionate minority
confinement provision.
Comment. The certification of compliance with the mandates should
occur at the time the subgrantee application is submitted.
Response. The guideline requires that units of general local
government must obtain a certification prior to applying for an award
of funds. This requirement is intended to eliminate a local government
developing a three year comprehensive plan as the basis for an
application for a grant which the locality is ineligible to receive.
Comment. In States where the compliance monitoring data is
generated by county-wide reporting, the State Advisory Groups should be
allowed to certify a city's compliance based on the overall compliance
status of the county.
Response. Section 505 of the JJDP Act requires that in order for a
unit of general local government to be eligible to receive a grant of
Title V funds, the unit must be ``in compliance with the requirements
of part B of Title II.'' OJJDP has interpreted this to mean that the
unit of general local government which is seeking eligibility to apply
for an award of Title V funds must be in compliance with the four
``mandates'' of part B of Title II. Thus, a city's eligibility must be
determined by the compliance data relevant to that city.
Comment. The language under the heading ``Local Subgrantee
Qualifications'' is unclear. It appears to say that all units of
general local government must be certified by the State Advisory Group
to be in compliance with the mandates of the JJDP Act.
Response. The guideline does not require the State Advisory Group
to certify all units of general local government, only those that wish
to apply for Title V funds.
Comment. Is it up to each State to define ``at-risk?''
Response. The guideline states that ``the target population is all
at-risk children in a given community.'' The Title V program is based
on analyzing and addressing research-based risk factors which are
identified in target communities. All children and youth who are
exposed to these identified risk factors are the target population. In
many cases, this would mean all children and youth in a target
community would be considered at-risk.
Comment. Define in-kind match, and identify what type of in-kind
match is allowed.
Response. In-kind match is determined by the value of goods and
services received and used in the program that do not have a money cost
to the grantee. In-kind match may be provided by the grantee or donated
by a third party, such as a volunteer or a public or private agency.
For example, the value of the time donated by a recreational counselor
who is not an employee of the grantee could be counted as in-kind
match. Likewise, the value of office space or equipment donated by a
private corporation could also be counted as in-kind match. Note that
the value of the time of an employee of the grantee who is not being
compensated by grant funds, but is providing service to the project
funded by the grant, would be counted as cash match.
John J. Wilson,
Acting Administrator, Office of Juvenile Justice and Delinquency
Prevention.
[FR Doc. 94-18650 Filed 7-29-94; 8:45 am]
BILLING CODE 4410-18-P

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A94-18650. Public record. Not legal advice.