VI. Personnel Policies and Procedures
Agency records and accounting systems must include the following components for personnel approved in the project’s budget:
1. Policies and Procedures: The subrecipient must have written personnel policies and procedures that address:
· Work hours
· Holidays, vacations, sick leave, and other leave time
· Overtime pay and compensatory time: Overtime pay must be authorized in the approved budget, or prior written approval must be obtained from OCJP before any overtime is worked. One time salary supplements or bonuses, including severance provisions, may not be paid with federal and/or state funds. Personnel working for more than one project must have sufficient records to show an accurate accounting of each project which have hours recorded to them. This can usually be accomplished by having personnel keep a detailed log of their activities for each project. Time sheets must accurately reflect hours spent working in separate programs.
· Written job descriptions
· Training Received
· Supervision of Staff
· Background Checks - Agency must have a policy for background checks and adhere to the policy. At a minimum, this policy must include which agency positions require a background check and the type of check performed. Additional requirements for background check are outlined below:
Agencies must conduct a background check and screening of staff and volunteers to ensure that children and vulnerable adults are protected. Individuals in contact with children and vulnerable adults must have background check/screening information collected from the following:
o National Background Check or a private National Criminal History Check/Screening provider, and
o All background checks otherwise required by state or federal law, or required for the programs/services provided by the sub-recipient (including fingerprint background checks through the Tennessee Bureau of Investigation, if required—see below).
Individuals transporting clients must have the following information reviewed:
o Driving Record Check
o Proof of Liability Insurance
NOTE: Project officials must ensure that employees working on the grant-funded project are not receiving duplicate compensation (i.e., being paid with the grant funds while receiving a salary for the same periods from another source).
· Nepotism – All agencies must have a policy regarding conflict of interest that incorporates the following definition, from Tennessee Code Annotated § 8-31-101-107, of “relative” as it pertains to nepotism: “Relative” means a parent, foster parent, parent –in-law, child, spouse, brother, foster brother, sister, foster sister, grandparent, grandchild, son-in- law, brother-in-law, daughter-in-law, sister-in-law, or other family member who resides in the same household.
2. Personnel Costs: Time and Attendance Records – Accurate time and attendance records are required to be maintained for all personnel whose salary is charged to the project. These records should contain, at a minimum, the following information:
o Date (day, month and year)
o Employee’s name
o Position title
o Total daily hours charged to the project
o Employee’s signature
o Project director’s or supervisor’s signature
o Grant number
The subrecipient may use any form that provides the above information.
3. Personnel Qualifications: The narrative section of the grant application includes job descriptions determined by the subrecipient agency which establish the qualifications for each position. If an employee does not meet agency established personnel qualifications, a waiver must be requested from the Office of Criminal Justice Programs. The Office of Criminal Justice Programs must approve prior to employment any grant employee not meeting these requirements. A written waiver of personnel qualifications must be requested prior to the employee’s employment. The written request for the waiver must explain the reason(s) for employing a staff person who does not meet the personnel qualifications. A training plan must be included that ensures the employee maintains a constant level of understanding on how services are to be provided. If approved, a copy of the request for waiver must be maintained in the employee’s personnel file. The waiver will approve the period of the individual’s employment in the position and is applicable to that individual only.
To satisfy the requirement that staff are qualified for the positions in which they are employed it is necessary that the agency obtain verification of education prior to employment and/or training. References for new employees and a resume are required.
4. Personnel File Requirements: Agencies are required to maintain personnel files for all staff employed by grant monies or volunteers providing direct services to clients. These records should minimally contain the following information:
o Documentation of verified character/employment references
o An agency application or resume'
o A signed release of information granting the organization permission to obtain a background check and to conduct reference checks
o Job description
o Documentation of training/certification received such as the topic, presenter, length of training, dates.
o Documentation of minimum qualifications
o Documentation of background checks according to agency policy.
5. Personnel Paid 100% from a single federal award (effective April 16, 2018)
In order to comply with federal regulations to track and identify time worked on activities related to a single federal award, OCJP subrecipients with employees paid 100% from federal grant funds must comply with the following instructions:
Have each employee paid 100% from a single federal award for an extended period of time (6 months or more) complete the Certification of Time Charged to a Single Award form.
Retain the signed form in the employee’s personnel file
See Title 2 Code of Federal Regulations (CFR) Part 225, Cost Principles for State, Local, and Indian Tribal Government, Appendix B, Selected Items of Cost.
NOTE: For personnel funded less than 100% on the grant, subrecipients must have a system in place to provide accurate accounting of time spent on each OCJP funded project. This system should reflect actual daily time worked by each direct staff on grant related activities.
6. Personnel Change Notifications
Subrecipients must provide written notification to OCJP within ten (10) days from the date of occurrence of any of the following:
a. Contact Information Changes
o Any change of address for Authorized Official, Project Director, or Financial Director for the grant-funded project
o Change in e-mail address of Project Director, Financial Director, Authorized Official or any personnel funded by this grant.
b. Personnel Changes
o Any cessation or interruption of implementation of project activities arising from litigation, loss of staff, or programmatic restructuring
o Change in or temporary absence of the Project Director or Financial Director
o Change in Authorized Official
o Change in grant funded personnel positions
o Temporary staff changes should also be reported
c. Staff Vacancies
Vacancies in all grant funded positions MUST be reported in writing (e- mail, fax, or mail) to OCJP within 10 days of the vacancy. All grant funded vacant positions MUST be filled within 45 days of the vacancy. Failure to abide by this requirement may result in the agency losing the position(s) in question. If the position(s) is/are not filled within 45 days, the subrecipient must submit a letter to OCJP justifying the delay in filling the position and explaining how the program is providing services while the position is vacant. After 45 days OCJP must receive a monthly report of this information until the position is filled. Once the vacant position(s) is filled the subrecipient agency MUST notify OCJP in writing within 10 days of the following information as it pertains to the new employee(s):
o Position Title
o Name of Employee
o Date Hired
o Percent of time allotted to the grant funded project
o Job Description
Agencies must use the Personnel Spreadsheet to notify OCJP of staff on the grant(s), and any staffing changes made throughout the life of the project. You are required to submit this form to your OCJP program manager in accordance with the above staff notification requirements.
7. Subcontracted Staff: For policies concerning Subcontracted Staff see Chapter XIII- Procurement of Professional Services.
NOTES: For RSAT specific personnel requirements see RSAT Chapter.
For specific volunteer requirements related to match see Chapter III-Financial Requirements.
This Page Last Updated: July 23, 2019 at 7:48 AM