OVW Guidance on Commingling of Funds

U.S . Department of Justice
ovwOffice on Violence Against Women
Work ing Together to End the Viole nce
OVW Guidance on Commingling of Funds
State administering agencies may choose to issue a single award for multiple funding streams, both
federal and state, to provide subgrantees the convenience of managing fewer awards. For example, state
administering agencies may make awards to rape crisis centers for sexual assault victim advocacy that
contain STOP Formula, SASP Formula, and state funds. Although this approach is permissible, state
administering agencies must ensure that both the state and subgrantees meet relevant provisions of the
DOJ Financial Guide and 2 CFR 200.302. Failure to meet these requirements can result in audit findings.
Requirements for permissible comingling of funds:
1) 	For each funding stream, the subgrantee must be able to identify the Catalog of Federal Domestic
Assistance (CFDA) title and number, federal award identification number and year, name of
awarding federal agency, and name of the pass-through entity (i.e., state administering agency).
2) 	The subgrantee’s accounting system must be able to account for each funding stream separately.
3) 	The subgrantee’s financial management systems, including records documenting compliance with
federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient
to permit the preparation of reports required by general and program-specific terms and
conditions; and the tracing of funds to a level of expenditures adequate to establish that the
subgrantee’s use of such funds complies with federal statutes and regulations and the terms and
conditions of each federal award.
4) 	The subgrantee must submit separate program progress reports for each funding stream, which
show what activities were supported with that funding.
5) 	The subgrantee must be able to provide accurate, current, and complete disclosure of how funds
were expended for each federal award or program.
6) 	The subgrantee must maintain records that identify adequately the source and application of funds
for federally-funded activities and how those funds are applied to the subgrant activities. These
records must contain information pertaining to federal awards, authorizations, obligations,
unobligated balances, assets, expenditures, income and interest and be supported by source
documentation.
In short, the state can save some time and effort by reducing the number of applications that subgrantees
need to submit, but, in turn, subgrantees must be able to treat the funds as if those funds are separate
awards in terms of tracking the activities and expenditures. An example of a combined solicitation
process within the Department of Justice is the Combined Tribal Assistance Solicitation (CTAS). Under
CTAS, the Department combines most of its tribal-specific grant programs into a single solicitation, so
that tribes only need to prepare a single application. However, the Department’s grant-making
components issue CTAS awards separately, and each award has its own special conditions and reporting
requirements commensurate with the underlying funding stream. This way it is clear to the grantees how
to meet the requirements for each funding stream.
Office on Violence Against Women (OVW)July 2017