HHS-2022-ACF-IOAS-OTIP-TV-0035_Signed.pdf
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Administration for Children and Families
Immediate Office of the Assistant Secretary - Office on Trafficking in Persons
Victims of Human Trafficking in Native Communities Demonstration (VHT-NC) Program
HHS-2022-ACF-IOAS-OTIP-TV-0035
Application Due Date: Application Due Date will be submitted as: date based on specified number of days after the actual Synopsis Post Date
04/26/2022
Table of Contents Executive Summary
I. Program Description
II. Federal Award Information
III. Eligibility Information
III.1. Eligible Applicants
III.2. Cost Sharing or Matching
III.3. Other
IV. Application and Submission Information
IV.1. Address to Request Application Package
IV.2. Content and Form of Application Submission
Required Forms, Assurances, and Certifications
The Project Description
The Project Budget and Budget Justification
Application Submission Options
IV.3. Unique Entity Identifier (UEI) and System for Award Management (SAM)
IV.4. Submission Dates and Times
Explanation of Due Dates
Acknowledgement of Received Application
IV.5. Intergovernmental Review
IV.6. Funding Restrictions
IV.7. Other Submission Requirements
V. Application Review Information
V.1. Criteria
V.2. Review and Selection Process
V.3. Anticipated Announcement and Federal Award Dates
VI. Federal Award Administration Information
VI.1. Federal Award Notices
VI.2. Administrative and National Policy Requirements
VI.3. Reporting
VII. HHS Award Agency Contact(s)
VIII. Other Information
Reference Websites
Application Checklist
Funding Opportunity Title:
Victims of Human Trafficking in Native Communities Demonstration (VHT-NC) Program Announcement Type:
Initial Funding Opportunity Number:
HHS-2022-ACF-IOAS-OTIP-TV-0035
Primary CFDA Number:
93.327 Due Date for Applications:
Application Due Date will be submitted as: date based on specified number of days after the actual Synopsis Post Date Executive Summary Notice:
Applicants are strongly encouraged to read the entire notice of funding opportunity (NOFO) carefully and observe the application formatting requirements listed in Section IV.2. Content and Form of Application Submission. For more information on applying for grants, please visit "How to Apply for a Grant" on the ACF Grants & Funding Page at https://www.acf.hhs.gov/grants/how-apply-grant.
The Office on Trafficking in Persons (OTIP) within the Administration for Children and Families (ACF) is announcing funds for the Victims of Human Trafficking in Native Communities Demonstration (VHT-NC) Program. The VHT-NC Program’s goal is to directly fund organizations that will build, expand, and sustain organizational and community capacity to deliver services to Native American (i.e., American Indians, Alaska Natives, Native Hawaiians, and/or Pacific Islanders) adults and minors who have experienced a severe form of human trafficking as defined by the Trafficking Victims Protection Act (TVPA) of 2000, as amended, through the provision of direct services, assistance, and referrals. The following activities are required under the VHT-NC Demonstration Program: a) provision of comprehensive, culturally and linguistically responsive case management to Native Americans who have experienced sex and labor trafficking; b) outreach efforts to increase identification of Native Americans who have experienced sex and labor trafficking; and c) training to service providers and community partners.
The VHT-NC Program, which is informed by a whole family approach, focuses equally and intentionally on services and opportunities for clients and their immediate family members living in their households. OTIP encourages establishing community partnerships, meaningfully engaging with Native American individuals who have experienced trafficking and hiring qualified professionals who reflect the communities being served in all project implementation strategies under the VHT-NC Program. Under the VHT-NC Program, there is a 12-month project implementation period for prime recipients to facilitate optional partnerships, on-board new staff, and develop service protocols specific to Native Americans who have experienced human trafficking. However, clients must be served during the 12-month project implementation period.
https://www.acf.hhs.gov/grants/how-apply-grant
Under the VHT-NC Program, prime recipients must provide a statutorily mandated 25 percent match (cash or in-kind).
I. Program Description Statutory Authority The legislative authority for this program is Section 107(f) of the Trafficking Victims Protection Act (TVPA) of 2000 as amended; 22 U.S.C. 7104(b) and 22 U.S.C. 7105(f), section 213(a)(1) of the William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Pub. L.
110-457.
Description
VHT-NC PROGRAM OVERVIEW
Background
Human trafficking is a crime involving the exploitation of someone to perform labor or commercial sex acts through force, fraud, or coercion. Per section 22 U.S.C. 7102(11) of the Trafficking Victims Protection Act (TVPA) of 2000, as amended, severe forms of trafficking in persons means:
Sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age; or
Labor trafficking in which there is recruitment, harboring, transportation, provision, or obtaining of a person for labor or services through force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.
It is a crime when a minor, a person under the age of 18, is asked or made to perform a sex act in exchange for something of value (e.g., shelter, food, money). There does not need to be a third party (e.g., trafficker) or evidence of force, fraud, or coercion for that minor to be identified as a victim of sex trafficking. Human trafficking victims are often difficult to identify or assist without targeted outreach and referral efforts. Victims can be of any age, race/ethnicity, nationality/citizenship, sex, gender identity, or sexual orientation, with or without disabilities.
In 2020, ACF, in consultation with the Administration for Native Americans (ANA), established the Demonstration Grants to Strengthen the Response to Victims of Human Trafficking in Native Communities (VHT-NC) Program and made six awards to the first cohort. The VHT-NC Program responds to gaps in the anti-trafficking field by dedicating funding to serve Native Americans who have experienced human trafficking through direct outreach and training to the local service provider community. Additionally, in 2021, the Biden Administration published Executive Order 13985 on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government to advance equity and support to communities that have been historically underserved, including Native Americans; and Executive Order 14053 on Improving Public Safety and Criminal Justice for Native Americans and Addressing the Crisis of Missing or Murdered Indigenous People. This NOFO supports these commitments by dedicating funding to identify and serve Native American and Indigenous persons who experience human trafficking. Finally, in 2021 the Biden Administration released the https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-advancing-racial-equity-and-support-for-underserved-communities-through-the-federal-government/ https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-advancing-racial-equity-and-support-for-underserved-communities-through-the-federal-government/ https://www.whitehouse.gov/briefing-room/presidential-actions/2021/11/15/executive-order-on-improving-public-safety-and-criminal-justice-for-native-americans-and-addressing-the-crisis-of-missing-or-murdered-indigenous-people/ https://www.whitehouse.gov/briefing-room/presidential-actions/2021/11/15/executive-order-on-improving-public-safety-and-criminal-justice-for-native-americans-and-addressing-the-crisis-of-missing-or-murdered-indigenous-people/ https://www.whitehouse.gov/briefing-room/presidential-actions/2021/11/15/executive-order-on-improving-public-safety-and-criminal-justice-for-native-americans-and-addressing-the-crisis-of-missing-or-murdered-indigenous-people/ new National Action Plan to Combat Human Trafficking (NAP). This NOFO highlights areas that are responsive to the NAP where appropriate.
Project Objectives
The VHT-NC Program's goal is to fund cooperative agreements that will build, expand, and sustain organizational and local capacity to provide direct services, assistance, and referrals for Native Americans (i.e., American Indians, Alaska Natives, Native Hawaiians, and/or Pacific Islanders) who have experienced severe forms of human trafficking as defined by the TVPA of 2000, as amended.
Under the VHT-NC Program, the following activities are required throughout the project period:
1. Provide comprehensive, culturally responsive, and linguistically appropriate case management and victim assistance to Native Americans who have experienced human trafficking.
2. Conduct outreach to increase identification of Native Americans who have experienced sex and/or labor trafficking.
3. Deliver training for service providers and community partners on effective and trauma-informed identification, referral, assessment, and service delivery strategies.
Project Scope
VHT-NC projects can be implemented in locations that include reservations, off-reservation communities, villages, cities, counties, or specific areas where Native Americans reside. The geographic area may cross state lines, does not need to be contiguous, and can include federally recognized tribal and non-federally recognized Native communities, and urban and rural areas. Prime recipients must be located in the geographic area to be served by the proposed project.
The VHT-NC prime recipient is authorized to form a partnership(s) with other organizations to achieve the VHT-NC Program’s objectives through subawards. If the prime recipient chooses to form a partnership(s), its principal office or the office of the affiliate responsible for implementing and overseeing the VHT-NC project must be located within the proposed project’s geographic area. The prime recipient must adhere to 45 CFR § 75.351 when formalizing partnerships with subrecipient(s). Prime recipients are encouraged to develop partnerships with Native American organizations, tribal governments, or other Native American entities to develop and deliver culturally responsive and linguistically appropriate services. Please see Section I.
VHT-NC Administrative Requirements, Subawards for more information.
OTIP encourages prime recipients to focus on issues relevant to their community through their project activities, including individuals and communities affected by the Missing and Murdered Indigenous People Crisis.
Informed by the National Action Plan to Combat Human Trafficking (NAP) (Priority Action 4.3.2: Leverage federal survivor-consultant networks and federal training and technical assistance centers to ensure survivor input is consistently incorporated into policies and https://www.whitehouse.gov/wp-content/uploads/2021/12/National-Action-Plan-to-Combat-Human-Trafficking.pdf programs), OTIP encourages the strategic integration and engagement with Native Americans who have experienced human trafficking into VHT-NC Program project implementation strategies, including hiring qualified professionals who reflect the communities they serve. Prime recipients should incorporate lived expertise in all aspects of the anti-trafficking response development and provide Native Americans who have experienced human trafficking with opportunities to contribute to program development and activity implementation. These opportunities should provide professional growth and development and not be limited to or heavily rely on presentations about their trafficking experience. Survivor engagement must include compensation based upon the level of engagement and comparable rates paid to practitioners and service providers.
Native Americans with human trafficking lived experience should be involved in efforts including, but not limited to the following:
Developing agency-wide policies and comprehensive case management protocols.
Developing strategies for project implementation, victim identification, program evaluation, etc.
Developing and delivering outreach and training activities.
Building organizational capacity.
Leading or contributing to support groups and/or mentorship initiatives.
Identifying community partners.
Prime recipients should inform individuals with lived experience of any professional development, leadership training, consultant, and/or employment opportunities available to them in their community and beyond, including opportunities with the National Human Trafficking Training and Technical Assistance Center (NHTTAC). NHTTAC provides individuals who have experienced human trafficking opportunities to participate in professional development and educational activities, develop anti-trafficking resources, and provide trainings and technical assistance.
Under the VHT-NC Program, there are three separate opportunities to receive bonus points listed under Section V.I. Criteria. Bonus points will be awarded to applicants that present a plan to meaningfully and ethically engage individuals with lived experience of human trafficking in project activities; to applicants that present a training plan to address the Missing and Murdered Indigenous People Crisis in their local community; and to applicants who either are or partner with an entity that is tribally chartered or has a board majority comprised of tribally affiliated members to demonstrate experience and expertise serving Native Communities. For the latter, prime recipients must identify each board member by name and indicate their affiliation or relationship to at least one of the following categories of community representation, defined by ANA as federally or state-recognized tribes (Indian Tribal Entities Within the Contiguous 48 States Recognized by and Eligible To Receive Services From the United States Bureau of Indian Affairs), or persons considered to be Native American as defined in 45 CFR § 1336.10 and Native American Pacific Islanders as defined in Section 815 of the Native American Programs Act.
VHT-NC SERVICE REQUIREMENTS
https://nhttac.acf.hhs.gov/survivor-involvement https://nhttac.acf.hhs.gov/survivor-involvement https://www.federalregister.gov/documents/2019/02/01/2019-00897/indian-entities-recognized-by-and-eligible-to-receive-services-from-the-united-states-bureau-of https://www.federalregister.gov/documents/2019/02/01/2019-00897/indian-entities-recognized-by-and-eligible-to-receive-services-from-the-united-states-bureau-of https://www.federalregister.gov/documents/2019/02/01/2019-00897/indian-entities-recognized-by-and-eligible-to-receive-services-from-the-united-states-bureau-of
Guiding Principles
The VHT-NC Program incorporates trauma-informed and person-centered approaches to assist Native Americans of different racial, ethnic, cultural, gender identity, sexual orientation, ability, and religious backgrounds who have experienced human trafficking. A trauma-informed care model assumes that clients and staff have experienced trauma. This model includes organizational change that promotes resilience in clients and staff; engages individuals in care;
prevents re-traumatization; and incorporates knowledge about trauma into policies, procedures, practices, and settings. For more information on the development of trauma-informed services, and a framework for becoming a trauma-informed organization, system, or service sector, please visit the Substance Abuse and Mental Health Services Administration’s Concept of Trauma and Guidance for a Trauma-informed Approach.
Prime recipients must incorporate culturally responsive and traditional healing practices into the project design and implementation, if appropriate. Cultural wisdom and traditional practices are fundamental to achieving behavioral health improvements today and effecting change for future generations.
All VHT-NC Program activities must adhere to the National Culturally and Linguistically Appropriate Services (CLAS) Standards, which are a comprehensive series of guidelines that inform and facilitate practices related to culturally and linguistically appropriate health services. Clients served under the VHT-NC Program must receive comprehensive case management assistance in their preferred language, including Indigenous languages. The VHT- NC Program is voluntary; clients must have the option to decline services provided by the agency supported under the program. The clients’ concerns and priorities should guide the actions of the service delivery strategy.
The VHT-NC Program is informed by a whole family approach that focuses on services and opportunities for clients and their family members living within their households. While the TVPA of 2000, as amended, does not authorize direct benefits for family members, this funding is intended to allow family members to derive benefits from the services provided, when in the client’s best interest. A focus on whole families is responsive to the NAP (Priority Action 2.6.3:
Increase access to employment) as well as the 2019 U.S. Advisory Council on Human Trafficking report, which states:
“Whole families must be considered in helping survivors overcome and heal. Many survivors have children who have been negatively affected by their parent’s trafficking experience and what they have seen and heard. We must lift up parents and children together with services and supports that will help them be safe, find financial stability, and be empowered to find new opportunities. With recent studies suggesting one in seven children have mental health needs and half do not receive treatment, it is imperative, when supporting families, to also address the needs of survivors’ children. We must offer services that help children heal to break intergenerational cycles of victimization.”
Eligible Beneficiaries of Program Services https://ncsacw.samhsa.gov/userfiles/files/SAMHSA_Trauma.pdf https://ncsacw.samhsa.gov/userfiles/files/SAMHSA_Trauma.pdf https://thinkculturalhealth.hhs.gov/clas/standards https://thinkculturalhealth.hhs.gov/clas/standards https://www.state.gov/united-states-advisory-council-on-human-trafficking-annual-report-2019/ https://www.state.gov/united-states-advisory-council-on-human-trafficking-annual-report-2019/
Under the Indian Citizenship Act of 1924, all Native Americans born in the United States (U.S.)
and U.S. Territories are U.S. citizens. This includes American Indians, Alaska Natives, Native Hawaiians, and/or Pacific Islanders. Eligibility for services under the VHT-NC Program is limited to Native Americans who have experienced severe forms of human trafficking, as defined by the TVPA of 2000, as amended. This includes adults and minors, regardless of gender identity or sexual orientation (including individuals who identify as Two-Spirit, Lesbian, Gay, Bisexual, Transgender, Queer, Questioning, Intersex, and/or Asexual (2SLGBTQIA+)), who are not currently receiving trafficking-specific services from another federally funded program. Under the VHT-NC Program, prime recipients and, if applicable, any subrecipient(s) may receive funding from more than one federal agency, but clients may not be served through more than one federally funded human trafficking-related grant, contract, or subaward at a time.
Prime recipients must have a viable plan in place to identify individuals who have experienced human trafficking, determine eligibility to enroll clients into the VHT-NC Program, and refer ineligible individuals for services, in compliance with statutory and administrative requirements prior to the initiation of VHT-NC Program-funded services. The prime recipient and, if applicable, its subrecipient(s) must implement universal human trafficking screening for all children and youth receiving services. The VHT-NC Program was authorized by 22 U.S.C.
7105(f) to assist U.S. citizens and lawful permanent residents (LPRs) who have previously experienced human trafficking. Therefore, non-LPR foreign nationals and individuals who have not previously experienced human trafficking are ineligible for assistance. Prime recipients must include a plan within its service delivery protocol to ensure that all clients enrolled into the VHT- NC Program meet the eligibility criteria in 22 U.S.C. 7105(f) and that they are not enrolled concurrently in other federally funded programs providing similar services. Prime recipients must develop trauma-informed protocols to assess a prospective client’s eligibility prior to enrollment. Potential clients may not be comfortable disclosing their human trafficking experience, may not know their current immigration status, or may not know if they are a beneficiary of other federal funding. For more information see Section I. VHT-NC Administrative Requirements, Service Delivery Protocol.
OTIP recognizes that determining eligibility can be a sensitive subject for many potential clients. Individuals who have experienced human trafficking may not have access to identification or immigration documents, or they may have fraudulent documents provided by the trafficker. OTIP encourages creative approaches that work for your community. Plans can include partnering with legal services agencies or other entities that specialize in eligibility or serving clients with alternate funding until they have built enough rapport to verify a potential client’s status.
Prime recipients or, if applicable, any subrecipient(s) who determine that the potential client is not a U.S. citizen or LPR who has experienced human trafficking must have protocols in place to provide referrals to programs that can address the individual’s needs including, but not limited to, the Trafficking Victim Assistance Program. Family members in the client’s household are not eligible to enroll as individual participants under the VHT-NC Program. However, family members who live with the client may derive benefits from the client’s services, such as housing, child care, food, family reunification, and other expenses determined in the client’s best interest.
Comprehensive Case Management Services
Under the VHT-NC Program, prime recipients must conduct a comprehensive case management approach throughout the project period. Comprehensive case management services must include helping clients navigate systems of care, direct services, and/or community referrals for the following, which reflect service priorities identified by the U.S. Advisory Council and in the NAP (Priority Action 2.6.1: Increase access to mental health and other healthcare services;
(Priority Action 2.6.3: Increase access to employment; and Priority Action 2.6.4: Increase access to education):
1. Culturally responsive and linguistically appropriate services tailored to Native American clients
2. Identification, screening, assessment, safety planning, and service planning
3. Advocacy and information about crime victims’ rights and services
4. Direct assistance to support unmet basic needs and the well-being of Native Americans who have experienced human trafficking
5. Allowable and reasonable expenses such as food, clothing, transportation assistance, child care, and interpreter services, including Certified Deaf Interpreters
6. Health care including traditional healing, mental health, behavioral health, substance use treatment, vaccinations, medical, residential treatment, vision, and dental services;
7. Emergency, transitional, and long-term housing assistance
8. Employment assistance, vocational training, and job training and placement services, such as those offered through American Job Centers and other employment and training programs funded by the Department of Labor, including the Workforce Innovation and Opportunity Act Section 166 Indian and Native American Programs or the U.S.
Department of the Interior’s Indian Employment, Training and Related Services Consolidation Act of 2017 Program (for more information visit: https://www.dol.gov/agencies/eta/dinap)
9. Enrolling clients to identify and receive available public benefits, assisting with the application preparation and submission, tracking the status of an application, assisting with collecting required supporting documentation, and assisting with an appeal if benefits are denied.
Optional comprehensive case management services that may be provided directly, or through referral, include but are not limited to, the following:
1. Legal advocacy and services related to an individual’s human trafficking experience, including explanation of legal rights and protections, cooperation with law enforcement, and assistance with family and civil matters (e.g., protection orders, victims’ rights enforcement and compliance efforts, representation in family court, emancipation of minors, expungement or vacatur of criminal records, and name changes)
2. Educational assistance
3. Life skills training, including managing personal finances
4. Peer-to-peer support and mentoring
5. Family reunification and supportive services intended to support broader well-being.
https://www.dol.gov/agencies/eta/dinap
Comprehensive case management services should empower clients to identify and achieve personal milestones toward well-being and independence and may include leadership development opportunities. Case management services and activities should be low-barrier and include service plan development, counseling, monitoring, evaluating client progress, and securing and coordinating direct services.
VHT-NC Program prime recipients must have the capacity to deliver all required services to clients directly through their agency and/or through formal partnership(s), which includes referring clients to the appropriate community agency if no such partnership exists. If a client requires services that are beyond the prime recipient’s and, if applicable, its subrecipient’s capacity, the client must be provided with referrals to services within the community. Under the VHT-NC Program, prime recipients must maintain proper documentation of all referrals provided. Prime recipients serving homeless minors who are at-risk for human trafficking may consider partnering with local Family and Youth Services Bureau-funded programs (including Runaway Homeless Youth recipients, Family Violence Prevention and Services recipients, and Adolescent Pregnancy Prevention recipients) to refer applicable clients to services.
VHT-NC Program prime recipients must strive to refer clients to pro bono providers whenever possible. If a client requires services that are within the scope of VHT-NC Program but are beyond the prime recipients’ capacity and cannot be covered through pro bono providers, prime recipients may use VHT-NC funds to cover service costs related to the client's need in accordance with the following restrictions: a) funds may not be used to pay for direct benefits for family members; b) all client-related costs must be allowable, reasonable, allocable, and commensurate with allowable program activities as noted in the NOFO and CFR; and c) any costs found to be unallowable will be disallowed. Please see Section IV.6. Funding Restrictions for more information.
Under the VHT-NC Program, prime recipients and, if applicable, any subrecipient(s) must conduct client satisfaction surveys to assess the quality of services being provided and to identify areas of program improvement. Please see Section I. VHT-NC Administrative Requirements, Service Delivery Protocol for more information. Prime recipients are encouraged to develop client satisfaction surveys and other evaluation tools through partnerships with colleges and universities, including but not limited to Tribal Colleges and Universities, Historically Black Colleges and Universities, and other Minority Serving Institutions recognized by the U.S.
Department of Education. No more than 3 percent of total award funds per budget period may be used to support client satisfaction evaluation efforts. Please see Section IV.6. Funding Restrictions for more information.
Financial Assistance for Transitional Costs
Clients that are within 8 months of program discharge may receive one-time financial assistance for transitional costs of up to $2,000 to cover transitional expenses, including:
Housing (e.g., security deposit, first month’s rent, relocation, etc.)
Education (e.g., tuition, enrollment fees, textbooks, etc.)
Employment (e.g., certification courses, purchasing business attire, etc.)
https://www.acf.hhs.gov/fysb/programs https://www2.ed.gov/about/offices/list/ocr/edlite-minorityinst.html
Child care (e.g. daycare costs, before/after-care school costs, etc.)
Other costs that the client in collaboration with the case manager identify as necessary for the client’s successful discharge from services.
Prime recipients must develop a policy within their service delivery protocol to assess client readiness to receive financial assistance at least 8 months prior to discharge from services that includes, at a minimum, objective criteria for assessing client readiness to receive financial assistance, timing and mechanism for disbursement, and dispute resolution procedures. The policy must be applicable to all clients served under the VHT-NC Program, including clients served through subrecipient(s), if applicable. It must demonstrate consideration for client agency, be voluntary, provide equal access and available funding level to all clients, and include a process that allows clients who re-enroll to accept financial assistance within 8 months following their discharge if they have not already received a total of up to $2,000 in financial assistance.
The client must be enrolled in services while receiving the financial assistance of up to $2,000. Payments must be made directly to the third-party (e.g., security deposit paid directly to a landlord, tuition paid directly to educational institution, child care payment paid directly to provider, etc.), and not directly to the client. Future expenses outside the enrollment period may not be dispersed. So, for example, if a client has either tuition or housing costs that are longer than the 8 months period and extends beyond their discharge date, these costs may not be charged to the award. Recipients must track financial assistance spending for each client to ensure total financial assistance does not exceed $2,000. A client’s decision to not request post-discharge services must not prevent them from re-enrolling in services under the VHT-NC Program or pursuing financial assistance at a later date. Please see Section I. VHT-NC Administrative Requirements, Service Delivery Protocol and Section IV.6. Funding Restrictions for more information.
Recipients must use traceable mechanisms for disbursement to include direct payments to vendor, reimbursed receipts, or invoices to ensure accurate record keeping. The issuance of alternative payment mechanisms (i.e., gift cards or cash) is not permitted.
Prime recipients must thoroughly document individual financial assistance plans and spending, including line-item amounts, cost category, nontraditional cost category, mechanisms for disbursements, connection to related goals, receipts, bank records, client identifiers, and relevant dates. Regardless of the number of times a client re-enrolls, clients may access up to $2,000 in financial assistance only once under any federal grant program funded by OTIP, so the prime recipient is responsible for keeping track of whatever balance is remaining from the $2,000. OTIP will review disbursement records for monitoring purposes throughout the project period. Prime recipients must consider available budget and projected financial assistance needs for each budget period. Prime recipients should not anticipate the availability of supplemental funding to meet this program requirement.
Outreach
Under the VHT-NC Program, targeted outreach to Native Americans developed by prime recipients throughout the project period must be conducted in the identified, geographic region and in venues, markets, and industries where human trafficking is known or suspected to occur. OTIP distinguishes between outreach and public awareness. Outreach is direct contact with Native Americans who may have experienced human trafficking or who are vulnerable or are considered to be at a higher risk for human trafficking. Examples include street outreach, targeted online outreach, and human trafficking screening carried out in court diversion programs, detention centers, community organizations, agricultural settings, hospitality industry, restaurants, domestic work settings, foster care, and elder and child care settings. Though screenings may be conducted during outreach events, it is not required as it may not always be feasible or safe to do so.
Public awareness includes education efforts aimed at the general public. Examples include community awareness raising, newspaper articles, radio or television interviews, and tabling at conferences. Prime recipients may not use VHT-NC Program funds to create or carryout any public awareness activities throughout the project period.
OTIP recognizes that partnerships serve to extend reach throughout the project region in most successful outreach models; therefore, OTIP encourages prime recipients to partner with agencies that have demonstrated experience conducting outreach to identify individuals who have experienced human trafficking, including outreach conducted within Native American communities. As part of the outreach strategy under the VHT-NC Program, prime recipients and, if applicable any subrecipient(s), must use standardized screening tool(s) that are validated, evidence- and trauma-informed to identify and evaluate client needs throughout the service relationship. Prime recipients may elect to use one or multiple tools, but all tools must be designed to identify adult and minor victims of sex and labor trafficking by assessing common indicators of human trafficking, including if the individual experiences any of the following:
Feels pressured by their employer to stay in a job or situation they want to leave.
Owes money to an employer or recruiter and/or is not being paid what they were promised or are owed.
Does not control their own identity documents (e.g., passport, driver's license, Social
Security card, tribal identification, etc.).
Is living and working in isolated conditions, largely cut off from interaction with others or support systems.
Appears to be monitored by another person when talking or interacting with others.
Is receiving threats of harm from their employer/supervisor.
Is working in dangerous conditions without proper safety gear, training, adequate breaks, and other precautions.
Is living in dangerous, overcrowded, or inhumane conditions provided by an employer.
Wants to stop participating in the coercive engagement of selling or trading sex but is intimidated or feels afraid to leave.
Discloses they were reluctant to engage in selling sex but that someone pressured them into it.
Lives where they work or are transported by guards between home and workplace.
Is a minor who lives with, is supported by, or is dependent on a family member with a substance use problem or who is abusive in other ways.
Has a trafficker or manager in the sex trade.
Works in an industry where it may be common to be pressured into performing sex acts for money, such as a strip club, illicit cantina, go-go bar, or illicit massage business.
Has a controlling parent, guardian, romantic partner, or “sponsor” who will not allow them to meet or speak with anyone alone, or monitors their movements, spending, and/or communications.
Is not in control of their own money or has no financial records and/or bank account.
Is unable to attend school.
Is unable to participate in extracurricular activities or come and go as they please from their home.
Is a minor being obligated to perform work, especially if it may jeopardize their safety, health, well-being, or educational opportunities.
Is being pressured to work to pay off debts or remittances.
Is being forced, coerced, or pressured to provide a labor or service that contributes to an illegal or illicit activity or business operation (e.g., assault, arms smuggling/dealing, decoy services, extortion, gang activity, financial scams, human smuggling/foot guiding, drug cultivation/production, drug transporting/distribution, drug smuggling, commercial sexual exploitation, look-out/scouting, robbery, and wildlife smuggling).
Optional outreach and screening tools that may be used in project activities are available on the OTIP website’s Resource Library. The ACF programs identified below can promote, coordinate, and make referrals to service delivery systems and training and technical assistance resources.
National Human Trafficking Hotline (NHTH)
NHTTAC
ANA Website Runaway and Homeless Youth Program Family Violence Prevention Services Program Adolescent Pregnancy Prevention Program Family Violence Prevention & Services Child Welfare Information Gateway U.S Department of Housing and Urban Development Exchange
All outreach materials must be submitted to the Federal Project Officer for approval at least 30 days prior to the intended event regardless of prior approvals through other programs or past HHS, DOJ, or state officials. For more information on prior approval requirements, please see Section I., Post-Award Requirements, Tools and Resources.
Community Training
Under the VHT-NC Program, prime recipients are required to provide training for local partners and community organizations throughout the project period to increase knowledge and understanding of effective and trauma-informed trafficking victim identification, referral, https://humantraffickinghotline.org/ https://nhttac.acf.hhs.gov/ https://www.acf.hhs.gov/ana https://www.acf.hhs.gov/fysb/runaway-homeless-youth https://www.acf.hhs.gov/fysb/programs/family-violence-prevention-services https://www.acf.hhs.gov/fysb/adolescent-pregnancy-prevention https://www.acf.hhs.gov/fysb/programs/family-violence-prevention-services https://www.childwelfare.gov/ https://www.hudexchange.info/ assessment, and service delivery strategies. Training builds the capacity of local service providers and strengthens the local response to human trafficking. Training audiences can include, but are not limited to, the following:
Native American organizations Tribes and tribal programs involved in referrals Court systems including tribal judges or other tribal court assigned staff such as tribal attorneys and tribal advocates Social service organizations including Bureau of Indian Affairs social services programs Adult emergency shelter and transitional housing programs Runaway and homeless youth shelters Substance use treatment centers Domestic violence organizations and shelters, sexual assault responders, and organizations dealing with intimate partner violence or child victimization Schools Faith-based organizations Legal services organizations Public health entities including Indian Health Service facilities, emergency room staff, clinic staff, community health clinics, and schools of public health and social work Business/labor organizations Transportation industry entities Juvenile justice systems Child welfare agencies Educators, school staff, and school districts
Under the VHT-NC Program, trainings to local partners and community organizations that may come in contact with individuals who may experience human trafficking must include all of the following topics below, at a minimum. The training topics listed are responsive to the 2021 U.S.
Advisory Council on Human Trafficking report that recommends HHS expand specialized training on human trafficking and its indicators to include subtopics related to underserved populations (e.g., youth, Indigenous populations, Black and Brown communities, 2SLGBTQIA+ communities, boys and men, and people with special needs).
Federal definition of severe forms of trafficking in persons Case studies of individuals, with a special emphasis on Native Americans, who have experienced human trafficking that include opportunities for identification in Native American communities
Information about human trafficking including types of human trafficking (both sex and labor trafficking) and recruitment and/or retention tactics used by traffickers
Indicators that a person may be experiencing human trafficking Safety protocols for those in direct contact with Native Americans potentially experiencing human trafficking Services and benefits available for Native Americans who have experienced human trafficking
Specific considerations for Native Americans who have experienced human trafficking which may include relevant cultural and/or spiritual needs, historical trauma, and cultural violence through the loss of access to lands, territories, natural resources, traditional practices, language, etc., and exclusion from the decision-making and policy frameworks in the nation-states in which they live
Intersectionality between race and human trafficking (e.g., the role racial identity and racism plays in the risk for human trafficking; process of identification; experience of service delivery; interaction with enforcement systems; including the criminal justice system; access to resources; health disparities/inequities experienced by underserved communities; etc.)
Intersection between political status and human trafficking (e.g., the role that criminal jurisdiction and limited enforcement of tribal governments over non-tribal citizens plays in the increased risk for human trafficking, interaction with law enforcement and the criminal justice system, etc.)
Intersectionality between sexual orientation, gender identity, and human trafficking (e.g., the role gender identity and expression and exclusion plays in the risk for human trafficking, process of identification, experience of service delivery, interaction with the criminal justice, access to resources, health disparities/inequities experienced by 2SLGBTQIA+ community members, etc.)
Intersectionality between disability and human trafficking (e.g., the role disability status and exclusion play in the risk for human trafficking, process of identification, experience of service delivery, interaction with the criminal justice system, access to resources, etc.)
Intersectionality between human trafficking and forced criminality (e.g., understanding that when an individual is forced to provide a labor or service that contributes to an illegal or illicit activity or business operation, they may also be considered a victim of human trafficking)
Special considerations for minors experiencing human trafficking, which may include relevant legal and social welfare systems, such as juvenile justice and child welfare
Anti-trafficking laws and legal considerations in the specified geographic area, including tribal jurisdiction
How to deliver person-centered, trauma-informed services and assistance to Native Americans who have experienced human trafficking
Post-identification reporting and referral protocols Housing and employment needs of Native Americans who have experienced human trafficking
Training audiences and topics listed above reflect the priorities reflected in the NAP (Priority Action 2.1.3: Regularly train federal law enforcement and service provider agencies on identifying human trafficking). Prime recipients may use no more than 5 percent of total award funds per budget period to support community training activities. Prime recipients may also refer local community partners seeking human trafficking training to NHTTAC. VHT-NC Program funds may not be used to cover any costs associated with continuing education units within community training activities. Please see Section IV.6. Funding Restrictions for more information.
VHT-NC ADMINISTRATIVE REQUIREMENTS
Subawards
Recipients under this grant program may opt to transfer a portion of substantive programmatic work to other organizations through subaward(s). The prime recipient must maintain a substantive role in the project. ACF defines a substantive role as conducting activities and/or providing services funded under the award that are necessary and integral to the completion of the project. Subrecipient monitoring activities alone, as specified in 45 CFR § 75.352, do not constitute a substantive role. Furthermore, ACF does not fund awards where the role of the applicant is primarily to serve as a conduit for passing funds to other organizations unless that arrangement is authorized by statute. No more than 40 percent of total award funds per budget period may be awarded as subawards. Please see Section IV.6. Funding Restrictions for more information.
Subrecipient(s) must meet the eligibility requirements identified in the NOFO, Section III.1.
Eligible Applicants. Additionally, all subrecipient(s) must obtain a Unique Entity Identifier (UEI) number assigned by the System for Award Management (SAM), if they do not already have one. Prime recipients are required to check the SAM to verify that the subrecipient(s) is/are not debarred, suspended, or ineligible.
Please reference the Award Term and Condition on Subawards on the ACF Administrative and National Policy Requirements website for further requirements involving subawards.
Prime recipients must conduct a risk assessment of the subrecipient(s) in accordance with 45 CFR § 75.352(b). Prime recipients are required to adhere to the requirements noted in 45 CFR §75.352 and be in compliance with 45 CFR §§ 75.351 and § 75.353. Prime recipients may be required to report under the Federal Financial Accountability and Transparency Act.
Should a subrecipient perform unsatisfactorily, prime recipients are responsible for remedying subrecipient issues. Prime recipients will be held accountable for cost disallowances regarding subawarded funds. Subrecipient performance will also be considered during review of applications for non-competing continuations. If requirements of the program cannot be met due to subrecipient issues, ACF may need to take one or more of the actions listed under 45 CFR § 75.371-.372, including withholding or disallowing funds, partially or fully suspending the award, or terminating the award.
Service Delivery Protocol
Under the VHT-NC Program, prime recipients must develop a service delivery protocol. The protocol must include the prime recipients' policies and procedures for eligibility, comprehensive case management, referral, discharge and post-discharge policies, and provisions specific to Native Americans who have experienced human trafficking. Discharge and post-discharge policies must include at a minimum, the level of client progress required to be discharged from the program, the frequency and duration of optional post-discharge check-ins, and policies for clients who do not want to remain engaged with the service provider post-discharge. Additionally, the protocol must include financial assistance for transitional cost https://www.acf.hhs.gov/administrative-and-national-policy-requirements#book_content_14 https://www.acf.hhs.gov/administrative-and-national-policy-requirements guidelines that comply with the eligibility and oversight requirements outlined in Section I. VHT- NC Service Requirements, Financial Assistance for Transitional Costs.
The protocol must include the standardized, validated, and evidence- and trauma-informed screening tool(s) VHT-NC Program staff will use to identify individuals who may have experienced human trafficking during outreach or intake. OTIP understands that providers need time to establish trust with individuals who may have experienced human trafficking to facilitate disclosure. Therefore, prime recipients are not required to use the screening tool immediately after establishing the service relationship. The screening tool(s) must be used within 30 days of a client entering the VHT-NC Program. Please note that though a screening tool does not have to be used until 30 days from date of client entry, prime recipients, and if applicable, subrecipient(s) must separately assess the eligibility of a prospective client prior to enrollment as described in Section I. VHT-NC Service Requirements, Eligible Beneficiaries of Program Services.
The protocol must also include a 24-hour response plan for handling client emergencies and emergency calls from law enforcement after hours and on weekends. While acceptable plans cannot be limited to hotline services and call-forwarding systems, the response plan must include coordination with the NHTH, which maintains a National Referral Directory (Directory) of organizations and programs that serve individuals who have experienced human trafficking. The Directory includes a comprehensive internal resource for limited use by the NHTH to respond to calls and an online, public version that includes anti-trafficking agencies that opt into the public version. Prime recipients must coordinate with the NHTH to ensure all providers receiving funding are included in the Directory's internal or public version. Please note that providing a link to a non-federal website in this NOFO does not constitute an endorsement by ACF or any of its employees of the sponsors of the website or the information or products presented on the site. ACF cannot attest to the accuracy of information provided by this link or any other linked sites on the website.
In response to the NAP (Priority Action 2.6.2: Increase access to shelters and safe housing), the service delivery protocol must include the prime recipients’ policies to facilitate safe and secure housing options (e.g., emergency, short-term, transitional, and long-term) for individuals who have experienced human trafficking.
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