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Section 4: Additional STEP Requirements

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Grant Agreement General Terms and Conditions

The Grant Agreement General Terms and Conditions will be included in all grant agreements. It provides the terms and conditions governing the grant and certifies that a subgrantee will comply with the applicable regulations, policies, guidelines, and requirements, including 2 C.F.R. Part 200 (Uniform Guidance), as they relate to the application, acceptance, and use of federal or state funds for the project. This attachment further explains other federal and state acts and laws that a subgrantee must adhere to with the awarding of federal and state moneys for grant expenditure.

Potential subgrantees completing a proposal must certify that they agree to the terms and conditions, as well as the responsibilities of the subgrantee, by completing the Terms, Conditions, and Responsibilities Proposal Page in eGrants.

NOTE: Potential subgrantees are required to become familiar with the contents of the Grant Agreement General Terms and Conditions, because failure to do so will not excuse nonperformance or noncompliance once a grant has been awarded.

See the Texas Behavioral Traffic Safety Program Grant Agreement General Terms and Conditions to obtain more information on general terms and conditions for STEP grant agreements.

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STEP Operating Policies and Procedures

All STEP agencies must either have established written Selective Traffic Enforcement Program (STEP) operating policies and procedures, or will develop written policies and procedures before STEP grants can be executed. Each STEP agency will certify that it has, or will, develop such procedures during the proposal process in eGrants. If an agency is selected for a grant award, a copy of the agency’s written policies and procedures must be submitted with the executed grant. Local policies and procedures must include at a minimum:

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  • A description of which position serves as a STEP project director and a list of their main responsibilities.
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  • A description of how the agency selects individuals to work a STEP shift.
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  • A description of how prior approval is obtained for an individual authorized to work a STEP shift.
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  • A list of any restrictions imposed on working STEP, such as limitations on the number of hours an officer can work per shift, etc.
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  • A description on how the agency determines an individual’s overtime status before working a STEP.
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  • A description of how the agency supervises officers working STEP shifts.
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  • A description of how an individual’s time worked on a STEP shift is documented.
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  • A description of the paperwork required after the STEP shift ends (e.g., time sheets, overtime cards, STEP daily activity reports, citations, etc.).
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  • A description of the process supervisors use to approve and document the hours worked.
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  • A description of the process used to oversee the agency’s performance toward meeting the grant’s performance measures/target numbers.

TRF-BTS staff will compile a list of agencies that have indicated they will develop these policies (after the proposal process, but before grant execution) and have each of these agencies submit a copy of the agency’s written policies and procedures for review. TRF-BTS will determine if the written policies and procedures are acceptable and contain the minimum requirements.

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Responsibilities of the Subgrantee

The responsibilities of the subgrantee are included below to encourage potential STEP subgrantees to become familiar with the requirements that they will be held responsible for once a grant is awarded. Familiarity with these requirements will also assist potential subgrantees in submitting successful proposals. The responsibilities of the subgrantee for a STEP program are to:

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  • Carry out all performance measures established in the grant, including fulfilling the law enforcement objectives by implementing the Operational Plan contained in the Grant Agreement.
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  • Submit all required reports to TxDOT fully completed with the most current information and within the required time frames as defined in Article 3 and Article 7 of the Grant Agreement General Terms and Conditions. This includes reporting to TxDOT on progress, achievements, and problems in monthly performance reports and attaching necessary source documentation to support all costs claimed in Requests for Reimbursement (RFRs).
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  • Attend TxDOT-approved training.
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  • Attend meetings according to the following:
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    • The Department will arrange for meetings with the subgrantee to present the status of activities and to discuss problems and the schedule for the following quarter’s work.
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    • The Project Director or other appropriate qualified persons will be available to represent the subgrantee at meetings requested by the Department, including on-site monitoring visits when required.

NOTE: For out-of-state travel expenses to be reimbursable, the subgrantee must have obtained the approval of TxDOT, through eGrants, prior to the beginning of the trip. Grant approval does not satisfy this requirement. Please see “Travel for Subgrantees” in Chapter 5, Section 10, for information on obtaining out-of-state travel approvals.

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  • Maintain verification that all expenses, including wages or salaries for which reimbursement is requested, is for work exclusively related to the project.
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  • Ensure that the grant will in no way supplant (replace) funds from other sources. Supplanting refers to the use of federal funds to support personnel or any activity already supported by local or state funds.
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  • Ensure that each officer working on the STEP project will complete an officer’s daily activity report form. The form should include at a minimum: name, date, badge or identification number, type of grant worked, grant site number, mileage (including starting and ending mileage), hours worked, type of citations issued or arrests made, and officer and supervisor signatures. See “STEP Tool Box” section on the eGrants Help Page for samples of officers’ daily activity reports.
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  • Ensure that the following language be added to officers’ activity reports immediately above the signature lines of the officer and supervisor:

“I understand that this information is being submitted to support a claim against a federally-funded grant program. False statements on this form may be prosecutable under 18 U.S.C. §1001. The information on this form is true, correct, and complete to the best of my knowledge and ability.”

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  • Ensure that no officer above the rank of lieutenant (or equivalent title) will be reimbursed for enforcement duty, unless the subgrantee received specific written authorization from TxDOT, through eGrants system messaging, prior to incurring costs. See “Step Rank Authorization Form” later in this section.

In addition to the requirements outlined above, subgrantees must also adhere to the provisions presented below.

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  • If an officer makes a STEP-related arrest during the shift, but does not complete the arrest before the shift is scheduled to end, the officer can continue working under the grant to complete that arrest. However, if the arrest is not due to a STEP element, the officer only has up to two hours to complete the arrest under the STEP grant.
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  • The subgrantee should have a safety belt use policy. If the subgrantee does not have a safety belt use policy in place, a policy should be implemented, and a copy maintained for verification during the grant year.
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  • Officers working DWI enforcement must be trained in National Highway Traffic Safety Administration/International Association of Chiefs of Police Standardized Field Sobriety Testing (SFST). In the case of a first-year subgrantee, the officers must be trained, or scheduled to be SFST trained, by the end of the grant year. For second or subsequent year grants, all officers working DWI enforcement must be SFST trained.
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  • The subgrantee should have a procedure in place for contacting and using drug recognition experts (DREs) when necessary.
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  • The subgrantee is encouraged to use the Law Enforcement Advanced DUI/DWI Reporting System (LEADRS) available through the Buckle Up Texas website at BuckleUpTexas.com.
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STEP Rank Authorization Form

Some subgrantees may have the need for an employee above the rank of lieutenant to work enforcement in order for the STEP grant to be successful. The subgrantee is responsible for justifying in writing why an employee above the rank of lieutenant should be allowed to work STEP enforcement.

Subgrantees must complete a STEP Rank Authorization Request Form, located on the eGrants Help Page, to request authorization for an employee above the rank of lieutenant to work STEP enforcement. The form must be submitted to the appropriate TxDOT Project Manager for review and approval. Potential subgrantees may submit the STEP Rank Authorization Form as an attachment to their proposal.

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