6. Proposition 47 and JMHCP Subrecipient Agreement with Justice Innovation, Inc.

AGREEMENT
THIS AGREEMENT, dated for purposes of identification only this 17th day of June, 2025, is made and entered into by and between the CITY OF ANAHEIM, a California municipal corporation and charter city, hereinafter referred to as "ANAHEIM,"

A
N
D

JUSTICE INNOVATION INC., a New York nonprofit corporation, hereinafter referred to as “SUBRECIPIENT.”

ANAHEIM and SUBRECIPIENT are sometimes individually referred to herein as “Party” and collectively as “Parties.”

W I T N E S S E T H:

WHEREAS, ANAHEIM has established a court diversion program named the Anaheim Collaborative Court: Evaluating Strategies & Solutions (“ACCESS”), which aims to assist individuals experiencing homelessness with a co-occurring mental health and/or substance use condition and who are justice involved with the opportunity to be arraigned and connected to housing, health, and mental health services in lieu of serving jail time; WHEREAS, ANAHEIM has been awarded a Proposition 47 grant from the State of California, through the Board of State and Community Corrections (“BSCC”), in order to fund the operation of the ACCESS program (“Program”);
WHEREAS, ANAHEIM has also been awarded a federal Department of Justice grant, the BJA FY24 Justice and Mental Health Collaboration Program grant, by the Office of Justice Programs, in order to fund the operation of the Program; WHEREAS, ANAHEIM and SUBRECIPIENT (each, a “Party” and jointly, the “Parties”) desire to enter into this Agreement in order for SUBRECIPIENT to receive a subgrant

of the Proposition 47 and Department of Justice grant funds (the “Grant Funds”) in consideration of SUBRECIPIENT'S participation in the Program;
WHEREAS, SUBRECIPIENT represents that it is qualified to participate in the Program and has the requisite qualifications, expertise, and experience in the provision of applicable services, and is willing to use the Grant Funds in the operation of the Program; and WHEREAS, SUBRECIPIENT acknowledges and agrees that this Agreement is contingent upon an allocation and receipt of Grant Funds from the grantors and the authorization given to ANAHEIM to use a portion of its allocation in the amount set forth in this Agreement to reimburse SUBRECIPIENT for the provision of services under this Agreement.

NOW THEREFORE, it is agreed by and between the Parties that the foregoing Recitals are a substantive part of this Agreement and the following terms and conditions are approved and, together with all exhibits and attachments hereto, shall constitute the entire Agreement between ANAHEIM and the SUBRECIPIENT:

1. SERVICES TO BE PROVIDED BY SUBRECIPIENT
SUBRECIPIENT shall provide to ANAHEIM the labor, materials, tools, equipment, services, and incidental and customary work necessary to fully and adequately provide services in accordance with the "Scope of Work " attached hereto as Exhibit A and incorporated herein by reference.

2. TERM
The term of this Agreement shall begin on July 1, 2025, and shall end on June 30, 2026. ANAHEIM shall have the option to renew this Agreement for up to two (2) successive one (1) year periods by providing thirty (30) days written notice to SUBRECIPIENT of its intent to renew the Agreement.

3. COMPENSATION

3.1 ANAHEIM shall pay SUBRECIPIENT , for services satisfactorily performed pursuant to this Agreement, pursuant to the rates as identified in the Budget attached hereto as Exhibit B and incorporated herein by reference. SUBRECIPIENT and ANAHEIM

agree that no changes to the Budget shall be made during the term of this Agreement without written agreement of the Parties.

3.2 The Parties agree that the Contract A mount set forth below includes all out-of-pocket expenses of SUBRECIPIENT , with the exception of extraordinary expenses or travel-related costs pre -approved by the City Manager . SUBRECIPIENT shall not be reimbursed for any other expenses.

3.3 It is understood by and agreed between the Parties to this Agreement that full and complete payment for all services pursuant to this Agreement shall not exceed Six Hundred and Forty Thousand Dollars and No/100 Cents ($640,000.00) (“Contract Amount”).

3.4 SUBRECIPIENT shall submit monthly invoices to ANAHEIM for work performed during the billing period. ANAHEIM shall pay SUBRECIPIENT within thirty (30) days after approval of the invoice by ANAHEIM staff.

4. STANDARD OF CARE

4.1 SUBRECIPIENT shall perform all s ervices under this Agreement in a skillful and competent manner, consistent with the standards generally recognized as being employed by professionals in the same discipline in the State of California. SUBRECIPIENT represents and maintains that it is skilled in the professional ca lling necessary to perform the services required by this Agreement. By delivery of completed work, SUBRECIPIENT certifies that the work conforms to the requirements of this Agreement; all applicable federal, state and local laws; and the professional standard of care.

4.2 SUBRECIPIENT represents and warrants to ANAHEIM that it has, shall obtain, and shall keep in full force in effect during the term hereof, at its sole cost and expense, all licenses, permits, qualifications, insurance and approvals of whatsoever nature that is legally required of SUBRECIPIENT to practice its profession.

5. INDEPENDENT CONTRACTOR

5.1 Neither ANAHEIM nor any of its employees shall have any control over the manner, mode or means by which SUBRECIPIENT performs the services required herein,

except as otherwise set forth herein. Except as expressly provided herein, ANAHEIM shall have no voice in the selection, discharge, supervision or control of SUBRECIPIENT or its representatives, contractors, or agents, or in fixing their number, compensation or hours of service. SUBRECIPIENT shall perform all services required herein as an independent contractor of ANAHEIM and shall remain at all times, as to ANAHEIM, a wholly independent contractor with only such obligations as are consistent with that role. SUBRECIPIENT shall not at any time or in any manner represent that it or any of its agents or employees are agents or employees of ANAHEIM. ANAHEIM shall not in any way or for any purpose become or be deemed to be a partner of SUBRECIPIENT in its business or otherwise or a joint venture or a member of any joint enterprise with SUBRECIPIENT.

5.2 In consideration for the compensation paid to SUBRECIPIENT by ANAHEIM, SUBRECIPIENT agrees that ANAHEIM shall not be liable or responsible for any benefits, including, but not limited to, worker’s compensation, disability, retirement, life, unemployment, health or any other benefits, and SUBRECIPIENT agrees that it shall not sue or file a claim, petition or application therefor against ANAHEIM or any of its officers, employees, agents, representatives or sureties.

6. INSURANCE

6.1 Without limiting ANAHEIM's right to indemnification, it is agreed that SUBRECIPIENT shall secure prior to commencing any activities under this Agreement, and maintain during the term of this Agreement, insurance coverage as follows:
.01 Workers' Compensation Insurance as required by California statutes and Employers Liability Insurance in an amount not less than One Million Dollars ($1,000,000.00) per occurrence.
.02 Comprehensive General Liability Insurance, or Commercial General Liability Insurance, including coverage for Premises and Operations, Contractual Liability, Personal Injury Liability, Products/Completed Operations Liability, and Independent Contractors' Liability (if applicable), in an amount of not less than Two Million Dollars

($2,000,000.00) per occurrence, $4,000,000 annual aggregate, written on an occurrence form.

Such insurance shall be written on a primary basis (i.e., without a self -insured retention), but may include a deductible of more than $10,000 per occurrence, provided that such deductible is disclosed to ANAHEIM, in writing, at the inception of this Agreement. .03 Comprehensive Automobile Liability Coverage including- as applicable-owned, non- owned, and hired autos, in an amount not less than $2,000,000 per occurrence, combined single limit, as required by California law. .04 Professional Liability Insurance providing coverage on a claims made basis for errors, omissions or malpractice with limits of not less than two million dollars ($2,000,000.00).

6.2 ANAHEIM's Risk Manager is hereby authorized to reduce the requirements set forth above in the event he or she determines that such reduction is in ANAHEIM's best interest.

6.3 Each insurance policy required by this Agreement shall contain the following clause (or a clause of similar effect):
"This insurance shall not be cancelled, or limited in scope or coverage, until after thirty (30) days' prior written notice has been given to the City Clerk, City of Anaheim, 200 S. Anaheim Blvd., Anaheim, CA 92805."

6.4 Each insurance policy required by this Agreement, excepting policies for workers' compensation and professional liability, shall contain the following clauses (or clauses of similar effect):
"It is agreed that any insurance maintained by SUBRECIPIENT pursuant to this Agreement shall be primary to, and not contributory with, any insurance or self-insurance maintained by the City of Anaheim."
"The City of Anaheim, its officers, agents, employees, representatives, and volunteers are added as additional insureds as respects operations or activities of, or on behalf of the named insured, performed under contract with the City of Anaheim."

6.5 Prior to commencing any work under this Agreement, SUBRECIPIENT shall deliver to ANAHEIM insurance certificates confirming the existence of the insurance required by this Agreement, and including the applicable clauses referenced above. Also, within thirty (30) days of the execution date of this Agreement, SUBRECIPIENT shall provide to ANAHEIM endorsements to the above-required policies, which add to these policies the applicable clauses referenced above. Said endorsements shall be signed by an authorized representative of the insurance company and shall include the signator's company affiliation and title. Should it be deemed necessary by ANAHEIM, it shall be SUBRECIPIENT's responsibility to see that ANAHEIM receives documentation acceptable to ANAHEIM which sustains that the individual signing said endorsements is indeed authorized to do so by the insurance company.

Insurance required hereunder shall be placed with insurers reasonably acceptable to ANAHEIM.

Also, ANAHEIM has the right to demand, and to receive within a reasonable time period, copies of any insurance policies required under this Agreement.

In addition to any other remedies ANAHEIM may have if
SUBRECIPIENT fails to provide or maintain any insurance policies or policy endorsements to the extent and within the time herein required, ANAHEIM may, at its sole option:
.01 Obtain such insurance and deduct and retain the amount of the premiums for such insurance from any sums due under the Agreement; .02 Instruct SUBRECIPIENT to stop work under this Agreement and/or withhold any payment(s) which become due to SUBRECIPIENT hereunder until SUBRECIPIENT demonstrates compliance with the requirements hereof; .03 Terminate this Agreement.

Exercise of any of the above remedies, however, is an alternative to other remedies ANAHEIM may have and is not the exclusive remedy for SUBRECIPIENT's failure to maintain insurance or secure appropriate endorsements.

6.6 Nothing herein contained shall be construed as limiting in any way the extent to which SUBRECIPIENT may be held responsible for payments of damages to persons

or property resulting from SUBRECIPIENT's (or SUBRECIPIENT's contractors/subcontractor's, if any) performance of the work covered under this Agreement.

7. INDEMNIFICATION

7.1 As respects acts, errors or omissions in the performance of professional services, SUBRECIPIENT agrees to indemnify and hold harmless ANAHEIM, its officials, officers, and employees from and against any and all claims, losses, damages, defense costs, or liability, of any kind or nature, arising directly out of SUBRECIPIENT ’s (or SUBRECIPIENT’s contractors’ or subcontractors’, if any) negligent acts, errors or omissions in the performance of professional services under this Agreement.

7.2 As respects all acts, errors or omissions which do not arise directly out of the performance of professional services, including but not limited to those acts, errors or omissions typically covered by ISO -based general and automobile liability insurance coverage, SUBRECIPIENT agrees to indemnify, defend (at ANAHEIM's option), and hold harmless ANAHEIM, its officials, officers, employees, agents, and representatives from and against any and all claims, losses, damages, defense costs, or liability, of any kind or nature (collectively referred to hereinafter as “Claims”), arising out of or in connection with SUBRECIPIENT ’s (or SUBRECIPIENT's contractors’ or subcontractors’, if any) acts, errors, omissions, or work, except for those Claims which arise out of the sole negligence or willful misconduct of ANAHEIM.

8. PROHIBITION AGAINST ASSIGNMENTS AND TRANSFERS
The Parties recognize that a substantial inducement to ANAHEIM for entering into this Agreement is the professional reputation, experience and competence of SUBRECIPIENT. Neither the whole nor any interest in, nor any of the rights or privileges granted under this Agreement shall be assigned, transferred or encumbered in any way without the prior written consent of ANAHEIM. Any such purported assignment, transfer, encumbrance, pledge, subuse, or permission given without such consent shall be void as t o ANAHEIM. If ANAHEIM approves an assignment or transfer, this Agreement and the covenants and

conditions contained herein shall be binding upon and inure to the benefit of and shall apply to the permitted successors and assigns of SUBRECIPIENT.

9. SUBCONTRACTING
SUBRECIPIENT warrants and represents that it shall not use any subcontractor to perform work or services required under this Agreement, unless approved in writing by ANAHEIM.

10. BOOKS AND RECORDS
SUBRECIPIENT shall maintain adequate fiscal and project books, records, documents, and other evidence pertinent to its work on the project in accordance with generally accepted accounting principles. Adequate supporting documentation shall be maintained in sufficient detail to facilitate tracing/tracking transactions from invoices to accounting records, to supporting documentation. Records shall be maintained for a minimum of three (3) years from the acceptance of the final grant project audit , or for any longer period required by law or Proposition 47 grant requirements.

11. ACCESS TO BOOKS AND RECORDS
SUBRECIPIENT agrees to m ake its books, records, supporting documentations, and other evidence available to the BSCC or its designee, the State Controller’s Office, the Department of General Services, the Department of Finance, the California State Auditor, and their designated representatives for a minimum of three (3) years after the end of the Proposition 47 grant period or acceptance of the final Proposition 47 grant project audit by the BSCC , whichever is longer. SUBRECIPIENT further agrees to provide suitable facilities for access ing, monitoring, inspection, and copying of books and records related to the Program, to the extent its work is funded by state grant funds.

12. PROJECT ACCESS
SUBRECIPIENT will ensure that the BSCC, or any authorized representative, will have suitable access to activities, sites, staff, and documents at all reasonable times during the period of the Proposition 47 grant, including those materials maintained by subcontractors.

Access to such records will be made available by both SUBRECIPIENT and any subcontractors for a period of three (3) years following the end of the Proposition 47 grant period.

13. NON-DISCRIMINATION AND CIVIL RIGHTS COMPLIANCE
During the performance of this Agreement, SUBRECIPIENT and its contractors/subcontractors shall not deny the benefits of the Agreement to any person on the basis of race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, or military and veteran status, nor shall they discriminate unlawfully against any employee or applicant for employment because of race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, or military and veteran status. SUBRECIPIENT shall insure that the evaluation and treatment of employees and applicants for employment are free of such discrimination. SUBRECIPIENT and its contractors/ subcontractors shall comply with the provisions of the Fair Employment and Housing Act (Gov. Code §12900 et seq.), the regulations promulgated thereunder (Cal. Code Regs., tit. 2, §11000 et seq.), the provisions of Article 9.5, Chapter 1, Part 1, Division 3, Title 2 of the Government Code (Gov. Code §§11135- 11139.5), and the regulations or standards adopted by the awarding state agency to implement such article.

SUBRECIPIENT shall permit access by representatives of the Department of Fair Employment and Housing and the awarding state agency upon reasonable notice at any time during the normal business hours, but in no case less than 24 hours’ notice, to such of its books, records, accounts, and all other sources of information and its facilities as the Department of Fair Employment and Housing or the awarding state agency shall require to ascertain compliance with this paragraph .

SUBRECIPIENT and its contractors/subcontractors shall give written notice of their obligations under this clause to labor organizations with which they have a collective bargaining or other agreement. (See Cal. Code Regs., tit. 2, §11105.) SUBRECIPIENT shall include the nondiscrimination and compliance provisions of this paragraph in all subcontracts to perform

work under this Agreement.

14. INTELLECTUAL PROPERTY INDEMNITY
SUBRECIPIENT shall defend and indemnify ANAHEIM, its agents, officers, representatives and employees against any and all liability, including costs, for infringement of any United States’ letters patent, trademark, or copyright infringement, including costs, contained in the work product or documents provided by SUBRECIPIENT to ANAHEIM pursuant to this Agreement.

15. WITHHOLDINGS
ANAHEIM may withhold payment to SUBRECIPIENT of any disputed sums until satisfaction of the dispute with respect to such payment. Such withholding shall not be deemed to constitute a failure to pay according to the terms of this Agreement. SUBRECIPIENT shall not discontinue work as a result of such withholding. SUBRECIPIENT shall have an immediate right to appeal to the City Manager or his/her designee with respect to such disputed sums and his/her decision shall be final. SUBRECIPIENT shall be entitled to receive interest on any withheld sums at the rate of return that ANAHEIM earned on its investments during the time period, from the date of withholding of any amounts found to have been improperly withheld.

16. ERRORS AND OMISSIONS
In the event of errors or omissions that are due to the negligence or professional inexperience of SUBRECIPIENT which result in expense to ANAHEIM greater than what would have resulted if there were not errors or omissions in the work accomplished by SUBRECIPIENT, the additional cost and expense shall be borne by SUBRECIPIENT . Nothing in this paragraph is intended to limit ANAHEIM’s rights under the law or any other sections of this Agreement.

17. ANAHEIM'S RIGHT TO EMPLOY OTHER SUBRECIPIENTS
SUBRECIPIENT acknowledges and agrees that this Agreement and the provision of services hereunder are nonexclusive and that ANAHEIM may enter into similar agreements

with other entities for the provision of similar services.

18. CONFLICTS OF INTEREST

18.1 SUBRECIPIENT represents that neither it nor any of its officers, partners or employees has a financial interest, as defined in Section 8 7103 of the Government Code, in the subject matter of this Agreement other than the right to receive payment from ANAHEIM for services rendered.

18.2 SUBRECIPIENT agrees that it shall not make, participate in making, nor in any way attempt to use its position as SUBRECIPIENT to influence any decision of ANAHEIM in which SUBRECIPIENT knows, or has reason to know, that any of its officers, partners or employees has a financial interest as defined in Section 87103 of the Government Code.

18.3 SUBRECIPIENT warrants that neither SUBRECIPIENT nor any of its officers, partners or employees, has any financial interest in any real property, building or structure within 2,500 feet of the location of any project or assignment to which this Agreement may apply in the City of Anaheim. SUBRECIPIENT agrees to disclose to ANAHEIM any financial interest in such property as may be acquired by its officers, partners or employees during the term of this Agreement.

19. NOTICES
All notices, demands or other writings to be made, given or sent hereunder, or which may be so given or made or sent by either ANAHEIM or SUBRECIPIENT to the other shall be deemed to have been given when in writing and personally delivered or if mailed on the third (3rd) day after being deposited in the United States mail, certified or registered, postage prepaid, and addressed to the respective Parties at the following addresses:

ANAHEIM: City of Anaheim
Attention: City Clerk
200 S. Anaheim Boulevard, 2nd Floor
Anaheim, California 92805
FAX No. (714) 765-4105

With copies to: City of Anaheim
Attention: Jennifer Contini
200 S. Anaheim Blvd., 7th Floor
Anaheim, CA 92805
FAX No. (714) 765-5164

SUBRECIPIENT: Justice Innovation Inc.
520 Eighth Avenue
18th Floor
New York, NY 10018
Attention: Matthew Savago
FAX No.: N/A

20. ENFORCEMENT OF AGREEMENT

20.1 Events of Default.
.01 For purposes of this Section 20, the word “Default” shall mean the failure of SUBRECIPIENT to perform any of SUBRECIPIENT ’s duties or obligations or the breach by SUBRECIPIENT of any of the terms and conditions set forth in this Agreement. In addition, SUBRECIPIENT shall be deemed to be in Default upon SUBRECIPIENT ’s (i) application for, consent to, or suffering of, the appointment of a receiver, trustee or liquidator for all or a substantial portion of its assets; (ii) making a general assignment for the benefit of creditors; (iii) being adjudged bankrupt; (iv) filing a voluntary petition or suffering an involuntary petition under any bankruptcy, arrangement, reorganization or insolvency law (unless in the case of an involuntary petition, the same is dismissed within thirty (30) days of such filing); or (v) suffering or permitting to continue unstayed and in effect for fifteen (15) consecutive days any attachment, levy, execution or seizure of all or a substantial portion of SUBRECIPIENT’s assets or of SUBRECIPIENT’s interests hereunder. .02 ANAHEIM shall not be deemed to be in Default in the performance of any obligation required to be performed by ANAHEIM hereunder unless and until ANAHEIM has failed to perform such obligation for a period of thirty (30) days after receipt of written notice from SUBRECIPIENT specifying in reasonable detail the nature and extent of any such failure; provided, however, that if the nature of ANAHEIM’s obligation is such that more than thirty (30) days are required for its performance, then ANAHEIM shall not

be deemed to be in Default if ANAHEIM shall commence to cure such performance within such thirty (30) day period and thereafter diligently prosecute the same to completion.

20.2 Immediate Termination for SUBRECIPIENT ’s Default. In the event of any Default by SUBRECIPIENT, ANAHEIM may immediately terminate this Agreement. Such termination shall be effective immediately upon receipt by SUBRECIPIENT of written notice from ANAHEIM. In such event, SUBRECIPIENT shall have no further rights hereunder, and ANAHEIM shall have all other rights and remedies as provided by law.

20.3 Termination Without Cause. Either of the Parties may terminate this Agreement at any time without the necessity of cause or Default by giving sixty (60) days written notice to the other Party.

21. COMPLIANCE WITH ALL LAWS
SUBRECIPIENT shall at its own cost and expense comply with all statutes, ordinances, regulations and requirements of all governmental entities, including federal, state, county or municipal, whether now in force or hereinafter enacted, and including, but not limited to, the laws and regulations that prohibit the use of public funds for campaign activities or personal use. In addition, all work prepared by SUBRECIPIENT shall conform to applicable local, county, state and federal laws, rules, regulations and permit requirements and be subject to approval of the City Manager.

22. WAIVER
A waiver by either Party of any breach, of any term, covenant or condition contained herein shall not be deemed to be a waiver of any subsequent breach of the same or any other term, covenant or condition contained herein, whether of the same or a different character.

23. INTEGRATED CONTRACT
This Agreement and the exhibits hereto contain the entire agreement of ANAHEIM and SUBRECIPIENT with respect to the matters covered hereby, and no agreement, statement or promise made by either ANAHEIM or SUBRECIPIENT which is not contained herein, shall be valid or binding. No prior agreement, understanding or representation pertaining

to any such matter shall be effective for any purpose.

24. CONFLICTS OR INCONSISTENCIES
In the event there are any conflicts or inconsistencies between this Agreement and Exhibit A-C, or any other documents attached hereto, the terms of this Agreement shall govern.

25. INTERPRETATION
Each Party acknowledges that he/she/it has had the benefit of advice of competent legal counsel with respect to its decision to enter this Agreement. The provisions of this Agreement shall be interpreted to give effect to their fair meaning and shall be construed as prepared by both Parties.

26. AMENDMENTS
This Agreement may be modified or amended only by a written document executed by both SUBRECIPIENT and ANAHEIM and approved as to form by the City Attorney.

27. SEVERABILITY
If any term or provision of this Agreement or the application thereof to any person or circumstance shall, to any extent, be held invalid or unenforceable, the remainder of this Agreement, or the application of its terms and provisions to persons and circumstances other than those to which it has been held invalid or unenforceable shal l not be affected thereby, and each term and provision of this Agreement shall be valid and enforceable to the fullest extent permitted by law.

28. REMEDIES CUMULATIVE
The remedies given to ANAHEIM and SUBRECIPIENT herein shall be cumulative and are given without impairing any other rights given ANAHEIM or SUBRECIPIENT by statute or law now existing or hereafter enacted and the exercise on any one (1) remedy by ANAHEIM or SUBRECIPIENT shall not exclude the exercise of any other remedy.

29. NO THIRD PARTY BENEFICIARIES
The Parties intend that neither rights nor remedies be granted to any third party as a beneficiary of this Agreement or of any covenant, duty, obligation or undertaking established herein.

30. COMPLIANCE WITH FEDERAL GRANT REQUIREMENTS
SUBRECIPIENT represents and agrees that it will comply with each and all of the terms and conditions set forth in the Department of Justice Grant Agreement and Award Letter attached hereto as Exhibit C, including Award Conditions 1-53.

31. CONTROLLING LAW AND VENUE
The laws of the State of California shall govern this Agreement and all matters relating to it and any action brought relating to this Agreement shall be adjudicated in a court of competent jurisdiction in the County of Orange.

32. AUTHORITY
Each individual executing this Agreement on behalf of a corporation, nonprofit corporation, partnership or other entity or organization, represents and warrants that it or she is duly authorized to execute and deliver this Agreement on behalf of such entity or organization and that this Agreement is binding upon the same in accordance with its terms.

SUBRECIPIENT shall, at ANAHEIM’s request, deliver a certified copy of its governing board’s resolution or certificate authorizing or evidencing such execution.

33. EFFECTIVE DATE
This Agreement shall be effective on July 1, 2025 (“Effective Date”).

[SIGNATURES ON FOLLOWING PAGE]

IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed on the dates hereinafter respectively set forth.

DATE OF EXECUTION:

CITY OF ANAHEIM
a municipal corporation

By:

Grace Ruiz-Stepter
Director, Housing and Community
Development Department

ATTEST:

THERESA BASS, CITY CLERK

By: _
City Clerk of Anaheim

APPROVED AS TO FORM:

By:

Kristin Pelletier
Chief Assistant City Attorney, Civil

DATE OF EXECUTION:

JUSTICE INNOVATION INC., a New York
nonprofit corporation

By:

Title: Chief Financial Officer
Printed Name: Matthew Savago

Center for Justice Innovation

EXHIBIT A - SCOPE OF WORK
Proposition 47 and DOJ

Data Collection Processes and Evaluation for Anaheim City Attorney ACCESS Program

Background

The Center for Justice Innovation (the Center) works to achieve justice and equity; create safe, healthy, and thriving communities; and ultimately transform justice systems. The Center does this by integrating new thinking and creative practices through its numerous operating projects in New York, New Jersey, and California; rigorous research and data analytics; and implementation assistance and policy guidance to communities and justice practitioners nationally and internationally.

The ACCESS program, launched in January 2022 in collaboration with the Orange County Superior Court and Public Defender, is a prosecution-led misdemeanor pre-trial diversion initiative aimed at homeless individuals with mental health or co-occurring mental health and substance use disorders, offering them access to community resources and treatment. By utilizing a multidisciplinary team and a personalized treatment approach, ACCESS seeks to provide meaningful intervention, improve outcomes, and foster a cultural shift within the local justice system, with the goal of expanding the program through increased funding and a comprehensive evaluation. Flourishing at the intersection of multi-partner collaboration, the Center’s significant experience cultivating and implementing comprehensive programs makes the Center an ideal partner for this project. The Center is well-postured to provide additional support due to our role as consultants during the pilot phase of the ACCESS program.

Throughout this process, the Center conducted training on needs assessment tools like the C- CAT and met regularly with the program manager to guide program and data development.

One of the most pressing concerns for ACCESS is the need for rigorous and standardized data collection that will ensure program credibility, sustainability, and impact. Ultimately, the goal is an evaluation of ACCESS that can demonstrate the impact the program has had in Anaheim and suggest how similar models can be adapted and adopted elsewhere. The Center will work with the City Attorney’s Office throughout the evaluation process, from laying the groundwork for quality data collection to completing a local level process and impact evaluation. The Center will also help address immediate data concerns, including monitoring progress toward the goals of program expansion and measuring impact on both housing and criminal justice outcomes.

Routine data analysis can ensure that a program operates effectively and efficiently and identify potential problems before they become fatal flaws. The Center will work with ACCESS to not only ensure rigorous and quality data collection but also that this data is used meaningfully throughout the life of this program.

Goals
The overarching goal of this collaboration is to strengthen ACCESS’s internal data collection process, establish performance measures, and conduct an evaluation. To achieve this, the Center will engage in four phases of work culminating in both a process and outcome evaluation after three years of program refinement and data preparations.

Proposed Activities and Timeline
Initial Planning (January 2025 – June 2025)

1. Draft Local Evaluation Plan – Produce a preliminary written document that describes the proposed process and outcome evaluations, including a plan for data collection and management, and final analysis, along with a logic model.

2. Initiate Process Map Protocol - Create infrastructure for process mapping by identifying and understanding case processes, including priority data points and ongoing internal data collection dialogue within the Anaheim City Attorney’s office.

3. Cultivate Relationships with Local ACCESS Stakeholders - The Center will develop relationships with local ACCESS stakeholders by hosting regular check-in meetings with this group.

Theory of Change (July 2025- December 2025)

4. Data Use Agreement – Draft and submit a Data Use Agreement between the Center and Anaheim’s City Attorney’s Office.

5. Workshop – The Center will host an in-person two-day intensive theory of change workshop on-site that will leverage the Center’s expertise to provide information regarding strategic planning, creating and articulating a theory of change, and logical modeling to prepare the Anaheim City Attorney’s Office best to execute their time task plan for the grant.

6. Court Observation to Finalize a Process Map – The Center will work closely with ACCESS staff and stakeholders to produce a comprehensive case flow for typical access cases.

7. Prepare the Logic Model – Building on the information gained at the workshop, the Center will prepare a draft of the logic model. The logic model process involves several rounds of feedback from all relevant stakeholders before it can be agreed upon. The Center will facilitate these feedback sessions with stakeholders identified by the City Prosecutor’s Office after remote or in-person introductions. The logic model will serve as the basis for an informal process evaluation of ACCESS to ensure that interventions are implemented as intended.

8. Refine Local Evaluation Plan – Based on the information gathered in the theory of change workshops, and through court observation, the Center will revise its evaluation plans to make sure that the evaluation adequately reflects the current goals and impacts of the ACCESS program. If additional data sources are identified as being useful, the Center will begin the process of acquiring the necessary partnerships and agreements.

Data Infrastructure and Implementation (Jan 2026 – June 2026)

9. Finalize Data Points and Performance Measures – Building on the stated inputs, activities, and outcomes identified in the logic model, the Center will work with ACCESS to ensure that there is a plan to collect all relevant data points and to use this data to describe programmatic success. More specifically, the Center will advise on the development and implementation of a client satisfaction survey. This will build the capacity of ACCESS to supplement administrative records with client feedback while establishing data collection protocols that will be used as part of the Center’s evaluation.

10. Advise on Data Auditing and Routine Data Management – Complete and accurate data is paramount to the success of this project and ACCESS as a whole. The Center will work with ACCESS staff to identify what data is routinely missing and how it can be identified and corrected. The Center will draft a standard operating procedure document for data management that will describe this process in the future.

11. Establish Procedures for Ongoing Data Analysis - The Center will train program staff on basic data analysis needed to routinely take stock of program successes and challenges.

Process Evaluation Data Collection (July 2026 – December 2026)

12. Conduct a Local Policy and Media Scan – The Center will document relevant policy shifts that have happened at the city, county, and state levels to document the broader ecosystem in which ACCESS functions. Policy analysis will be supplemented by local media scans to document community needs. This will provide context for understanding the goals of ACCESS and help identify potential explanations for any shifts in program inputs or activities.

13. Review Programmatic Documents - The Center will work with program staff to collect supporting programmatic documents related to diversion (i.e., referral forms, diversion agreements), resources (i.e., grant proposals or reporting), and operations (i.e., organizational charts). Many of these documents will be gathered during the earlier phase of the work to inform the theory of change. However, their role in the process evaluation will be to document how program inputs, activities, and outputs have changed during implementation.

14. Begin Qualitative Interviews with Stakeholders – The Center will interview key partners to better understand their perception of goals, strengths, successes, and room for improvement. These interviews will be conducted as part of a site visit, with remote interviews offered as needed. The Center will work with a designated local point of contact to convene interviewees for interviews that will last approximately one hour. The Center will use a semi-structured interview protocol to standardize data collection across interviewees, with researchers capturing detailed notes. The interview protocols will be tailored to each stakeholder’s role, with domains informed by the theory of change. This will allow us to compare the extent to which there is fidelity to the program model and consistency across stakeholders.

15. Begin Focus Groups with Program Participants – The Center will conduct focus groups with former and active ACCESS participants to understand their perceptions of the program. The focus groups will be conducted during the site visit and will also utilize a semi-structured protocol informed by the ACCESS theory of change with specific emphasis upon understanding how clients experienced the activities, outputs, and outcomes. The Center will work with program stakeholders to devise a recruitment strategy that will allow us to verify that focus group participants have been ACCESS participants. This may include direct outreach from ACCESS staff, posting fliers in spaces frequented by participants, and cross-referencing those who sign up against ACCESS records, or actively recruiting upon the conclusion of an ACCESS hearing. The Center will work with the local point of contact to identify a private location to conduct the interviews, depending on the recruitment strategy.

Focus groups will last approximately one hour, and participants will receive a $60 incentive. With participants’ permission, focus groups will be recorded for the purposes of transcription. The focus groups will help identify how participants engage in activities as well as how they define and experience outcomes related to success and failure.

16. Analyze Program Data – The Center will work with program staff to analyze existing program data to assess its completeness and spot-check for accuracy. The Center will also calculate basic descriptive statistics that can help ACCESS understand its program and participants. Insight into the reach of the program will be measured using data maintained by the City Attorney’s office to describe characteristics of individuals who encountered the program (e.g., demographics, charges, open cases, etc.) broken down by their program status (e.g., assessed, declined, enrolled, graduated, noncompliant). The Center will also capture measures related to the dosage of ACCESS via analysis of case management records maintained by community partners. This will also include basic descriptive analysis of the client satisfaction surveys referenced above once a large enough sample has accumulated (n = 50).

Outcome Evaluation (Jan 2027 – June 2028)

17. Qualitative Analysis – The Center will analyze qualitative data sources collected during the prior period to describe general themes and findings. Detailed notes from stakeholder interviews and observations will be analyzed thematically to help develop a detailed description of the ACCESS model and how it has evolved over time (e.g., planning, initial implementation, lessons learned). Focus groups with current and former clients will be transcribed, coded, and analyzed to identify patterns in responses across types of individuals (e.g., gender, race, ethnicity, and age) and focus group domain (e.g., service engagement, successes, challenges).

To augment the qualitative findings, descriptive statistics of closed-ended questions or structured observation data will be performed. Finally, we may cull de-identified direct quotes from interviews and focus groups to add depth to the process evaluation findings.

18. Outcome Analysis – The Center will conduct a within-subject analysis of changes in participants’ housing, employment, benefits, and contact with law enforcement, comparing status at program start, during programming, and post-programming.

The analysis will also analyze differences in program completers and program non- completers. If earlier activities facilitate the identification of a comparison group and the sample size is sufficient, the Center will apply propensity score matching techniques to test the impact of ACCESS on criminal legal system outcomes (e.g., re-arrest, conviction, charge type).

19. Final Report and Recommendations - Center staff will present preliminary findings to the Anaheim City Attorney’s office throughout the process, with a final cumulative presentation representing findings from the evaluation. Findings will be summarized in a final written report that fulfills the requirements for the Prop 47 local evaluation report.

20. Strategic Session on Recommendation Implementation - The Center will offer a strategic session with the Anaheim City Attorney’s office and ACCESS stakeholders on implementing proposed findings of the final report.

Proposed Site Engagement: The Center will meet with the Anaheim City Attorney’s office regularly to perform the aforementioned activities. Additionally, the Center proposes an annual meeting with the site team and stakeholders to assess achievements and identify additional areas for support.

Written deliverables will include a process map, logic model, and data collection forms and processes related to the referral process and participant progress reports.

To comply with State of California Proposition 47 funding, a Local Evaluation Plan (LEP) will be produced by March 31, 2025, that describes the proposed process and outcome evaluations, logic model, data collection, management, analysis, and the reporting plan that will be implemented. Towards the end of the project period, a Local Evaluation Report (LER) will be produced by June 30, 2028, that describes the findings and interpretations of the process and outcome evaluations; an updated logic model; and interpretation of various data elements; and the evaluation of the project’s goals and objectives.

Budget
The total budget for this proposed work is $640,000 over 3.5 years. A budget worksheet to support the required staffing is attached.

Capacity
Darcy Hauslik, PhD, Associate Director of Data Analytics and Applied Research, Center for Justice Innovation
Darcy Hauslik is the Associate Director of ATI and Diversion on the Data Analytics and Applied Research team at the Center for Justice Innovation (CJI). Darcy oversees the data collection and reporting for the Center’s New York City and Newark, New Jersey based Alternative to Incarceration and Diversion programming. Darcy’s portfolio includes technical assistance on a range of data-related topics, including data collection, reporting, communication, and management to a variety of jurisdictions, most recently, LA’s newly formed Alternative to Incarceration Initiative. Additionally, a mixed methodologist by training, she has brought that expertise to multiple evaluations, including an analysis of the supports available to those who have lost loved ones to gang violence or intrafamilial violence in the Bronx. She is currently the Principal Investigator for an evaluation of Bronx Reset, a restorative justice diversion program designed to keep low-level offenses out of the court system. Darcy received her PhD in Sociology from Washington State University.

Tia Strozier, Associate Director of Community Justice Center or Justice Innovation, Los Angeles, CA
Tia Strozier currently serves as the Associate Director of Policy and Practice for the Community Justice Technical Assistance team at the Center for Justice Innovation (CJI). In this role, she works with the local criminal justice community and system partners to develop and implement equitable, impactful alternatives to traditional prosecution, policing, and policymaking.

Incorporating her insights as a former misdemeanor prosecutor with the Los Angeles City Attorney’s office, Ms. Strozier uses technical assistance to support jurisdictions across the country as they tell a new story about their local criminal justice system. Serving both as a calendar court deputy and community prosecutor, she has experience managing a caseload of varied misdemeanor charges and working collaboratively with community, city, and county government representatives, and law enforcement to address quality of life issues in the Downtown and South Los Angeles neighborhoods. In her pursuit to promote legal literacy, Ms.

Strozier has hosted multiple public safety summits highlighting the expertise of system and policy partners. She also co-created Community Vision Conversations, a facilitated dialogue designed to spark systemic reform while prioritizing comprehensive community healing following George Floyd’s death. Ms. Strozier graduated with a Bachelor of Arts in Sociology from Hampton University and earned her Juris Doctorate from Indiana University - Maurer School of Law.

Brett Taylor, Senior Advisor, Center for Justice Innovation

Brett Taylor is the Senior Advisor for the Center for Justice Innovation's West Coast Initiatives. He formerly was the Center’s Deputy Director of National Technical Assistance and the Director of Operations for the Center's Tribal Justice Exchange. Brett currently provides technical
assistance to the MacArthur Foundation’s Safety and Justice Challenge Los Angeles site. He also works with numerous states, cities, and tribes on creating justice system strategic plans and needs assessments. He has been the lead planner on several community courts across the country. Brett was an original planner of the Red Hook Peacemaking Program that launched in 2013. He was an attendance court hearing officer at P.S. 27 in Brooklyn from 2007-2010.

Before joining the Center in 2007, Brett was the senior defense attorney for more than six years at the Red Hook Community Justice Center in Brooklyn, NY, and was a senior trial attorney for the Legal Aid Society in Brooklyn for the previous 10 years. From 2000-2015, he was an organizer and coach in the Red Hook Youth Baseball League. He was also a Red Hook Youth Court trainer. Brett holds a B.A. from the University of Pittsburgh and a J.D. from the University of Pittsburgh School of Law.

Jennifer A. Tallon, Director of Research-Practice Strategies, Center for Justice Innovation

Jennifer A. Tallon is the Director of Research-Practice Strategies and has ten years of experience leading mixed-methods program evaluations. Jennifer is currently the principal investigator/Co-PI on three NIJ-funded evaluations, including an implementation and outcome evaluation of a law enforcement led booking diversion program in Los Angeles County. Previously, Jennifer oversaw an exploratory research study on prosecutorial decision making in cases involving violence and an evaluation of the District Attorney of New York’s Intelligence Driven Prosecution model. Jennifer earned her PhD in Psychology from the City University of New York Graduate Center with a concentration in Psychology and the Law.

Viet Nguyen, Associate Director of Research-Practice Strategies, Center for Justice Innovation

Viet Nguyen is the Associate Director of Research-Practice Strategies. Prior to joining the Center, Viet served as a post-doctoral research fellow embedded within the Philadelphia District Attorney’s Office and a research associate at the Public Policy Institute of California.

He has worked extensively with administrative data throughout his career. Viet is currently leading a quasi-experimental impact evaluation of a holistic defense model that leverages random case assignment to court appointed attorneys. Additionally, Viet is working with the California Office of the State Public Defender to develop data improvements in three rural public defense systems and is working in San Mateo County to develop a benchmarking system for managed assigned counsel attorneys. Viet’s prior research utilizes econometrics and advanced statistics to understand the trade-offs of different criminal justice policies with a primary focus on court policies that involve judges, prosecutors, and defense attorneys. Viet earned his PhD in criminology and MA in statistics from the University of Pennsylvania.

Sruthi Naraharisetti, Senior Research Associate, Center for Justice Innovation

Sruthi Naraharisetti is a Senior Research Associate on the Research-Practice Strategies team. Currently, Sruthi is leading a mixed-methods process evaluation of a holistic defense model (that includes interviews with former public defense clients) and a five-site process evaluation of juvenile resentencing initiatives. Prior to this work, Sruthi helped lead case study data collection on a national study examining how prosecutors use alternatives to incarceration in cases involving violence. Before joining the Center, Sruthi worked with Poverty Solutions at the University of Michigan, where she conducted mixed-methods research focusing on racial, economic, and criminal justice and provided data-driven technical assistance to governmental entities and non-profits. Sruthi holds a Master’s in Public Policy and a Master’s in Social Work from the University of Michigan, and a Bachelor’s in Social Relations and Policy from Michigan State University.

Danielle Reynolds, Principal Research and Data Associate Center for Justice Innovation;

Danielle Reynolds is a Principal Research and Data Associate on the Data Analytics and Applied Research team at the Center for Justice Innovation (CJI). Danielle oversees the data collection, reporting, and research for the Center’s Alternative to Incarceration (ATI) programs serving cases from the Supreme Court, mental health courts, and those utilizing restorative responses. Danielle has 10 years of experience conducting program evaluation and mixed methods research. Danielle served as a PI on a program assessment of Manhattan’s Felony ATI Court and a process evaluation of Albany’s Law Enforcement Assisted Diversion (LEAD) Program serving individuals in frequent contact with the justice system with mental health and substance use needs. She recently completed an impact evaluation of the Center’s Driver Accountability Program. Danielle received her PhD in Criminal Justice from Albany University.

Budget Category Year One Year Two Year Three 6 Month Budget Total 1 Personnel 70,270$ 103, 970$ 109, 481$ 57, 868$ 342, 201$ 2 Travel 6,624$ 6, 624$ 6, 624$ 19, 260$
3 Incentive 1,200$ 1, 200$
4 Transcription Services 975$ 975$
5 Indirect Costs 7,689$ 11, 179$ 11, 708$ 5, 787$ 36, 364$ TOTAL PROJECT COST 84,584$ 122,973$ 128, 788$ 63, 655$ 400, 000$ Prop 47
Justice Innovation Inc
Anaheim Collaborative Court – Evaluating Strategies and Solutions (ACCESS) Exhibit B - Budget
Budget Category Year One Year Two Year Three Year Four Total 1 Personnel 39,480$ 40,615$ 41,058$ 17,220$ 138,372$ 2 Fringe Benefits 12,634$ 12,997$ 13,138$ 5,510$ 44,279$ 3 Supplies 210$ 210$ 206$ 84$ 710$
4 Office 4,345$ 4,412$ 4,403$ 1,827$ 14,986$
5 Indirect Costs 11,900$ 12,229$ 12,349$ 5,175$ 41,653$ TOTAL PROJECT COST 68,569$ 70,463$ 71,154$ 29,816$ 240,000$ US Department of Justice
Bureau of Justice Assistance/Board of State and Community Corrections in California Justice Innovation Inc.

Anaheim Collaborative Court – Evaluating Strategies and Solutions (ACCESS) Exhibit B - Budget
Department of Justice (DOJ)
Office of Justice Programs
Bureau of Justice Assistance
Washington, D.C. 20531
Name and Address of Recipient: CITY OF ANAHEIM
201 S ANAHEIM BLVD
City, State and Zip: ANAHEIM, CA 92805
Recipient UEI: J34GBL8PSNU5
Project Title: Anaheim Collaborative Court -
Evaluating Strategies and Solutions Award Number: 15PBJA-24-GG-01967-MENT Solicitation Title: BJA FY24 Justice and Mental Health Collaboration Program Federal Award Amount: $550,000.00 Federal Award Date: 9/23/24 Awarding Agency: Office of Justice Programs
Bureau of Justice Assistance
Funding Instrument Type: Grant
Opportunity Category: D
Assistance Listing:

16.745 - Criminal and Juvenile Justice and Mental Health Collaboration Program Project Period Start Date: 10/1/24 Project Period End Date: 9/30/27 Budget Period Start Date: 10/1/24 Budget Period End Date: 9/30/27 Project Description:

In January 2022, with the support of the Orange County Superior Court and Public Defender, the Anaheim City Attorney launched the Anaheim Collaborative Court-Evaluating Strategies and Solutions (ACCESS), a prosecution led, misdemeanor pre-trial diversion program designed for homeless individuals suffering from mental health disorders or co-occurring mental health and substance use disorders. The purpose of ACCESS is to connect the Court with community resources so that our system of justice may support, rather than undermine, the stability and sobriety of those whose criminality is inextricably intertwined with their disease and housing insecurity.

The heart of ACCESS is the multidisciplinary courtroom team consisting of a Judge, Prosecutor, Public Defender, Clinician, Peer Lead and Coordinator. In order to sustain and expand ACCESS, the Anaheim City Attorney is seeking federal assistance to fund critical programmatic components that lack immediate resource streams. Federal funds will enable ACCESS to scale up courtroom assessments and contract with the Center for Justice Innovation to inform data collection in anticipation of an exhaustive program evaluation which may inform system change for the entire Orange County Justice system and beyond. There are no planned conference activities for the recommended award.

Page: 1 of 20
Exhibit C
Award Letter
September 23, 2024
Dear Linda Ly,

On behalf of Attorney General Merrick B. Garland, it is my pleasure to inform you the Office of Justice Programs (OJP) has approved the application submitted by CITY OF ANAHEIM for an award under the funding opportunity entitled 2024 BJA FY24 Justice and Mental Health Collaboration Program. The approved award amount is $550,000.

Review the Award Instrument below carefully and familiarize yourself with all conditions and requirements before accepting your award. The Award Instrument includes the Award Offer (Award Information, Project Information, Financial Information, and Award Conditions) and Award Acceptance. For COPS Office and OVW funding the Award Offer also includes any Other Award Documents.

Please note that award requirements include not only the conditions and limitations set forth in the Award Offer, but also compliance with assurances and certifications that relate to conduct during the period of performance for the award. These requirements encompass financial, administrative, and programmatic matters, as well as other important matters (e.g., specific restrictions on use of funds). Therefore, all key staff should receive the award conditions, the assurances and certifications, and the application as approved by OJP, so that they understand the award requirements. Information on all pertinent award requirements also must be provided to any subrecipient of the award.

Should you accept the award and then fail to comply with an award requirement, DOJ will pursue appropriate remedies for non-compliance, which may include termination of the award and/or a requirement to repay award funds.

Prior to accepting the award, your Entity Administrator must assign a Financial Manager, Grant Award Administrator, and Authorized Representative(s) in the Justice Grants System (JustGrants). The Entity Administrator will need to ensure the assigned Authorized Representative(s) is current and has the legal authority to accept awards and bind the entity to the award terms and conditions. To accept the award, the Authorized Representative(s) must accept all parts of the Award Offer in the Justice Grants System (JustGrants), including by executing the required declaration and certification, within 45 days from the award date.

To access your funds, you will need to enroll in the Automated Standard Application for Payments (ASAP) system, if you haven’t already completed the enrollment process in ASAP. The Entity Administrator should have already received an email from ASAP to initiate this process.

Congratulations, and we look forward to working with you.

Brent J. Cohen
Acting Assistant Attorney General
Office for Civil Rights Notice for All Recipients
The Office for Civil Rights (OCR), Office of Justice Programs (OJP), U.S. Department of Justice (DOJ) enforces federal civil rights laws and other provisions that prohibit discrimination by recipients of federal financial assistance from OJP, the Office of Community Oriented Policing Services (COPS), and the Office on Violence Against Women (OVW).

Several civil rights laws, including Title VI of the Civil Rights Act of 1964 and Section 504 of the Rehabilitation Act of 1973, require recipients of federal financial assistance (recipients) to give assurances that they will comply with those laws. Taken together, these and other civil rights laws prohibit recipients from discriminating in the provision of services and employment because of race, color, national origin, religion, disability, and sex or from discriminating in the provision of services on the bases of age.

Some recipients of DOJ financial assistance have additional obligations to comply with other applicable nondiscrimination provisions like the Omnibus Crime Control and Safe Streets Act of 1968, which prohibits discrimination on the basis of religion in addition to race, color, national origin, and sex. Recipients may also have related requirements regarding the development and implementation of equal employment opportunity programs.

OCR provides technical assistance, training, and other resources to help recipients comply with civil rights obligations.

Page: 2 of 20
Further, OCR administratively enforces civil rights laws and nondiscrimination provisions by investigating DOJ recipients that are the subject of discrimination complaints. In addition, OCR conducts compliance reviews of DOJ recipients based on regulatory criteria. These investigations and compliance reviews permit OCR to evaluate whether DOJ recipients are providing services to the public and engaging in employment practices in a nondiscriminatory manner.

For more information about OCR, your civil rights and nondiscrimination responsibilities, how to notify your employees or beneficiaries of their civil rights protections and responsibilities and how to file a complaint, as well as technical assistance, training, and other resources, please visit www.ojp.gov/program/civil-rights-office/outreach. If you would like OCR to assist you in fulfilling your civil rights or nondiscrimination responsibilities, please contact us at askOCR@o jp.usdoj.govor www.ojp.gov/program/civil-rights-office/about#ocr-contacts.

Memorandum Regarding NEPA
NEPA Letter Type
OJP - Categorical Exclusion
NEPA Letter
None of the following activities will be conducted whether under the Office of Justice Programs federal action or a related third party action:
(1) New construction
(2) Any renovation or remodeling of a property located in an environmentally or historically sensitive area, including property (a) listed on or eligible for listing on the National Register of Historic Places, or (b) located within a 100-year flood plain, a wetland, or habitat for an endangered species (3) A renovation that will change the basic prior use of a facility or significantly change its size (4) Research and technology whose anticipated and future application could be expected to have an effect on the environment
(5) Implementation of a program involving the use of chemicals (including the identification, seizure, or closure of clandestine methamphetamine laboratories)
Additionally, the proposed action is neither a phase nor a segment of a project that when reviewed in its entirety would not meet the criteria for a categorical exclusion.

Consequently, the subject federal action meets the Office of Justice Programs' criteria for a categorical exclusion as contained in paragraph 4(b) of Appendix D to Part 61 of Title 28 of the Code of Federal Regulations.

Questions about this determination may be directed to your grant manager or Orbin Terry, Environmental Coordinator for the Bureau of Justice Assistance.

NEPA Coordinator
First Name
Orbin Middle Name Last Name
Terry
Award Information
This award is offered subject to the conditions or limitations set forth in the Award Information, Project Information, Financial Information, and Award Conditions.

Recipient Information
Recipient Name

CITY OF ANAHEIM
Page: 3 of 20
UEI
J34GBL8PSNU5
Street 1
201 S ANAHEIM BLVD Street 2
City

ANAHEIM
State/U.S. Territory
California
Zip/Postal Code
92805
Country
United States
County/Parish
no value
Province
no value
Award Details
Federal Award Date
9/23/24
Award Type
Initial
Award Number
15PBJA-24-GG-01967-MENT
Supplement Number
00 Federal Award Amount
$550,000.00
Funding Instrument Type
Grant
Assistance Listing
Number
Assistance Listings Program Title

16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program Statutory Authority
Public Law No. 90-351, Title I, Sec. 2991 (codified at 34 U.S.C. 10651); (Public Law No. 117-103, 136 Stat. 49, 127).

Any awards under this solicitation would be made under statutory authority provided by the Consolidated Appropriations Act, 2024. As of the writing of this solicitation, the Department of Justice is operating under a short- term Continuing Resolution with no full-year appropriation for the Department being enacted for FY 2024 currently. [ ] I have read and understand the information presented in this section of the Federal Award Instrument.

Project Information
This award is offered subject to the conditions or limitations set forth in the Award Information, Project Information, Financial Information, and Award Conditions.

Solicitation Title
2024 BJA FY24 Justice and Mental Health Collaboration
Program
Application Number
GRANT14128792
Awarding Agency
OJP
Program Office
BJA
Page: 4 of 20
Grant Manager
Ivette Ruiz
Phone Number
202-353-5423
E-mail Address
[email protected]
Project Title
Anaheim Collaborative Court - Evaluating Strategies and Solutions Performance Period Start
Date
10/01/2024
Performance Period End Date
09/30/2027
Budget Period Start Date
10/01/2024
Budget Period End Date
09/30/2027
Project Description
In January 2022, with the support of the Orange County Superior Court and Public Defender, the Anaheim City Attorney launched the Anaheim Collaborative Court-Evaluating Strategies and Solutions (ACCESS), a prosecution led, misdemeanor pre-trial diversion program designed for homeless individuals suffering from mental health disorders or co-occurring mental health and substance use disorders. The purpose of ACCESS is to connect the Court with community resources so that our system of justice may support, rather than undermine, the stability and sobriety of those whose criminality is inextricably intertwined with their disease and housing insecurity.

Note: This project contains a research and/or development component, as defined in applicable law. See Part 200 Uniform Requirements.
[ ] I have read and understand the information presented in this section of the Federal Award Instrument.

Financial Information
This award is offered subject to the conditions or limitations set forth in the Award Information, Project Information, Financial Information, and Award Conditions.

The recipient budget is currently under review.
[ ] I have read and understand the information presented in this section of the Federal Award Instrument.

Award Conditions
This award is offered subject to the conditions or limitations set forth in the Award Information, Project Information, Financial Information, and Award Conditions.

Condition 1
Meaningful access requirement for individuals with limited English proficiency Page: 5 of 20
The recipient, and any subrecipient at any tier, must take reasonable steps to ensure that individuals with limited English proficiency (LEP) have meaningful access to their programs and activities to comply with Title VI of the Civil Rights Act of 1964 (Title VI), which prohibits discrimination on the basis of national origin, including discrimination against individuals with LEP. Such steps may require providing language assistance services, such as interpretation or translation services. The Department of Justice guidance on compliance with this requirement may be found at "Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons" (67 Fed. Reg. 41455-41472) (https:// www.federalregister.gov/d/02-15207) and is incorporated by reference here.

Condition 2
Compliance with general appropriations-law restrictions on the use of federal funds (FY 2024) The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable restrictions on the use of federal funds set out in federal appropriations statutes. Pertinent restrictions that may be set out in applicable appropriations acts are indicated at https://ojp.gov/funding/Explore/FY24AppropriationsRestrictions.htm, and are incorporated by reference here.

Should a question arise as to whether a particular use of federal funds by a recipient (or a subrecipient) would or might fall within the scope of an appropriations-law restriction, the recipient is to contact OJP for guidance, and may not proceed without the express prior written approval of OJP.

Condition 3
Requirements of the award; remedies for non-compliance or for materially false statements The conditions of this award are material requirements of the award. Compliance with any assurances or certifications submitted by or on behalf of the recipient that relate to conduct during the period of performance also is a material requirement of this award.

Limited Exceptions. In certain special circumstances, the U.S. Department of Justice ("DOJ") may determine that it will not enforce, or enforce only in part, one or more requirements otherwise applicable to the award. Any such exceptions regarding enforcement, including any such exceptions made during the period of performance, are (or will be during the period of performance) set out through the Office of Justice Programs ("OJP") webpage entitled "Legal Notices:

Special circumstances as to particular award conditions" (ojp.gov/funding/Explore/LegalNotices-AwardReqts.htm), and incorporated by reference into the award.

By signing and accepting this award on behalf of the recipient, the authorized recipient official accepts all material requirements of the award, and specifically adopts, as if personally executed by the authorized recipient official, all assurances or certifications submitted by or on behalf of the recipient that relate to conduct during the period of performance.

Failure to comply with one or more award requirements -- whether a condition set out in full below, a condition incorporated by reference below, or an assurance or certification related to conduct during the award period -- may result in OJP taking appropriate action with respect to the recipient and the award. Among other things, the OJP may withhold award funds, disallow costs, or suspend or terminate the award. DOJ, including OJP, also may take other legal action as appropriate.

Any materially false, fictitious, or fraudulent statement to the federal government related to this award (or concealment or omission of a material fact) may be the subject of criminal prosecution (including under 18 U.S.C. 1001 and/or 1621, and/or 34 U.S.C. 10271-10273), and also may lead to imposition of civil penalties and administrative remedies for false claims or otherwise (including under 31 U.S.C. 3729-3730 and 3801-3812).

Should any provision of a requirement of this award be held to be invalid or unenforceable by its terms, that provision shall first be applied with a limited construction so as to give it the maximum effect permitted by law. Should it be held, instead, that the provision is utterly invalid or -unenforceable, such provision shall be deemed severable from this award.

Condition 4
Effect of failure to address audit issues
Page: 6 of 20
The recipient understands and agrees that the DOJ awarding agency (OJP or OVW, as appropriate) may withhold award funds, or may impose other related requirements, if (as determined by the DOJ awarding agency) the recipient does not satisfactorily and promptly address outstanding issues from audits required by the Part 200 Uniform Requirements (or by the terms of this award), or other outstanding issues that arise in connection with audits, investigations, or reviews of DOJ awards.

Condition 5
Applicability of Part 200 Uniform Requirements
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements in 2 C.F.R. Part 200, as adopted and supplemented by DOJ in 2 C.F.R. Part 2800 (together, the "Part 200 Uniform Requirements") apply to this award from OJP.

For more information and resources on the Part 200 Uniform Requirements as they relate to OJP awards and subawards ("subgrants"), see the OJP website at https://ojp.gov/funding/Part200UniformRequirements.htm.

Record retention and access: Records pertinent to the award that the recipient (and any subrecipient ("subgrantee") at any tier) must retain -- typically for a period of 3 years from the date of submission of the final expenditure report (SF 425), unless a different retention period applies -- and to which the recipient (and any subrecipient ("subgrantee") at any tier) must provide access, include performance measurement information, in addition to the financial records, supporting documents, statistical records, and other pertinent records indicated at 2 C.F.R. 200.334.

In the event that an award-related question arises from documents or other materials prepared or distributed by OJP that may appear to conflict with, or differ in some way from, the provisions of the Part 200 Uniform Requirements, the recipient is to contact OJP promptly for clarification.

Condition 6
Reporting potential fraud, waste, and abuse, and similar misconduct The recipient, and any subrecipients ("subgrantees") at any tier, must promptly refer to the DOJ Office of the Inspector General (OIG) any credible evidence that a principal, employee, agent, subrecipient, contractor, subcontractor, or other person has, in connection with funds under this award-- (1) submitted a claim that violates the False Claims Act; or (2) committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, gratuity, or similar misconduct.

Potential fraud, waste, abuse, or misconduct involving or relating to funds under this award should be reported to the OIG by--(1) online submission accessible via the OIG webpage at https://oig.justice.gov/hotline/contact-grants.htm (select "Submit Report Online"); (2) mail directed to: U.S. Department of Justice, Office of the Inspector General, Investigations Division, ATTN: Grantee Reporting, 950 Pennsylvania Ave., NW, Washington, DC 20530; and/or (3) by facsimile directed to the DOJ OIG Investigations Division (Attn: Grantee Reporting) at (202) 616-9881 (fax).

Additional information is available from the DOJ OIG website at https://oig.justice.gov/hotline.

Condition 7
Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 38 The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28 C.F.R. Part 38.

Among other things, 28 C.F.R. Part 38 includes rules that prohibit specific forms of discrimination on the basis of religion, a religious belief, a refusal to hold a religious belief, or refusal to attend or participate in a religious practice.

Part 38 also sets out rules and requirements that pertain to recipient and subrecipient ("subgrantee") organizations that engage in or conduct explicitly religious activities, as well as rules and requirements that pertain to recipients and subrecipients that are faith-based or religious organizations.

Recipients and subrecipients that provide social services under this award must give written notice to beneficiaries and prospective beneficiaries prior to the provision of services (if practicable) which shall include language substantially Page: 7 of 20
similar to the language in 28 CFR Part 38, Appendix C, sections (1) through (4). A sample written notice may be found at https://www.ojp.gov/program/civil-rights-office/partnerships-faith-based-and-other-neighborhood-organizations.

In certain instances, a faith-based or religious organization may be able to take religion into account when making hiring decisions, provided it satisfies certain requirements. For more information, please see https://www.ojp.gov/ funding/explore/legaloverview2024/civilrightsrequirements.

Condition 8
Requirements related to "de minimis" indirect cost rate A recipient that is eligible under the Part 200 Uniform Requirements and other applicable law to use the "de minimis" indirect cost rate described in 2 C.F.R. 200.414(f), and that elects to use the "de minimis" indirect cost rate, must advise OJP in writing of both its eligibility and its election, and must comply with all associated requirements in the Part 200 Uniform Requirements. The "de minimis" rate may be applied only to modified total direct costs (MTDC) as defined by the Part 200 Uniform Requirements.

Condition 9
Compliance with applicable rules regarding approval, planning, and reporting of conferences, meetings, trainings, and other events
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable laws, regulations, policies, and official DOJ guidance (including specific cost limits, prior approval and reporting requirements, where applicable) governing the use of federal funds for expenses related to conferences (as that term is defined by DOJ), including the provision of food and/or beverages at such conferences, and costs of attendance at such conferences.

Information on the pertinent DOJ definition of conferences and the rules applicable to this award appears in the DOJ Grants Financial Guide (currently, as section 3.10 of "Postaward Requirements" in the "DOJ Grants Financial Guide").

Condition 10
Requirement for data on performance and effectiveness under the award The recipient must collect and maintain data that measure the performance and effectiveness of work under this award. The data must be provided to OJP in the manner (including within the timeframes) specified by OJP in the program solicitation or other applicable written guidance. Data collection supports compliance with the Government Performance and Results Act (GPRA) and the GPRA Modernization Act of 2010, and other applicable laws.

Condition 11
Compliance with DOJ Grants Financial Guide
References to the DOJ Grants Financial Guide are to the DOJ Grants Financial Guide as posted on the OJP website (currently, the "DOJ Grants Financial Guide" available at https://ojp.gov/financialguide/DOJ/index.htm), including any updated version that may be posted during the period of performance. The recipient agrees to comply with the DOJ Grants Financial Guide.

Condition 12
Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 42 The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28 C.F.R. Part 42, specifically including any applicable requirements in Subpart E of 28 C.F.R. Part 42 that relate to an equal employment opportunity program.

Among other items, 28 C.F.R. § 42.106(d), 28 C.F.R. § 42.405(c), and 28 C.F.R. § 42.505(f) contain notice requirements that covered recipients must follow regarding the dissemination of information regarding federal nondiscrimination requirements.

Condition 13
Page: 8 of 20
Determination of suitability to interact with participating minors SCOPE. This condition applies to this award if it is indicated -- in the application for the award (as approved by DOJ)(or in the application for any subaward, at any tier), the DOJ funding announcement (solicitation), or an associated federal statute -- that a purpose of some or all of the activities to be carried out under the award (whether by the recipient, or a subrecipient at any tier) is to benefit a set of individuals under 18 years of age.

The recipient, and any subrecipient at any tier, must make determinations of suitability before certain individuals may interact with participating minors. This requirement applies regardless of an individual's employment status.

The details of this requirement are posted on the OJP web site at https://ojp.gov/funding/Explore/Interact-Minors.htm (Award condition: Determination of suitability required, in advance, for certain individuals who may interact with participating minors), and are incorporated by reference here.

Condition 14
Requirement to disclose whether recipient is designated "high risk" by a federal grant-making agency outside of DOJ If the recipient is designated "high risk" by a federal grant-making agency outside of DOJ, currently or at any time during the course of the period of performance under this award, the recipient must disclose that fact and certain related information to OJP by email at [email protected]. For purposes of this disclosure, high risk includes any status under which a federal awarding agency provides additional oversight due to the recipient's past performance, or other programmatic or financial concerns with the recipient. The recipient's disclosure must include the following: 1. The federal awarding agency that currently designates the recipient high risk, 2. The date the recipient was designated high risk, 3. The high-risk point of contact at that federal awarding agency (name, phone number, and email address), and 4. The reasons for the high-risk status, as set out by the federal awarding agency.

Condition 15
Employment eligibility verification for hiring under the award

1. The recipient (and any subrecipient at any tier) must-- A. Ensure that, as part of the hiring process for any position within the United States that is or will be funded (in whole or in part) with award funds, the recipient (or any subrecipient) properly verifies the employment eligibility of the individual who is being hired, consistent with the provisions of 8 U.S.C. 1324a(a)(1).

B. Notify all persons associated with the recipient (or any subrecipient) who are or will be involved in activities under this award of both--
(1) this award requirement for verification of employment eligibility, and (2) the associated provisions in 8 U.S.C. 1324a(a)(1) that, generally speaking, make it unlawful, in the United States, to hire (or recruit for employment) certain aliens.

C. Provide training (to the extent necessary) to those persons required by this condition to be notified of the award requirement for employment eligibility verification and of the associated provisions of 8 U.S.C. 1324a(a)(1).

D. As part of the recordkeeping for the award (including pursuant to the Part 200 Uniform Requirements), maintain records of all employment eligibility verifications pertinent to compliance with this award condition in accordance with Form I-9 record retention requirements, as well as records of all pertinent notifications and trainings.

2. Monitoring
The recipient's monitoring responsibilities include monitoring of subrecipient compliance with this condition.

3. Allowable costs
To the extent that such costs are not reimbursed under any other federal program, award funds may be obligated for the reasonable, necessary, and allocable costs (if any) of actions designed to ensure compliance with this condition.

Page: 9 of 20

4. Rules of construction
A. Staff involved in the hiring process
For purposes of this condition, persons "who are or will be involved in activities under this award" specifically includes (without limitation) any and all recipient (or any subrecipient) officials or other staff who are or will be involved in the hiring process with respect to a position that is or will be funded (in whole or in part) with award funds.

B. Employment eligibility confirmation with E-Verify
For purposes of satisfying the requirement of this condition regarding verification of employment eligibility, the recipient (or any subrecipient) may choose to participate in, and use, E-Verify (www.e-verify.gov), provided an appropriate person authorized to act on behalf of the recipient (or subrecipient) uses E-Verify (and follows the proper E-Verify procedures, including in the event of a "Tentative Nonconfirmation" or a "Final Nonconfirmation") to confirm employment eligibility for each hiring for a position in the United States that is or will be funded (in whole or in part) with award funds.

C. "United States" specifically includes the District of Columbia, Puerto Rico, Guam, the Virgin Islands of the United States, and the Commonwealth of the Northern Mariana Islands.

D. Nothing in this condition shall be understood to authorize or require any recipient, any subrecipient at any tier, or any person or other entity, to violate any federal law, including any applicable civil rights or nondiscrimination law.

E. Nothing in this condition, including in paragraph 4.B., shall be understood to relieve any recipient, any subrecipient at any tier, or any person or other entity, of any obligation otherwise imposed by law, including 8 U.S.C. 1324a(a)(1).

Questions about E-Verify should be directed to DHS. For more information about E-Verify visit the E-Verify website (https://www.e-verify.gov/) or email E-Verify at [email protected]. E-Verify employer agents can email E-Verify at E- [email protected].

Questions about the meaning or scope of this condition should be directed to OJP, before award acceptance.

Condition 16
Encouragement of policies to ban text messaging while driving Pursuant to Executive Order 13513, "Federal Leadership on Reducing Text Messaging While Driving," 74 Fed. Reg. 51225 (October 1, 2009), DOJ encourages recipients and subrecipients ("subgrantees") to adopt and enforce policies banning employees from text messaging while driving any vehicle during the course of performing work funded by this award, and to establish workplace safety policies and conduct education, awareness, and other outreach to decrease crashes caused by distracted drivers.

Condition 17
Reclassification of various statutory provisions to a new Title 34 of the United States Code On September 1, 2017, various statutory provisions previously codified elsewhere in the U.S. Code were editorially reclassified (that is, moved and renumbered) to a new Title 34, entitled "Crime Control and Law Enforcement." The reclassification encompassed a number of statutory provisions pertinent to OJP awards (that is, OJP grants and cooperative agreements), including many provisions previously codified in Title 42 of the U.S. Code.

Effective as of September 1, 2017, any reference in this award document to a statutory provision that has been reclassified to the new Title 34 of the U.S. Code is to be read as a reference to that statutory provision as reclassified to Title 34. This rule of construction specifically includes references set out in award conditions, references set out in material incorporated by reference through award conditions, and references set out in other award requirements.

Condition 18
Restrictions and certifications regarding non-disclosure agreements and related matters Page: 10 of 20
No recipient or subrecipient ("subgrantee") under this award, or entity that receives a procurement contract or subcontract with any funds under this award, may require any employee or contractor to sign an internal confidentiality agreement or statement that prohibits or otherwise restricts, or purports to prohibit or restrict, the reporting (in accordance with law) of waste, fraud, or abuse to an investigative or law enforcement representative of a federal department or agency authorized to receive such information.

The foregoing is not intended, and shall not be understood by the agency making this award, to contravene requirements applicable to Standard Form 312 (which relates to classified information), Form 4414 (which relates to sensitive compartmented information), or any other form issued by a federal department or agency governing the nondisclosure of classified information.

1. In accepting this award, the recipient--
a. represents that it neither requires nor has required internal confidentiality agreements or statements from employees or contractors that currently prohibit or otherwise currently restrict (or purport to prohibit or restrict) employees or contractors from reporting waste, fraud, or abuse as described above; and b. certifies that, if it learns or is notified that it is or has been requiring its employees or contractors to execute agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations of award funds, will provide prompt written notification to the federal agency making this award, and will resume (or permit resumption of) such obligations only if expressly authorized to do so by that agency.

2. If the recipient does or is authorized under this award to make subawards ("subgrants"), procurement contracts, or both--
a. it represents that--
(1) it has determined that no other entity that the recipient's application proposes may or will receive award funds (whether through a subaward ("subgrant"), procurement contract, or subcontract under a procurement contract) either requires or has required internal confidentiality agreements or statements from employees or contractors that currently prohibit or otherwise currently restrict (or purport to prohibit or restrict) employees or contractors from reporting waste, fraud, or abuse as described above; and
(2) it has made appropriate inquiry, or otherwise has an adequate factual basis, to support this representation; and b. it certifies that, if it learns or is notified that any subrecipient, contractor, or subcontractor entity that receives funds under this award is or has been requiring its employees or contractors to execute agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations of award funds to or by that entity, will provide prompt written notification to the federal agency making this award, and will resume (or permit resumption of) such obligations only if expressly authorized to do so by that agency.

Condition 19
OJP Training Guiding Principles
Any training or training materials that the recipient -- or any subrecipient ("subgrantee") at any tier -- develops or delivers with OJP award funds must adhere to the OJP Training Guiding Principles for Grantees and Subgrantees, available at https://www.ojp.gov/funding/implement/training-guiding-principles-grantees-and-subgrantees.

Condition 20
Specific post-award approval required to use a noncompetitive approach in any procurement contract that would exceed $250,000
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements to obtain specific advance approval to use a noncompetitive approach in any procurement contract that would exceed the Simplified Acquisition Threshold (currently, $250,000). This condition applies to agreements that -- for purposes of federal grants administrative requirements -- OJP considers a procurement "contract" (and therefore does not consider Page: 11 of 20
a subaward).

The details of the requirement for advance approval to use a noncompetitive approach in a procurement contract under an OJP award are posted on the OJP web site at https://ojp.gov/funding/Explore/NoncompetitiveProcurement.htm (Award condition: Specific post-award approval required to use a noncompetitive approach in a procurement contract (if contract would exceed $250,000)), and are incorporated by reference here.

Condition 21
Requirement to report potentially duplicative funding
If the recipient currently has other active awards of federal funds, or if the recipient receives any other award of federal funds during the period of performance for this award, the recipient promptly must determine whether funds from any of those other federal awards have been, are being, or are to be used (in whole or in part) for one or more of the identical cost items for which funds are provided under this award. If so, the recipient must promptly notify the DOJ awarding agency (OJP or OVW, as appropriate) in writing of the potential duplication, and, if so requested by the DOJ awarding agency, must seek a budget-modification or change-of-project-scope Grant Award Modification (GAM) to eliminate any inappropriate duplication of funding.

Condition 22
Required training for Grant Award Administrator and Financial Manager The Grant Award Administrator and all Financial Managers for this award must have successfully completed an "OJP financial management and grant administration training" by 120 days after the date of the recipient's acceptance of the award. Successful completion of such a training on or after January 1, 2021, will satisfy this condition.

In the event that either the Grant Award Administrator or a Financial Manager for this award changes during the period of performance, the new Grant Award Administrator or Financial Manager must have successfully completed an "OJP financial management and grant administration training" by 120 calendar days after the date the Entity Administrator enters updated Grant Award Administrator or Financial Manager information in JustGrants. Successful completion of such a training on or after January 1, 2021, will satisfy this condition.

A list of OJP trainings that OJP will consider "OJP financial management and grant administration training" for purposes of this condition is available at https://onlinegfmt.training.ojp.gov/. All trainings that satisfy this condition include a session on grant fraud prevention and detection.

The recipient should anticipate that OJP will immediately withhold ("freeze") award funds if the recipient fails to comply with this condition. The recipient's failure to comply also may lead OJP to impose additional appropriate conditions on this award.

Condition 23
Compliance with 41 U.S.C. 4712 (including prohibitions on reprisal; notice to employees) The recipient (and any subrecipient at any tier) must comply with, and is subject to, all applicable provisions of 41 U.S.C. 4712, including all applicable provisions that prohibit, under specified circumstances, discrimination against an employee as reprisal for the employee's disclosure of information related to gross mismanagement of a federal grant, a gross waste of federal funds, an abuse of authority relating to a federal grant, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a federal grant.

The recipient also must inform its employees, in writing (and in the predominant native language of the workforce), of employee rights and remedies under 41 U.S.C. 4712.

Should a question arise as to the applicability of the provisions of 41 U.S.C. 4712 to this award, the recipient is to contact the DOJ awarding agency (OJP or OVW, as appropriate) for guidance.

Condition 24
Requirements pertaining to prohibited conduct related to trafficking in persons (including reporting requirements and OJP authority to terminate award)
Page: 12 of 20
The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements (including requirements to report allegations) pertaining to prohibited conduct related to the trafficking of persons, whether on the part of recipients, subrecipients ("subgrantees"), or individuals defined (for purposes of this condition) as "employees" of the recipient or of any subrecipient.

The details of the recipient's obligations related to prohibited conduct related to trafficking in persons are posted on the OJP web site at https://ojp.gov/funding/Explore/ProhibitedConduct-Trafficking.htm (Award condition: Prohibited conduct by recipients and subrecipients related to trafficking in persons (including reporting requirements and OJP authority to terminate award)), and are incorporated by reference here.

Condition 25
Potential imposition of additional requirements
The recipient agrees to comply with any additional requirements that may be imposed by the DOJ awarding agency (OJP or OVW, as appropriate) during the period of performance for this award, if the recipient is designated as "high- risk" for purposes of the DOJ high-risk grantee list.

Condition 26
Requirement to report actual or imminent breach of personally identifiable information (PII) The recipient (and any "subrecipient" at any tier) must have written procedures in place to respond in the event of an actual or imminent "breach" (OMB M-17-12) if it (or a subrecipient) -- (1) creates, collects, uses, processes, stores, maintains, disseminates, discloses, or disposes of "Personally Identifiable Information (PII)" (2 CFR 200.1) within the scope of an OJP grant-funded program or activity, or (2) uses or operates a "Federal information system" (OMB Circular A-130). The recipient's breach procedures must include a requirement to report actual or imminent breach of PII to an OJP Program Manager no later than 24 hours after an occurrence of an actual breach, or the detection of an imminent breach.

Condition 27
Requirements related to System for Award Management and Universal Identifier Requirements The recipient must comply with applicable requirements regarding the System for Award Management (SAM), currently accessible at https://www.sam.gov/. This includes applicable requirements regarding registration with SAM, as well as maintaining the currency of information in SAM.

The recipient also must comply with applicable restrictions on subawards ("subgrants") to first-tier subrecipients (first- tier "subgrantees"), including restrictions on subawards to entities that do not acquire and provide (to the recipient) the unique entity identifier required for SAM registration.

The details of the recipient's obligations related to SAM and to unique entity identifiers are posted on the OJP web site at https://ojp.gov/funding/Explore/SAM.htm (Award condition: System for Award Management (SAM) and Universal Identifier Requirements), and are incorporated by reference here.

This condition does not apply to an award to an individual who received the award as a natural person (i.e., unrelated to any business or non-profit organization that he or she may own or operate in his or her name).

Condition 28
Compliance with restrictions on the use of federal funds--prohibited and controlled equipment under OJP awards Consistent with Executive Order 14074, “Advancing Effective, Accountable Policing and Criminal Justice Practices To Enhance Public Trust and Public Safety,” OJP has prohibited the use of federal funds under this award for purchases or transfers of specified equipment by law enforcement agencies. In addition, OJP requires the recipient, and any subrecipient (“subgrantee”) at any tier, to put in place specified controls prior to using federal funds under this award to acquire or transfer any property identified on the “controlled equipment” list. The details of the requirement are posted on the OJP web site at https://www.ojp.gov/funding/explore/prohibited-and-controlled-equipment (Award condition:

Compliance with restrictions on the use of federal funds--prohibited and controlled equipment under OJP awards), and Page: 13 of 20
are incorporated by reference here.

Condition 29
Restrictions on "lobbying"
In general, as a matter of federal law, federal funds awarded by OJP may not be used by the recipient, or any subrecipient ("subgrantee") at any tier, either directly or indirectly, to support or oppose the enactment, repeal, modification, or adoption of any law, regulation, or policy, at any level of government. See 18 U.S.C. 1913. (There may be exceptions if an applicable federal statute specifically authorizes certain activities that otherwise would be barred by law.)
Another federal law generally prohibits federal funds awarded by OJP from being used by the recipient, or any subrecipient at any tier, to pay any person to influence (or attempt to influence) a federal agency, a Member of Congress, or Congress (or an official or employee of any of them) with respect to the awarding of a federal grant or cooperative agreement, subgrant, contract, subcontract, or loan, or with respect to actions such as renewing, extending, or modifying any such award. See 31 U.S.C. 1352. Certain exceptions to this law apply, including an exception that applies to Indian tribes and tribal organizations.

Should any question arise as to whether a particular use of federal funds by a recipient (or subrecipient) would or might fall within the scope of these prohibitions, the recipient is to contact OJP for guidance, and may not proceed without the express prior written approval of OJP.

Condition 30
All subawards ("subgrants") must have specific federal authorization The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements for authorization of any subaward. This condition applies to agreements that -- for purposes of federal grants administrative requirements -- OJP considers a "subaward" (and therefore does not consider a procurement "contract").

The details of the requirement for authorization of any subaward are posted on the OJP web site at https://ojp.gov/ funding/Explore/SubawardAuthorization.htm (Award condition: All subawards ("subgrants") must have specific federal authorization), and are incorporated by reference here.

Condition 31
Compliance with DOJ regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 54 The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28 C.F.R. Part 54, which relates to nondiscrimination on the basis of sex in certain "education programs." Among other items, 28 C.F.R. § 54.140 contains notice requirements that covered recipients must follow regarding the dissemination of information regarding federal nondiscrimination requirements.

Condition 32
The recipient understands that, in accepting this award, the Authorized Representative declares and certifies, among other things, that he or she possesses the requisite legal authority to accept the award on behalf of the recipient entity and, in so doing, accepts (or adopts) all material requirements that relate to conduct throughout the period of performance under this award. The recipient further understands, and agrees, that it will not assign anyone to the role of Authorized Representative during the period of performance under the award without first ensuring that the individual has the requisite legal authority.

Condition 33
Verification and updating of recipient contact information The recipient must verify its Grant Award Administrator, Financial Manager, and Authorized Representative contact information in JustGrants, including telephone number and e-mail address. If any information is incorrect or has changed, the award recipient’s Entity Administrator must make changes to contact information through DIAMD.

Page: 14 of 20
Instructions on how to update contact information in JustGrants can be found at https://justicegrants.usdoj.gov/training/ training-entity-management.

Condition 34
The recipient agrees that no funds under this grant award (including via subcontract or subaward, at any tier) may be used for unmanned aircraft systems (UAS), which includes unmanned aircraft vehicles (UAV), or for any accompanying accessories to support UAS.

Condition 35
The recipient agrees to comply with OJP grant monitoring guidelines, protocols, and procedures, and to cooperate with BJA and OCFO on all grant monitoring requests, including requests related to desk reviews, enhanced programmatic desk reviews, and/or site visits. The recipient agrees to provide to BJA and OCFO all documentation necessary to complete monitoring tasks, including documentation related to any subawards made under this award. Further, the recipient agrees to abide by reasonable deadlines set by BJA and OCFO for providing the requested documents.

Failure to cooperate with BJA's/OCFO's grant monitoring activities may result in sanctions affecting the recipient's DOJ awards, including, but not limited to: withholdings and/or other restrictions on the recipient's access to grant funds; referral to the Office of the Inspector General for audit review; designation of the recipient as a DOJ High Risk grantee; or termination of an award(s).

Condition 36
Any written, visual, or audio publications funded in whole or in part under this award, with the exception of press releases, shall contain the following statements: "This project was supported by Grant No. <AWARD_NUMBER> awarded by the Bureau of Justice Assistance. The Bureau of Justice Assistance is a component of the Department of Justice's Office of Justice Programs, which also includes the Bureau of Justice Statistics, the National Institute of Justice, the Office of Juvenile Justice and Delinquency Prevention, the Office for Victims of Crime, and the SMART Office. Points of view or opinions in this document are those of the author and do not necessarily represent the official position or policies of the U.S. Department of Justice." The current edition of the DOJ Grants Financial Guide provides guidance on allowable printing and publication activities.

Condition 37
Body armor - compliance with NIJ standards and other requirements Ballistic-resistant and stab-resistant body armor purchased with award funds may be purchased at any threat level, make or model, from any distributor or manufacturer, as long as the body armor has been tested and found to comply with applicable National Institute of Justice ballistic or stab standards, and is listed on the NIJ Compliant Body Armor Model List. In addition, ballistic-resistant and stab-resistant body armor purchased must be made in the United States and must be uniquely fitted, as set forth in 34 U.S.C. 10202(c)(1)(A). The latest NIJ standard information and the NIJ Compliant Body Armor List may be found by following the links located on the NIJ Body Armor page: https://nij.ojp.gov/ topics/equipment-and-technology/body-armor. In addition, if recipient uses funds under this award to purchase body armor, the recipient is strongly encouraged to have a "mandatory wear" policy in effect. There are no requirements regarding the nature of the policy other than it be a mandatory wear policy for all uniformed officers while on duty.

Condition 38
Any Web site that is funded in whole or in part under this award must include the following statement on the home page, on all major entry pages (i.e., pages (exclusive of documents) whose primary purpose is to navigate the user to interior content), and on any pages from which a visitor may access or use a Web-based service, including any pages that provide results or outputs from the service: "This Web site is funded in whole or in part through a grant from the Bureau of Justice Assistance, Office of Justice Programs, U.S. Department of Justice. Neither the U.S. Department of Justice nor any of its components operate, control, are responsible for, or necessarily endorse, this Web site (including, without limitation, its content, technical infrastructure, and policies, and any services or tools provided)." The full text of the foregoing statement must be clearly visible on the home page. On other pages, the statement may be included through a link, entitled "Notice of Federal Funding and Federal Disclaimer," to the full text of the statement.

Condition 39
The recipient agrees to cooperate with any assessments, national evaluation efforts, or information or data collection requests, including, but not limited to, the provision of any information required for the assessment or evaluation of any Page: 15 of 20
activities within this project.

Condition 40
FFATA reporting: Subawards and executive compensation
The recipient must comply with applicable requirements to report first-tier subawards ("subgrants") of $30,000 or more and, in certain circumstances, to report the names and total compensation of the five most highly compensated executives of the recipient and first-tier subrecipients (first-tier "subgrantees") of award funds. The details of recipient obligations, which derive from the Federal Funding Accountability and Transparency Act of 2006 (FFATA), are posted on the OJP web site at https://ojp.gov/funding/Explore/FFATA.htm (Award condition: Reporting Subawards and Executive Compensation), and are incorporated by reference here.

This condition, including its reporting requirement, does not apply to-- (1) an award of less than $30,000, or (2) an award made to an individual who received the award as a natural person (i.e., unrelated to any business or non-profit organization that he or she may own or operate in his or her name).

Condition 41
Justification of consultant rate
Approval of this award does not indicate approval of any consultant rate in excess of $650 per day. A detailed justification must be submitted to and approved by the OJP program office prior to obligation or expenditure of such funds.

Condition 42
Applicants must ensure that Limited English Proficiency persons have meaningful access to the services under this program(s). National origin discrimination includes discrimination on the basis of limited English proficiency (LEP). To ensure compliance with Title VI and the Safe Streets Act, recipients are required to take reasonable steps to ensure that LEP persons have meaningful access to their programs. Meaningful access may entail providing language assistance services, including oral and written translation when necessary. The U.S. Department of Justice has issued guidance for grantees to help them comply with Title VI requirements. The guidance document can be accessed on the Internet at www.lep.gov.

Condition 43
To the extent that direct services will be provided to participants as a component of the JMHCP project, grant funds must be used to support a target population that includes adults who: 1) have been diagnosed as having MI or CMISA or manifest obvious signs of MI or CMISA during arrest or confinement or before any court; 2) have been unanimously approved for participation in a program funded under this award by (as appropriate) the relevant prosecuting attorney, defense attorney, probation or corrections official, judge, and a representative from the relevant mental health agency, and having been determined by each of these relevant individuals to not pose a risk of violence to any person in the program, or the public; and 3) have not been charged with or convicted of any sex offense (as defined at 34 U.S.C. ?2 0911) or any offense relating to the sexual exploitation of children, or murder or assault with intent to commit murder.

Condition 44
A match of 20% is required for years 1&2 combined. Match may be met through any combination of percentage between years 1 & 2 as long as the combined total for both years is 20%. Recipient understands that significant project delays (over 90 days) may lead to increases in the required cost match, pursuant to 34 USC 10651(d), and agrees to cooperate with BJA on any budget revisions that may be necessary, particularly following such significant project delays. Recipient further understands that the required match set forth in the proposed budget and any budget revisions will be reviewed in accordance with statutory requirements, leading to a total match amount for which the recipient will be responsible. The recipient understands they will be required to meet the total match amount as outlined in approved budget by project period end date.

Condition 45
JMHCP Planning Phase: The recipient may incur obligations, expend, and draw down funds in an amount not to exceed $100,000 for the sole purpose of completing the required planning phase during which it must develop a Planning and Implementation Guide. The grantee is not authorized to incur any additional obligations, make any Page: 16 of 20
additional expenditures, or drawdown any additional funds until BJA has reviewed and approved the grant recipient's completed Planning and Implementation Guide, reviewed and approved a signed MOU between the applicant and its behavioral health partner, and has issued an Award Condition Modification (ACM) removing this condition.

Condition 46
Limit on use of grant funds for grantees' employees' salaries With respect to this award, federal funds may not be used to pay cash compensation (salary plus bonuses) to any employee of the award recipient at a rate that exceeds 110% of the maximum annual salary payable to a member of the federal government's Senior Executive Service (SES) at an agency with a Certified SES Performance Appraisal System for that year. (An award recipient may compensate an employee at a higher rate, provided the amount in excess of this compensation limitation is paid with non-federal funds.) This limitation on compensation rates allowable under this award may be waived on an individual basis at the discretion of the OJP official indicated in the program announcement under which this award is made.

Condition 47
Recipient integrity and performance matters: Requirement to report information on certain civil, criminal, and administrative proceedings to SAM and FAPIIS
The recipient must comply with any and all applicable requirements regarding reporting of information on civil, criminal, and administrative proceedings connected with (or connected to the performance of) either this OJP award or any other grant, cooperative agreement, or procurement contract from the federal government. Under certain circumstances, recipients of OJP awards are required to report information about such proceedings, through the federal System for Award Management (known as "SAM"), to the designated federal integrity and performance system (currently, "FAPIIS").

The details of recipient obligations regarding the required reporting (and updating) of information on certain civil, criminal, and administrative proceedings to the federal designated integrity and performance system (currently, "FAPIIS") within SAM are posted on the OJP web site at https://ojp.gov/funding/FAPIIS.htm (Award condition:

Recipient Integrity and Performance Matters, including Recipient Reporting to FAPIIS), and are incorporated by reference here.

Condition 48
Confidentiality of data
The recipient (and any subrecipient at any tier) must comply with all confidentiality requirements of 34 U.S.C. 10231 and 28 C.F.R. Part 22 that are applicable to collection, use, and revelation of data or information. The recipient further agrees, as a condition of award approval, to submit a Privacy Certificate that is in accord with requirements of 28 C.F.R. Part 22 and, in particular, 28 C.F.R. 22.23.

Condition 49
Justice Information Sharing
Information sharing projects funded under this award must comply with DOJ's Global Justice Information Sharing Initiative (Global) guidelines. The recipient (and any subrecipient at any tier) must conform to the Global Standards Package (GSP) and all constituent elements, where applicable, as described at: https:/ / it.ojp.gov/ gsp_grantcondition.

The recipient (and any subrecipient at any tier) must document planned approaches to information sharing and describe compliance with the GSP and appropriate privacy policy that protects shared information, or provide detailed justification for why an alternative approach is recommended.

Condition 50
Protection of human research subjects
The recipient (and any subrecipient at any tier) must comply with the requirements of 28 C.F.R. Part 46 and all OJP policies and procedures regarding the protection of human research subjects, including obtainment of Institutional Review Board approval, if appropriate, and subject informed consent.

Page: 17 of 20
Condition 51
Required monitoring of subawards
The recipient must monitor subawards under this award in accordance with all applicable statutes, regulations, award conditions, and the DOJ Grants Financial Guide, and must include the applicable conditions of this award in any subaward. Among other things, the recipient is responsible for oversight of subrecipient spending and monitoring of specific outcomes and benefits attributable to use of award funds by subrecipients. The recipient agrees to submit, upon request, documentation of its policies and procedures for monitoring of subawards under this award.

Condition 52
The recipient's budget (and budget narrative) is pending clearance by OJP.

Prior to budget clearance (and unless there is a more restrictive condition on this award, in which case the terms of that more restrictive condition apply): The recipient may not obligate, expend, or drawdown more than 10% of the award. Pre-clearance obligations, expenditures, and drawdowns may be disallowed if not in compliance with program requirements.

The recipient should be judicious in using award funds prior to budget clearance. Generally, OJP expects that recipients (depending on the specific project scope) may need to advertise for award-funded positions, pay personnel and fringe benefits for positions budgeted under the award, plan for project activities, attend training and pay training- related travel necessary to begin the award project, and engage in other limited activities conducted by recipient staff (i.e., generally not requiring a subaward or procurement contract under an award).

OJP will issue an Award Condition Modification upon budget clearance.

Condition 53
The recipient may not expend or drawdown more than 10% of the award funds until: (1) it has provided to the grant manager for this OJP award information regarding research and evaluation independence and integrity in accordance with the detailed instructions in the program solicitation, (2) OJP has completed its review of the information provided and of any supplemental information it may request, (3) the recipient has made (or agreed to) any adjustments to the award (including as to amount) that OJP may require to prevent, eliminate, mitigate, or otherwise adequately address any actual or apparent personal or financial conflict of interest on the part of the investigators or other staff/consultants engaged in the research/evaluation or organizational conflict of interest on the part of the recipient entity, and (4) Award Condition Modification (ACM) has been issued to remove this condition. Obligations, expenditures, and drawdowns prior to the ACM are made at the recipient's risk and may be disallowed if not in compliance with program requirements or approved budget.
[ ] I have read and understand the information presented in this section of the Federal Award Instrument.

Award Acceptance
Declaration and Certification to the U.S. Department of Justice as to Acceptance By checking the declaration and certification box below, I-- A. Declare to the U.S. Department of Justice (DOJ), under penalty of perjury, that I have authority to make this declaration and certification on behalf of the applicant.

B. Certify to DOJ, under penalty of perjury, on behalf of myself and the applicant, to the best of my knowledge and belief, that the following are true as of the date of this award acceptance: (1) I have conducted or there was conducted (including by applicant’s legal counsel as appropriate and made available to me) a diligent review of all terms and conditions of, and all supporting materials submitted in connection with, this award, including any assurances and certifications (including anything submitted in connection therewith by a person on behalf of the applicant before, after, Page: 18 of 20
or at the time of the application submission and any materials that accompany this acceptance and certification); and (2) I have the legal authority to accept this award on behalf of the applicant.

C. Accept this award on behalf of the applicant.

D. Declare the following to DOJ, under penalty of perjury, on behalf of myself and the applicant: (1) I understand that, in taking (or not taking) any action pursuant to this declaration and certification, DOJ will rely upon this declaration and certification as a material representation; and (2) I understand that any materially false, fictitious, or fraudulent information or statement in this declaration and certification (or concealment or omission of a material fact as to either) may be the subject of criminal prosecution (including under 18 U.S.C. §§ 1001 and/or 1621, and/or 34 U.S.C. §§ 10271-10273), and also may subject me and the applicant to civil penalties and administrative remedies under the federal False Claims Act (including under 31 U.S.C. §§ 3729-3730 and/or §§ 3801-3812) or otherwise.

Agency Approval
Title of Approving Official
Acting Assistant Attorney General
Name of Approving Official
Brent J. Cohen
Signed Date And Time
9/19/24 8:21 AM
Authorized Representative
[ ] no value
Entity Acceptance
Title of Authorized Entity Official
no value
Signed Date And Time
no value

Page: 19 of 20
Page: 20 of 20

Anaheim City CouncilJune 17, 2025

Anaheim City Council
June 17, 2025