Adam Walsh Act (AWA) Implementation Grant Program – Managing Your Award

Samantha Opong: Good afternoon and thank you for joining us today. I'm Samantha Opong, the associate director of programs and planning in the Office of Sex Offender Sentencing, Monitoring, Apprehending, Registering, and Tracking, also known as the SMART office. Next slide please.

Today's webinar, Adam Walsh Act implementation Grant program – Managing your award, is presented by the SMART grant management specialists, Kashan Alamin, Yolanda Curtis Gibson, Kim Martin and Daniel Rappaport. They will provide an overview of responsibilities for managing AWA Grant awards and provide participants with best practices for award acceptance. This webinar is intended for AWA recipients. Next slide please.

Before we get started, I want to go over a few housekeeping items. Today's webinar will be recorded. If you are using a computer and need to adjust your auto setting, at the bottom of your screen click on the down arrow unmute button to adjust as needed. If you are still having an issue within this icon, you can request that WebEx call your phone directly.

You can submit your questions at any time using the chat feature. To submit the question, at the bottom of the righthand side of the corner, click on the chat box icon. We will try to address as many questions as we can at the end of the webinar during the allotted time However, if we're unable to address your questions, someone will follow up with you after the webinar.

Or you can email your grant manager directly. Closed captioning is available and to use this feature, click on the three dots at the bottom righthand side of the screen and then select captions.

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Congratulations on receiving your FY 2025 AWA award. And a warm welcome to our new and returning AWA Award recipients.  

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Together we want to help you with your project and help it be successful through partnering and supporting you by addressing any questions, solving any problems that may arise and ensuring that you meet all requirements of your award. Laws and grant processes may change year after year, but your grant managers are here to guide you through it all.

Contact your grant manager to collectively work through any questions or concerns you may have. Remember, your success is our success. Thank you again for joining us. Now I'll turn it over to Daniel.

Daniel Rappaport: Thank you so much, Sam. Good morning, everyone. I'm Daniel Rappaport. I'm a grants management specialist with the SMART Office. Today's presentation is a helpful overview for all SMART Award recipients. Experienced recipients looking for a refresh and new recipients looking for an orientation to SMART grant management.  

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Today we'll walk you through these eight critical topics that apply to all OJP Awards. Our discussion is just an overview of the basics. As we go through each topic, we'll tell you exactly where to go for in-depth training and resources.  

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Our first topic today is JustGrants.  

The Justice Grants System, or JustGrants, is DOJ's official grants management system. You might also hear us refer to JustGrants as DOJ's system of record for grants. It's important to know some JustGrants basics. I also encourage you to log in, if you haven't already, and look around your entity’s profile in JustGrants. You'll notice that we use the term entity throughout today's discussion.

This term refers to your organization, which is called an entity in federal rules and systems. JustGrants provides an entity level view, meaning that you, as the award recipient, can see all of your entity’s DOJ grants related information in one place. This includes applications, awards, users and points of contact. If you have grants from multiple DOJ offices, you can see all of those in JustGrants, making it easier to collaborate and communicate on your DOJ grants.

JustGrants is also where you assign entity users to individual applications and awards and find your DOJ grant manager’s contact information. For users assigned to individual awards, you will complete all assigned reports and request changes to your awards in JustGrants.  

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To access JustGrants and complete work assignments, you will need these critical roles assigned to people in your entity. When staff depart or take on different assignments, these roles will need to be reassigned. Outdated assignments can block you from completing your grant requirements in JustGrants. For every award, you need users assigned to these five roles. Together, these users will ensure work is completed on time and grant requirements are fully met in JustGrants.

First, each entity has one entity administrator in JustGrants. This person is critical to your success because they manage the entity users and assignments, as well as maintain entity information and documents. This person should also be tracking that your entity status in Sam.gov always remains active because this expires annually. If this one person goes on extended leave or departs your organization, they will need to reassign the role to another entity user.

If the departure is unexpected, your entity will need to work with JustGrants support to onboard a new entity administrator using current Sam.gov contact information. The next critical user is the authorized representative. This person must have the legal authority to accept or decline the award. The financial manager completes required financial reports quarterly and at the conclusion of the award. The grant administrator and alternative grant administrator are responsible for everything else. Tracking and reporting award progress, submitting key deliverables and requesting modifications when needed. As we go through each topic today, we'll talk more about who does what and when in JustGrants.  

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We don't expect you to understand everything perfectly today. And we have resources and support to assist you throughout your award. Our JustGrants resources website has practical tools to support you as you prepare and complete tasks in JustGrants. Explore these at your own pace, and bookmark this site so you can return periodically. Our training and web teams make updates and improvements to the site regularly, so you can rely on this site as your source of truth for all JustGrants related activities.

If you're ever working in JustGrants and need some extra support, our JustGrants support team is standing by to help. You can also find this information when you're logged in to JustGrants. You can quickly link to training resources and contact support when you need it.  

Now we'll move on to Award acceptance.  

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After you receive notice of a new award, you must formally accept or decline that award in JustGrants. The act of award acceptance itself is important because it binds your entity to all the conditions outlined in the award package in JustGrants. Your entity administrator and authorized representative must take actions in JustGrants to complete award acceptance. This involves assigning users to the new award, carefully reviewing each part of the award package, acknowledging the legal conditions, and electronically signing the award.

OJP encourages recipients to accept or decline their new award within 45 days of award notification. If you need additional time, email your DOJ grant manager to let them know. Our JustGrants resources website has dedicated resources to help guide entity administrators and authorized representatives through the award acceptance process.  

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Your authorized representative must review the entire award package during award acceptance, but everyone involved in carrying out your award should also review the award package and award conditions. You might consider printing and reviewing the award package together as a team and discussing how it applies to your day-to-day work. If something is confusing, ask your DOJ grant manager to help clarify. When new staff joins your team, review and discuss the package and conditions again. Remember, if you fail to comply with the award conditions, OJP may withhold funds, disallow costs, or terminate your award.  

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We want to emphasize that award recipients must notify their grant managers when there are changes to your project director, any grant funded staff, and any other key program personnel, regardless of whether they are grant funded or not. As always, please talk to your grant manager for any specific questions about this requirement or any other conditions.  

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A new award condition for some SMART recipients this year requires the revision of the submitted program narrative. Any recipient that has this award condition must revise the program narrative based on guidance provided by their grant manager. It's critically important that the project not begin until a revised program narrative and or budget documents have been received and approved by SMART, and an award condition modification has been issued to remove the condition in your award.

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And now I'll pass it over to my colleague, Kim Martin.

Kim Martin: Thanks, Daniel.

Hello, everyone. My name is Kim Martin, and I am a grant management specialist with SMART. Today I will be covering the process for accessing funds. After you accept your award, there are a few required steps you'll need to complete before you can access your grant funds.  

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First, you'll need to set up in a system called ASAP, the Automated Standard Application for Payments, or ASAP for short, is a federal shared service that is managed by the US Department of Treasury Bureau of the Fiscal Service. Federal agencies establish an account for each grant in ASAP. If you have a federal grant recently, you're likely already enrolled and familiar with ASAP.

If your entity is new to DOJ, you'll complete an enrollment process. More about this process is found on our JustGrants ASAP resource website. Once your entity is set up in ASAP, you'll need to keep users and bank information up to date. As you prepare to make your first payment request, be sure you are following your entity’s established policies and procedures for payment requests.

You'll also need to prepare a payment justification for each request to explain the expenses are tied to your DOJ approved grant budget and allowable activities. Funding may not be available for a few reasons. Routine and end-of-month reconciliation activities, delinquent grant reports, or holes tied to award conditions such as a final clearance.

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DOJ must thoroughly review and approve all award budgets. Oftentimes, a conditional clearance is performed until a more thorough review can be completed. DOJ carefully reviews all proposed grant budgets to ensure federal grant funds will be used for the purpose that they were awarded. When there are questions or changes needed, DOJ will send a grant award modification to you in JustGrants. Before you can begin to incur project expenses, determine whether your budget has received a final clearance. When DOJ staff asks you to provide additional documents or revise your budget, please do your best to act quickly. Your DOJ grant manager can help you navigate the budget clearance process.

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Next, I want to highlight the financial management training requirement. This training is included in all award conditions, and it's important to know that if it isn't completed, it can result in a freeze on your award funds. It's mandatory for the grant award administrator and the financial manager. Other users are welcome to take it, but it's optional for them. The training needs to be completed every three years, and you can take it either online or in person.

Whatever works best for your schedule. Once you finish the training, be sure to send your certificate to your entity administrator. They will upload it to the entity documents in JustGrants.  

Now we'll talk about your financial reporting requirements.  

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Early in the orientation we mentioned the financial manager role. This is the person that completes the financial reports, also known as the FFR, each quarter in JustGrants. No matter your role on your grant, you should know your financial manager assigned to your award and work with them to ensure that they have current information about grant expenditures. All awards follow the same financial reporting schedule, which aligns with the federal fiscal year, October 1st through September 30th.

After each quarter ends, a new financial report is created and assigned to the Financial Manager. The financial manager must complete the report within 30 days of the end of the quarter. Be sure your financial reports are submitted on time. Late financial reports automatically freeze your access to grant funds. Access is restored when the delinquent report is submitted.

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Your quarterly financial reports provide a snapshot of your grant expenditures to date, from the start of your project through the end of the reporting period. Make sure the amounts in your accounting system are accurate. Report the same amounts in your financial reports so everything aligns. And keep supporting documentation for all grant expenditures and be prepared to share those if requested.

DOJ Grant Financial Guide provides deeper guidance on topics such as adequate accounting systems, separate tracking of awards and more details about federal financial reports, including how to report indirect costs for each quarter. And with that, I will turn it over to my colleague, Kashan, who will be covering the next section on tracking and reporting progress.  

Kashan Alamin: Thank you. Kim. I’m Kashan Alamin, and I'm also a grant management specialist in the SMART office. This next section covers the tracking and reporting of your program’s progress.  

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Okay. From the start of your award, you'll need to track your progress of meeting the goals and objectives of your grant program. At a high level, here are some ways to help you establish and maintain strong progress reporting practices. Every grant program has designated performance measures. You're required to track your progress on those measures and then report every six months in JustGrants.

That information is then rolled up into larger reports that help to demonstrate the impact of federal grant funds overall. From the start, you'll want to establish a plan for who will collect, track and report on your program’s progress. A good rule of thumb is to routinely check in with your team to discuss what you're learning from the data you're collecting.

Your project has a public benefit, and everyone wants you to succeed in achieving the goals of your program. You may encounter challenges, but your grant manager is here to help you navigate those challenges so that the public benefits as much as possible.  

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Now we come to the “who,” “what” and “when” of performance reporting. The “who” is the grant award administrator, who is responsible for updating, or excuse me, uploading performance reporting into JustGrants. The “what” is a two-part performance report which is comprised of an actual progress report that's uploaded as well as responses to the performance measures questionnaire. And I'm going to actually add a “where” in here.

So, the “where” would be the performance management module within JustGrants. The “when” is semiannually. So, as you can see here in this chart, July 30th is the due date for the January 1st through June 30th reporting period. And January 30th is the due date for the July 1st through December 31st reporting period. These due dates reflect 30 days after the end of the reporting period, so please be mindful.

Keep these dates, and if you need to remind yourself in a calendar, please do so because late performance reports will automatically freeze your award funds. And we don't want that. Performance reports are automatically created in JustGrants for each award at the start of each reporting period, which is, again, every six months. This is where you'll enter the data you've been collecting about your awards progress, identifying any successes and challenges met during the reporting period.

This is also an opportunity to request technical assistance if needed. If you have a new award, the first reporting period will be slightly different depending on when your award is accepted. So please be sure to look in the performance management section of your award in JustGrants to confirm your first reporting period. It may be shorter or longer than the typical six-month reporting period.

Once submitted, the report is routed to your grant manager who will review and approve it or return it to you via an email in JustGrants for changes that may need to be made. So, when it's time to complete performance reports, you can find more information on our JustGrants performance reporting site.  

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So, what else do you include in the progress report. So of course there's, along the top, you have general award information, which includes your name and contact information for the person who's completing the report. And this is also where you provide the status of your goals and objectives, your award balances and any future plans that you see.

All goals and objectives identified in your approved applications program narrative must be listed along with the status for each. This is how we are able to get a sense of how you all are doing in terms of the administration of your grant award. If there's an occasion where you have no program activity for a specific goal, and this happens a lot particularly with a new award, you're still required to submit progress reports with the goals and objectives filled out in the template.

However, you can state there that there has been no program activity, and you must provide the reason. And at any time, if additional space is needed to capture all program process, feel free to add extra pages as necessary and you can upload those to JustGrants.

Now, for those of you who attended, you might remember last summer, the SMART Office facilitated a performance reporting specific webinar and introduced new performance measures that will replace the current set that you've been reporting on. The new measures will be live for the upcoming performance period, which will be due on July 30th.

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So, there are three standard performance measures for Adam Walsh Act award recipients. To assist you with understanding what information we're asking for, we have included guidance for each of the measures. So, the first measure is to enter the number of staff trained virtually and/or in person during the current reporting period. So here by staff we mean it includes registry officials, law enforcement, jurisdiction level and registry administrators. And trainings could include those within the jurisdiction, regional or local registry conferences, webinars like this, SMART workshops and symposia, as well as national conferences.  

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The second measure is the number of records that are digitized in the current reporting period. And so here, what records means is sex offender documents contained in the jurisdictions sex offender registry, or SOR, database. And for example, that could be driver's licenses, conviction documents, passports, duty to register, acknowledgment forms etc. And digitized means records that have been converted from paper form into a digital or electronic format.

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And finally, you are to enter the individual instances in which records are entered or updated in the current reporting period. So, in this instance, you know, individual instances means each unique occurrence in which records are entered or updated in the jurisdiction’s SOR for a sex offender. For example, if multiple records are entered for a sex offender, such as an offender's name, date of birth, social security number and residence address on Monday, and then one record like the residence address is updated for the same sex offender on Tuesday, this would equate to two individual instances for purposes of this performance measure.

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So, the number of individual instances in which records are entered or updated in the current reporting period. So, records again means sex offender documents including driver's licenses, conviction documents, passports, duty to register acknowledgment forms, etc. And sex offender database entries like residence addresses, offensive conviction, etc. that are contained in the jurisdiction SOR database. Entered in this measure means the input of records during initial sex offender registration, and updated refers to the input or modification of records occurring at any time after the initial sex offender registration.

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So, our veteran award recipients will notice that we're no longer requesting the data to be broken out by each month of the reporting period. So, this now we are requesting the six month aggregated data for each measure. So, there will be two more questions in the questionnaire which you're already familiar with. One of them being if any reported values are zero, you need to provide an explanation as to why.

And question five we'll just basically provide you an opportunity to enter additional or supporting documentation for any of the data that was entered. That's not mandatory, but it's there if you need to, if you feel you need to give us additional information. So, the new measures are currently being loaded into JustGrants, and you will have access to them the same way you always have, which is via the performance management module within JustGrants.

So, these new measures should be available to respond to by early next week. So, around July 7th. So again, your grant manager is here to assist. So, feel free to contact us with any questions you may have. So, with that I will turn over the presentation to Yolanda who will go over modifying your award. Yolanda.  

Yolanda Gibson: Thanks, Kashan.

As Kashan mentioned, I'm Yolanda Curtis Gibson, and I am the final member of the SMART Office’s Grants management team to present to you today. As Kashan mentioned, we will discuss modifying your award, when you would modify your award and the general process for doing so. Next slide please.

If you would like to make changes to your grant project scope, timeline, budget or project period and date, you would submit a grant award modification, which we refer to as a GAM for short. GAMs are submitted in JustGrants by your grant award administrator, and if you need to submit a GAM, please communicate with your grant manager to determine the type of GAM you'll need to submit.

There are resources available to walk you through the process of initiating and submitting a GAM, including training videos and a job aid reference. Those references or resources are available using the link on your screen. Next slide please.

So, there are five different types of GAMs that you can initiate. These include a project period extension GAM, two types of programmatic GAMs and two types of financial GAMs. The project period extension GAM basically sounds exactly like the description. You would submit this type of GAM if you want to extend your grant’s project period end date. This type of GAM is typically submitted in the last year of your grant project period.

The two types of programmatic GAMS are the programmatic cost GAM and scope change GAM. You would submit a programmatic cost GAM to request prior approval for certain costs, including, but not limited to, approval to pay a consultant more than the OJP maximum rate. And that rate is currently $650 per day, or $81.25 per hour. You might also submit a programmatic cost GAM if you want to request to use grant funds for foreign travel.

A scope change GAM is submitted if you want to change the purpose of your project, programmatic activities, the project site or the primary personnel responsible for oversight and implementation of the grant project. The two types of financial GAMs are budget modification and sole source. You would submit a budget modification GAM if you want to redistribute funds between budget categories or otherwise modify your budget, including adding any new expenses that are not already included in your budget.

And finally, a sole source GAM is submitted if you want to enter into a contract without competitive bidding, and if the contract amount will exceed the simplified acquisition threshold. And the simplified acquisition threshold is currently $350,000. We highly recommend that you communicate with your grant manager prior to submitting any GAMs in JustGrants.  

So next we will discuss monitoring compliance and use of funds. Next slide please.

So, all grant awards require monitoring. And this includes a combination of your internal checks as a grant recipient, OJP’s reviews, so that can be from the SMART office on the programmatic side or OCFO, which is our office of the Chief Financial Officer, and also additional external oversight. Together, these strategies and resources help to safeguard federal funds and maximize the impact of these funds in your communities.

So first, let's discuss how you can monitor your grant award. It's important to establish compliance checks throughout the life of your grant award. Staff and circumstances may change over time, but you are still bound to the original award agreement and conditions. Routine internal monitoring can help you find and correct issues early on and ensure that your award achieves maximum benefit to the American people.

Here are some questions you might consider and discuss with your colleagues during your internal checks. So, for example, are we carrying out the project as it was approved by OJP? If we modify the project, did we receive written OJP, or specifically, SMART office approval? Are we submitting all reports and deliverables? Are we documenting and tracking all award related expenditures? And do those expenditures align with our progress and financial reports? Are we passing award funding through to another entity? If so, are we meeting our oversight requirements? And finally, are there areas in which we need additional guidance and assistance? And if so, have we contacted our grant manager? Next slide please.

SMART monitoring. Thank you. So OJP and the SMART office also monitor all grant awards so we can better understand what's working well and where you as grant recipients may need additional support. We do this in a few different ways. So first we review all of your grant reports to better understand how your projects are progressing and whether your spending aligns with that progress.

We talk with all of you as grant recipients directly through email, through webinars such as this one, and through phone calls to understand challenges and provide information and support. We also do in-depth monitoring, both virtually and in person, on a percentage of awards each year. And this helps us to provide deeper support to all of you. During this monitoring, we review a variety of documents, including your grant award files, policies and procedures, financial records, among other documents.

These more in-depth reviews help us to better understand your successes and areas of need. One thing I would like to emphasize is that we want you to succeed in your grant funded service to the public. While some of these monitoring activities might seem burdensome, their purpose is to ensure that your project is on track and to support you in meeting your federal grant requirements. OJP has a grant and funding site where you can learn more about additional external oversight activities, such as those conducted by DOJ's Office of the Inspector General and the General Accountability Office, or GAO. On this site, you can also find information about the government wide single audit requirements, and the link to that site is on your screen. Next slide please.

So, the last topic we will cover today is award closeout. Next slide please.

Okay. So, you must complete closeout requirements within 120 days of your Grant's project period end date. Successful closeout includes several items, which are noted on your screen. And it includes submitting your final programmatic progress report and all required deliverables, ensuring that your project is compliant with all of your grant's award conditions, submitting the final federal financial report and requesting final payment for financial reconciliation. OJP will review all programmatic and financial documents to ensure that your project is complete and that all award conditions have been met. Once the closeout is verified, OJP staff will close the award in JustGrants. Next slide please.

So, I know that we've covered quite a bit of information. Here are a few high level points to remember from today's webinar. First, you should know which staff have roles in JustGrants and what those roles are. You should review your grant award package and conditions both at the beginning when you receive notice of your award and throughout the Grant's project period.

You should know who reports on what, and that applies to both programmatic performance reports and financial reports. You should continually confirm progress on your award and ensure that your spending aligns with that progress. And finally, and we've emphasized this throughout today's webinar, but I'd like to emphasize it again, please don't be afraid to ask your grant manager for help, especially when changes are needed. That is why we are here and we love to work with all of you. Next slide please.

So as a reminder, here's how you can reach us. Again, we are here to support you. All of you should know who your assigned grant manager is already and how to reach them. However, if you are not sure who your grant manager is, please email the ask SMART email address on the screen, and we will be happy to connect you. So, thank you, so much for taking time to join today's webinar. I will now open the floor for any questions that you have. Next slide please.

Samantha Opong: Thank you, Yolanda, and thank you to all the grant managers. That brings us to the portion of the webinar that is our Q&A. And as I look in the chat box, I see a couple of questions here, a few questions, and I'll just start off by reading one of the questions. This question is, will the slides of this webinar be available for us to print afterwards? The answer is yes. We will make these slides available to you all by emailing them to you by the end of the week. Okay.  

The next question is, as of yesterday, the questions in JustGrants still had the monthly data as a requirement. Are you saying that what is showing in the JustGrants now will change? Kashan, will you take that since that has very much so to deals with what you presented on.  

Kashan Alamin: Oh sure thing and great question. And I like the fact that you're starting early enough to realize that. So those questions will change. So, and I had mentioned earlier, on or about July 7th, so that's next Tuesday, you will see the new set of questions that we went through in the presentation. So just hold off on doing any submissions as of yet.

Samantha Opong: Great. Thank you. Maybe Daniel can answer this for us. What are some allowable for the AWA award?

Daniel Rappaport: Sure. Some allowable costs include salary and fringe for police and other public safety officers, digital fingerprint and palm print technology consultants, training seminars, laptops and information sharing databases. But you can find a list of allowable and unallowable costs in the SMART administration guide that we will send out after the webinar. But please be aware that the list in the guide is not an exhaustive list. So, if you're ever unsure whether an item is allowable or unallowable, just contact your grant manager and they can help you out.

Samantha Opong: Great. Thank you. Kashan, what are some best practices for the use of the new report template and ensuring correct responses to performance measure questions.  

Kashan Alamin: Great question. So first, again, we emphasize to know what the expectations are regarding our reporting. You know as well as what you're being asked to provide responses to.

Again, establish team responsibility in terms of who's doing what, when it's due, as well as where to submit your performance information. And again, routinely review the data that you're collecting. So you know, as I think we've said a million times already, please keep in touch if you have questions regarding especially these new measures. These are new. And we did try to provide a little bit of clarification by way of definitions of what we mean to better help you to, you know, realize what to submit. But again, if you have questions, please, we are your resources and partners. So your success is our success. And so anytime you have questions feel free to reach out. Thanks.

Samantha Opong: Great. Thank you. The next question, Kim, if you wouldn't mind taking this one. The writer asks, can a jurisdiction apply for multiple grant wards for different objectives and goals?

Kim Martin: Sure, Sam. Good question. A jurisdiction can apply for one grant award each cycle. That would allow for a jurisdiction to have up to one grant award with different award objectives/goals per award cycle. So, for instance, that means you can have one award from the 2023 grant cycle, one award from the 2024 grant cycle, and one in the 2025 grant cycle, all with different goals and objectives. But you can't submit two applications within the same grant cycle.

Samantha Opong: Great. Thank you. Yolanda, if you wouldn't mind taking this question. The writer asked, can I submit a grant modification with one day left in the performance period?

Yolanda Gibson: So, we recommend working with your grant manager as soon as you're aware of the possible need to submit a GAM for your award. Your grant manager can guide you on when, what, and how to submit that GAM. However, I will say that you cannot, as a grant recipient, submit a project period extension GAM with just one day left on the performance period. If you find yourself in that situation, and we really hope that you don't, but if you do, please have a conversation with your grant manager about how you can address that issue.

Samantha Opong: Thank you. Yolanda, if you wouldn't mind taking this other question. Can I purchase firearms, ammunition and/or bulletproof vests with AWA funds?

Yolanda Gibson: So unfortunately, firearms, ammunition, bulletproof vests, etc. are not allowable costs under AWA awards. However, there are some grants from other OJP offices that allow those expenses, so we encourage you to explore those opportunities.

Samantha Opong: Thank you. Someone logged in a little bit later, which is fine. This is what I said was that this is being recorded, and we will be sending out the slide deck for you to take advantage of. And should you have any questions, feel free to reach out to your assigned grant manager. And whenever we are doing trainings, giving trainings or webinars, we always send out an E blast.

So please stay tuned for that. I don't see any other questions in the chat. So that brings us to the end of today's webinar. I want to thank you again for taking the time to join us today. We hope you found the information to be helpful and valuable. We also appreciate your participation and hope the information that we shared is a support for your continued success in managing your AWA awards.

And again, we can't express enough, if you have any questions, do not hesitate to reach out to your grant managers as this is a partnership. Okay, thank you very much.