COMBAT Program Evaluation . Series: NIJ Solicitation Published: April 1996 18 pages 37585 bytes COMBAT Program Evaluation Introduction The National Institute of Justice (NIJ) is requesting proposals to conduct an evaluation of the Jackson County, Missouri COMmunity- Backed Anti-drug Tax (COMBAT) initiative. The COMBAT program, described in more detail below, is a locally funded effort designed to fight drugs in the county through a variety of avenues, including law enforcement, prosecution and prevention. The findings from this evaluation will be useful in informing public policy on the effectiveness of an innovative, locally initiated effort for attacking drugs, crime, and the drug-crime nexus. Results will be useful to policymakers at all levels of government, but particularly the local level where direct responsibility for providing for citizens' safety and health resides . This solicitation is a competitive announcement. One evaluation is planned. Funding will be provided by the National Institute of Justice and the Ewing Marion Kauffman Foundation. A twenty- four month project period, beginning on or about June 1, 1996, and a funding level not to exceed a total of $500,000 are anticipated. I. Program Overview In November 1989, voters in Jackson County, Missouri (Kansas City) approved a 0.25% supplement to the County sales tax. Revenue from the tax can be used only to support intensified local efforts to combat drugs. The supplementary tax went into effect in April 1990 and has since generated about $14 million in revenue each fiscal year. The tax was renewed by the voters in November 1995 when more than seventy percent voted to extend the tax for another five years. The "drug tax" and associated organizations created to disburse revenue were named the "COMBAT" program (COMmunity Backed Anti-drug Tax). The revenue from the tax is placed in a trust fund for the COMBAT program. Since its initial expenditures in 1991, COMBAT has supported a wide variety of programs to enforce drug laws, prosecute and punish offenders, prevent drug use and associated crime, and treat drug users. Major organizational and programmatic recipients of COMBAT (together with approximate annual funding levels) include: o Law enforcement ($3 million). Funding supports a variety of drug enforcement activities by the Kansas City Police Department and 13 law enforcement agencies in suburban and rural Jackson County; a multi-jurisdictional drug task force; and community policing in Kansas City. o Prosecution ($1.5 million) and Circuit Court ($0.5 million). Funding supports additional attorneys and staff for drug prosecution; a separate drug docket; community prosecution; and payment of private attorneys to supplement public defender staff. o Drug Court ($1.5 million). Funding supports deferred prosecution and treatment for first-time, non-violent offenders charged with drug possession. o Family Court ($1.5 million). Funding supports drug testing and treatment for juvenile offenders and school-based juvenile probation officers. o Prevention ($1.0 million, plus $0.75 million grant match). Funding supports programs delivered by over 30 community non-profit organizations identified through competitive RFP. o Treatment ($2.5 million, plus $0.75 million grant match). Funding supports drug treatment programs delivered by non-profit treatment organizations through competitive RFP (does not include treatment provided through deferred prosecution, courts and corrections). o Corrections ($2.5 million). Funding supports in- jail substance abuse treatment and counseling, employee drug testing, and a jail construction trust fund. Additionally, the processes of implementation, disbursement, and oversight of COMBAT funds and programs have spawned increased collaboration and cooperation among justice agencies and across units of local government in Jackson County. Administrative changes and innovations include a centralized COMBAT office and development and implementation of a uniform assessment protocol for drug treatment. II. Solicitation Request In collaboration with the Ewing Marion Kauffman Foundation, together with Jackson County and Kansas City officials, NIJ solicits proposals to evaluate the COMBAT program, associated administrative changes, and innovative approaches to funding anti- drug and other criminal justice programs. Although COMBAT encompasses a wide variety and large number of specific programs, this solicitation seeks proposals that will focus on the program and its funding mechanism as a whole. Many other jurisdictions have adopted individual programs, often funded by outside sources, similar to those funded and implemented under COMBAT. But few jurisdictions have developed the comprehensive package of programs that has evolved in Jackson County. And no other jurisdiction has funded such activities through a self-imposed tax designated specifically for anti-drug programs. NIJ, Jackson County, and the Kauffman Foundation are most interested in evaluating the unique systemic aspects of COMBAT that might benefit other jurisdictions in combating drug crime. In addition, the identification of performance measures that can routinely collected and used as indicators of the effectiveness of specific programs or groups of programs is of interest. Specific issues to be addressed by the evaluation include the following: o The COMBAT Program has identified three general objectives. The evaluation should identify to what extent evidence is available to document achieving these general objectives: (1) jail dangerous criminals; (2) treat non-violent offenders who want to get off drugs; and (3) prevent children from ever experimenting with drugs. o Cost/benefit or cost/effectiveness study of specific program activities supported by COMBAT. This component of the evaluation should distinguish sales tax revenues from revenues attributable to other sources. o One major objective of COMBAT is to support innovative activities and programs that could not otherwise be funded. Has this occurred? If so, to what extent can it be attributed to the sales tax and subsequent administrative changes? o COMBAT has sought to enhance communication and collaborative action across organizations, programs, and jurisdictions. To what extent has this occurred, and how much can be attributed to COMBAT and associated administrative structures? What are the benefits, if any, of such communication and collaboration? To what extent do such benefits rely on the presence of a central funding mechanism? Does a unitary organization responsible for comprehensive anti- drug or other criminal justice programs produce benefits that can be achieved through organizational changes alone? o Are administrative arrangements for disbursing COMBAT funds and overseeing operations appropriate? Is the particular organizational and political arrangement the most appropriate for centralizing criminal justice programs? o What is the extent of community support for COMBAT and its various elements? Are city and county residents aware of COMBAT activities? Have perceptions of community safety and quality of life increased? If so, to what extent can this be attributed to COMBAT? Do city and suburban county residents feel benefits have outweighed costs of the additional tax? o What, if any, economic development activities can be associated with COMBAT and its programs? o Should a central funding mechanism to support drug control and other criminal justice action be promoted in other jurisdictions? In some senses, the sales tax increment reflects similar funding mechanisms for other local and regional services (e.g., transportation, water treatment, schools, parks and recreation). Is there evidence to support promoting similar innovative local funding mechanisms for crime control, treatment, and prevention? o Many elements of COMBAT and associated programs embody a community focus: policing, prosecution, school-based probation counselors, funding for community treatment and prevention service providers. What benefits, if any, can be attributed to this common community focus? Can a similar common focus be produced in other jurisdictions? What, if any, role have central administrative structures of COMBAT played in promoting a common community focus? III. Application Requirements This section presents general application information, recommendations to proposal writers, and requirements for grant recipients. The application form, SF 424, is included at the end of this document. Proposals not conforming to the application procedures will not be considered. Award period. In general, NIJ limits its grants and cooperative agreements to a maximum period of 24 months. It is anticipated that this award will be for 24 months. Award amount. One evaluation will be funded under this solicitation in an amount not to exceed $500,000. NIJ anticipates issuing a grant not to exceed $250,000. The Ewing Marion Kauffman Foundation anticipates issuing a contract not to exceed $250,000. Although it is anticipated that two awards will be made to a single recipient, grant writers should prepare a single proposal for up to $500,000 and an award period not to exceed 24 months. Due date. Ten (10) copies of fully executed proposals should be sent to: COMBAT Evaluation National Institute of Justice 633 Indiana Avenue NW Washington, DC 20531 Completed proposals must be received by NIJ by close of business on June 28, 1996. Extensions of this deadline will not be permitted. Contact. The National Criminal Justice Reference Service (NCJRS), 800-851-3420, can provide copies of this solicitation and general background information on the COMBAT Program. Additional information on the COMBAT Program can be obtained by contacting Mr. James Nunnelly in the COMBAT Program in the Jackson County Prosecutor's Office at 816-881-3814. To obtain other information, prospective applicants may contact Dr. Pamela K. Lattimore, NIJ Program Manager, at 202-307-2961. V. Recommendations to Grant Writers Over the past 4 years, Institute staff have reviewed approximately 1,500 grant applications. On the basis of those reviews and inquiries from applicants, the Institute offers the following recommendations to help potential applicants present workable, understandable proposals. Many of these recommendations were adopted from materials provided to NIJ by the State Justice Institute. Others reflect standard NIJ requirements. The author(s) of the proposal should be clearly identified. Proposals that are incorrectly collated, incomplete, or handwritten will be judged as submitted or, at NIJ's discretion, will be returned without a deadline extension. No additions to the original submission are allowed. The Institute suggests that applicants make certain that they address the questions, issues, and requirements set forth below when preparing an application. 1. What is the subject or problem you wish to address? Describe the subject or problem and how it affects the criminal justice system and the public. Discuss how your approach will improve the situation or advance the state of the art of knowledge or state of the science and explain why it is the most appropriate approach to take. Give appropriate citations to the research literature. The source of statistics or research findings cited to support a statement or position should be included in a reference list. 2. What do you want to do? Explain the goal(s) of the project in simple, straightforward terms. The goals should describe the intended consequences or expected overall effect of the proposed project, rather than the tasks or activities to be conducted. To the greatest extent possible, applicants should avoid a specialized vocabulary that is not readily understood by the general public. Technical jargon does not enhance an application. 3. How will you do it? Describe the methodology carefully so that what you propose to do and how you would do it is clear. All proposed tasks should be set forth so that a reviewer can see a logical progression of tasks and relate those tasks directly to the accomplishment of the project's goal(s). When in doubt about whether to provide a more detailed explanation or to assume a particular level of knowledge or expertise on the part of the reviewers, err on the side of caution and provide the additional information. A description of project tasks also will help identify necessary budget items. All staff positions and project costs should relate directly to the tasks described. 4. What should you include in a grant application for a program evaluation? An evaluation should determine whether the proposed program, training, procedure, service, or technology accomplished the objectives it was designed to meet. Applicants seeking support for a proposed evaluation should describe the criteria that will be used to evaluate the project's effectiveness and identify program elements that will require further modification. The description in the application should include how the evaluation will be conducted, when it will occur during the project period, who will conduct it, and what specific measures will be used. In most instances, the evaluation should be conducted by persons not connected with the implementation of the procedure, training, service, or technique, or the administration of the project. 5. How will others learn about your findings? Include a plan to disseminate the results beyond the jurisdictions and individuals directly affected by the project. The plan should identify the specific methods that will be used to inform the field about the project such as the publication of journal articles or the distribution of key materials. Expectations regarding products are discussed more fully in the following section, "Requirements for Award Recipients." A statement that a report or research findings "will be made available to" the field is not sufficient. The specific means of distribution or dissemination as well as the types of recipients should be identified. Reproduction and dissemination costs are allowable budget items. Applicants must concisely describe the interim and final products and address each product's purpose, audience, and usefulness to the field. This discussion should identify the principal criminal justice constituency or type of agency for which each product is intended and describe how the constituent group or agency would be expected to use the product or report. Successful proposals will clearly identify the nature of the grant products that can reasonably be expected if the project is funded. In addition, a schedule of delivery dates of all products should be delineated. 6. What are the specific costs involved? The budget application should be presented clearly. Major budget categories such as personnel, benefits, travel, supplies, equipment, and indirect costs should be identified separately. The components of "Other" or "Miscellaneous" items should be specified in the application budget narrative and should not include set-asides for undefined contingencies. 7. How much detail should be included in the budget narrative? The budget narrative should list all planned expenditures and detail the salaries, materials, and cost assumptions used to estimate project costs. The narrative and cost estimates should be presented under the following standard budget categories: personnel, fringe benefits, travel, equipment, supplies, contracts, other, and indirect costs. For multi year projects, applicants must include the full amount of NIJ funding for the entire life of the project. This amount should be reflected in item 15g on Form 424 and line 6k on 424A. When appropriate, grant applications should include justification of consultants and a full explanation of daily rates for any consultants proposed. To avoid common shortcomings of application budget narratives, include the following information: o Personnel estimates that accurately provide the amount of time to be spent by personnel involved with the project and the total associated costs, including current salaries for the designated personnel (e.g., Project Director, 50 percent of 1 year's annual salary of $50,000 = $25,000). If salary costs are computed using an hourly or daily rate, the annual salary and number of hours or days in a work year should be shown. o Estimates for supplies and expenses supported by a complete description of the supplies to be used, nature and extent of printing to be done, anticipated telephone charges, and other common expenditures, with the basis for computing the estimates included (e.g., 100 reports x 75 pages each x $0.05/page = $375.00). Supply and expense estimates offered simply as "based on experience" are not sufficient. 8. What travel regulations apply to the budget estimates? Transportation costs and per diem rates must comply with the policies of the applicant organization, and a copy of the applicant's travel policy should be submitted as an appendix to the application. If the applicant does not have a travel policy established in writing, then travel rates must be consistent with those established by the Federal Government. The budget narrative should state which regulations are in force for the project and should include the estimated fare, the number of persons traveling, the number of trips to be taken, and the length of stay. The estimated costs of travel, lodging, ground transportation, and other subsistence should be listed separately. When combined, the subtotals for these categories should equal the estimate listed on the budget form. 9. Which forms should be used? A copy of Standard Form (SF) 424, Application for Federal Assistance, plus instructions, appears in the back of this document. Please follow the instructions carefully and include all parts and pages. In addition to SF 424, recent requirements involve certification regarding (1) lobbying; (2) debarment, suspension, and other responsibility matters; and (3) drug-free workplace requirements. The certification form that is attached to SF 424 should be signed by the appropriate official and included in the grant application. 10. What technical materials are required to be included in the application? o A one-page abstract of the full proposal, highlighting the project's purpose, methods, activities, and when known, the location(s) of field research. o A program narrative, which is the technical portion of the proposal. It should include a clear, concise statement of the problem, goals, and objectives of the project and related questions to be explored. A discussion of the relationship of the proposed work to the existing literature is expected. o A statement of the project's anticipated contribution to criminal justice policy and practice. It is important that applicants briefly cite those particular issues and concerns of present-day criminal justice policy that stimulate the proposed line of inquiry and suggest what their own investigation would contribute to current knowledge. o A detailed statement of the proposed research or study design and analytical methodologies. The proposed data sources, data collection strategies, variables and issues to be examined, and procedures of analysis to be employed should be delineated carefully and completely. When appropriate, experimental designs are encouraged because of their potential relevance to policymaking and the strength of the evidence they can produce. o The organization and management plan to conduct the study. A list of major milestones of events, activities, and products and a timetable for completion that indicates the time commitments to individual project tasks should be included. All grant activities, including writing of the final report, should be completed within the duration of the award period. o The applicant's curriculum vitae should summarize education, research experience, and bibliographic information related to the proposed work. 11. How may grant funds be used? Grant funds may be used to purchase or lease equipment essential to accomplishing the objectives of the project. The budget narrative must list such equipment and explain why the equipment is necessary. Funds may not be used for operating programs, writing texts or handbooks, training, etc. 12. To what extent may indirect costs be included in the budget estimates? It is the policy of the Institute that all costs should be budgeted directly; however, if an applicant has an indirect cost rate that has been approved by a Federal agency within the past 2 years, an indirect cost recovery estimate may be included in the budget. A copy of the approved rate agreement should be submitted as an appendix to the application. If an applicant does not have an approved rate agreement, the applicant should contact the Office of the Comptroller, Office of Justice Programs, (202) 307 0623, to obtain information about preparing an indirect cost rate proposal. 13. What, if any, matching funds are required? Units of State and local governments (not including publicly supported institutions of higher education) are encouraged to contribute a match (cash, noncash, or both) of requested funds. Other applicants also are encouraged to seek matching contributions from other Federal agencies or private foundations to assist in meeting the costs of the project. 14. Should other funding sources be listed? Applicants are expected to identify all other Federal, local, or private sources of support, including other NIJ programs, to which this or a closely related proposal has been or will be submitted. This information permits NIJ to consider the joint funding potential and limits the possibility of inadvertent duplicate funding. 15. What are the deadlines? Proposals are due to NIJ by close of business on June 28, 1996. 16. Is there a page limit? The Institute has established a limit of 30 double-spaced pages for all normal grant applications. This page limit does not include references, budget narrative, curriculum vitae, or necessary appendixes. NIJ does not wish to create elaborate regulations regarding type fonts, margins, and spacing. Applicants are cautioned, however, that obvious attempts to stretch interpretations of the Institute's limits have, in the past, caused proposal reviewers to regard such efforts 17. What is the page order? The following order is mandatory. Omission can result in rejection of the application: 1. SF 424. 2. Names and affiliations of all key persons from applicant and subcontractor(s), advisors, consultants, and Advisory Board members. Include the name of the Principal Investigator, title, organizational affiliation (if any), department (if institution of higher education), address, phone, and fax. 3. Abstract. 4. Table of Contents. 5. Budget narrative. 6. Assurances and Certifications, etc. 7. Negotiated rate agreement. 8. Program narrative. 9. References. 10. Resumes of key personnel. 18. What does the review process entail? After all applications for a competition are received, NIJ will convene a series of peer review panels of criminal justice professionals and researchers. Panel members read each proposal and meet to assess the technical merits and policy relevance of the proposed research. Panel assessments of the proposals, together with assessments by NIJ staff, are submitted to the Director, who has sole and final authority over approval and awards. Assessments will also be submitted to The Ewing Marion Kauffman Foundation for their consideration and decision making. (Note that only one applicant will be selected, as previously described.) The review is expected to take 30-to-45 days, depending on the number of applications received. Each applicant receives written comments from the peer review panel concerning the strengths and weaknesses of the proposal. These comments may include suggestions for how a revised or subsequent application to NIJ might be improved. 19. What are the criteria for an award? The essential question asked of each applicant is, "If this study were successful, how would criminal justice policies or operations be improved?" Four criteria are applied in the evaluation process: o Impact of the proposed project. o Feasibility of the approach to the issue, including technical merit and practical considerations. o Originality of the approach, including creativity of the proposal and capability of the research staff. o Economy of the approach. Applicants bear the responsibility of demonstrating to the panel that the proposed study addresses the critical issues of the topic area and that the study findings could ultimately contribute to a practical application in law enforcement or criminal justice. Reviewers will assess applicants' awareness of related research or studies and their ability to direct the research or study toward answering questions of policy or improving the state of criminal justice operations. Technical merit is judged by the likelihood that the study design will produce convincing findings. Reviewers take into account the logic and timing of the research or study plan, the validity and reliability of measures proposed, the appropriateness of statistical methods to be used, and each applicant's awareness of factors that might dilute the credibility of the findings. Impact is judged by the scope of the proposed approach and by the utility of the proposed products. Reviewers consider each applicant's understanding of the process of innovation in the targeted criminal justice agency or setting and knowledge of prior uses of criminal justice research by the proposed criminal justice constituency. Appropriateness of products in terms of proposed content and format is also considered. Applicants' qualifications are evaluated both in terms of the depth of experience and the relevance of that experience to the proposed research or study. Costs are evaluated in terms of the reasonableness of each item and the utility of the project to the Institute's program. 20. Are there any other considerations in selecting applications for an award? Projects should have a national impact or have potential relevance to a number of jurisdictions. Because of the broad national mandate of the National Institute of Justice, projects that address the unique concerns of a single jurisdiction should be fully justified. Projects that intend to provide services in addition to performing research are eligible for support, but only for the resources necessary to conduct the research tasks outlined in the proposal. The applicant's performance on previous or current NIJ grants will also be taken into consideration in making funding decisions. 21. Who is eligible to apply? NIJ awards grants to, or enters into cooperative agreements with, educational institutions, nonprofit organizations, public agencies, individuals, and profitmaking organizations that are willing to waive their fees. Where appropriate, special eligibility criteria are indicated in the solicitation. Requirements for Award Recipients Required Products Each project is expected to generate tangible products of maximum benefit to criminal justice professionals, researchers, and policymakers. In particular, NIJ strongly encourages documents that provide information of practical utility to law enforcement officials; prosecutors; judges; corrections officers; victims services providers; and Federal, State, county, and local elected officials. Products should include: o A summary of approximately 2,500 words highlighting the findings of the research and the policy issues those findings will inform. The material should be written in a style that will be accessible to policy officials and practitioners and suitable for possible publication as an NIJ Research in Brief. An NIJ editorial style guide is sent to each project director at the time of the award. o A full technical report, including a discussion of the research question, review of the literature, description of project methodology, detailed review of project findings, and conclusions and policy recommendations. o Clean copies of all automated data sets developed during the research and full documentation prepared in accordance with the instructions in the NIJ Data Resources Manual. o Brief project summaries for NIJ use in preparing annual reports to the President and the Congress. As appropriate, additional products such as case studies and interim and final reports (e.g., articles, manuals, or training materials) may be specified in the proposal or negotiated at the time of the award. Public Release of Automated Data Sets NIJ is committed to ensuring the public availability of research data and to this end established its Data Resources Program in 1984. All NIJ award recipients who collect data are required to submit a machine-readable copy of the data and appropriate documentation to NIJ prior to the conclusion of the project. The data and materials are reviewed for completeness. NIJ staff then create machine-readable data sets, prepare users' guides, and distribute data and documentation to other researchers in the field. A variety of formats are acceptable; however, the data and materials must conform with requirements detailed in Depositing Data With the Data Resources Program of the National Institute of Justice: A Handbook. A copy of this handbook is sent to each project director at the time of the award. For further information about NIJ's Data Resources Program, contact Dr. James Trudeau, (202) 307 1355. Standards of Performance by Recipients NIJ expects individuals and institutions receiving its support to work diligently and professionally toward completing a high-quality research or study product. Besides this general expectation, the Institute imposes specific requirements to ensure that proper financial and administrative controls are applied to the project. Financial and general reporting requirements are detailed in Financial and Administrative Guide for Grants, a publication of the Office of Justice Programs. This guideline manual is sent to recipient institutions with the award documents. Project directors and recipient financial administrators should pay particular attention to the regulations in this document. Program Monitoring Award recipients and Principal Investigators assume certain responsibilities as part of their participation in government-sponsored research and evaluation. NIJ's monitoring activities are intended to help grantees meet these responsibilities. They are based on good communication and open dialogue, with collegiality and mutual respect. Some of the elements of this dialogue are: o Communication with NIJ in the early stages of the grant, as the elements of the proposal's design and methodology are developed and operationalized. o Timely communication with NIJ regarding any developments that might affect the project's compliance with the schedules, milestones, and products set forth in the proposal. (See statement on Timeliness, below.) o Communication with other NIJ grantees conducting related research projects. An annual "cluster conference" should be anticipated and should be budgeted for by applicants at a cost of $1,000 for each year of the grant. o Providing NIJ on request with brief descriptions of the project in interim stages at such time as the Institute may need this information to meet its reporting requirements to the Congress. NIJ will give as much advance notification of these requests as possible, but will expect a timely response from grantees when requests are made. NIJ is prepared to receive such communication through electronic media. o Providing NIJ with copies of presentations made at conferences, meetings, and elsewhere based in whole or in part on the work of the project. o Providing NIJ with prepublication copies of articles based on the project appearing in professional journals or the media, either during the life of the grant or after. o Other reporting requirements (Progress Reports, Final Reports, and other grant products) are spelled out elsewhere in this section of the Research Plan. Financial reporting requirements will be described in the grant award documents received by successful applicants. Communications NIJ Program Managers should be kept informed of research progress. Written progress reports are required on a semi-annual basis and should inform the Program Manager of which tasks have been completed and whether significant delays or departures from the original workplan are expected. The first progress report should cover the period from the beginning date of the project through the end of the first complete quarter (quarters are January 1-March 31, April 1-June 30, July 1- September 30, and October 1-December 31). Subsequent progress reports should cover the next two quarters. All progress reports are due 30 days following the end of the reporting period. For example, if a grant is awarded in May the first progress report would cover the rest of the current quarter (through June 30) and the first complete quarter (July 1-September 30) and would be due October 31; the second progress report would cover the next two quarters (October 1-December 31 and January 1-March 31) and would be due April 30. Timeliness Grantees are expected to complete award products within the time frames that have been agreed upon by NIJ and the grantee. The Institute recognizes that there are legitimate reasons for project extensions. However, NIJ does not consider the assumption of additional research projects that impinge upon previous time commitments as legitimate reasons for delay. Projects with unreasonable delays can be terminated administratively. In this situation, any funds remaining are withdrawn. Future applications from either the project director or the recipient institution are subject to strict scrutiny and may be denied support based on past failure to meet minimum standards. Publications The Institute encourages grantees to prepare their work for NIJ publication. In cases where grantees disseminate their findings through a variety of media, such as professional journals, books, and conferences, copies of such publications should be sent to the Program Manager as they become available, even if they appear well after a project's expiration. NIJ imposes no restriction on such publications other than the following acknowledgment and disclaimer: This research was supported by grant number _____________ from the National Institute of Justice. Points of view are those of the author(s) and do not necessarily represent the position of the U.S. Department of Justice. Data Confidentiality and Human Subjects Protection Research that examines individual traits and experiences plays a vital part in expanding our knowledge about criminal behavior. It is essential, however, that researchers protect subjects from needless risk of harm or embarrassment and proceed with their willing and informed cooperation. NIJ requires that investigators protect information identifiable to research participants. When information is safeguarded, it is protected by statute from being used in legal proceedings: "[S]uch information and copies thereof shall be immune from legal process, and shall not, without the consent of the person furnishing such information, be admitted as evidence or used for any purpose in any action, suit, or other judicial, legislative, or administrative proceedings" (42 United States Code 3789g). Applicants should file their plans to protect sensitive information as part of their proposal. Necessary safeguards are detailed in 28 Code of Federal Regulations (28 CFR), Part 22. A short "how-to" guideline for developing a privacy and confidentiality plan can be obtained from NIJ program managers. In addition, the U.S. Department of Justice has adopted Human Subjects policies similar to those established by the U.S. Department of Health and Human Services. If an Institutional Review Board is necessary for this project, a copy of the Board's approval must be submitted to the National Institute of Justice prior to the initiation of data collection. Researchers are encouraged to review 28 CFR Part 46 to determine their individual project requirements.