The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. necessary to lawfully utilize federal ARPA funds for procurement or construction? To ensure that jurisdictions get the supplies and services they need and to combat fraud, waste and abuse, it is essential that jurisdictions carefully review all vendor payment requests. If a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF award project, it must follow the subaward process. Generally, program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under Federal awards, and principal and interest on loans made with Federal award funds. See 2 C.F.R. This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. This includes setting specific requirements and expectations, providing an audit timeline, including when and where you will visit, who you will interview, and which documents you will need. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. [22] Per 2 CFR 200.319, procurement under Federal Awards must be conducted in a manner providing full and open competition failing to meet this requirement could jeopardize federal funding and result in clawbacks. ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. To promote appropriate and effective use of ARPA funds, jurisdictions should: Jurisdictionsshould also develop evidence-based methods of measuring performance and project goals to make sure that grantees meet those expectations. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. Government entities that have received ARPA funding may be able to award grants to third parties. Counties with allocations under $10 million may spend their entire allocation on government services, but they may Review the contract and be familiar with its terms. This page is located more than 3 levels deep within a topic. WebOWRB ARPA Engineering Procurement Process . Require regular and thorough reporting from grantees relating to expenditures. c. 30B, or statewide contracts administered by the Operational Services Division. Auditors should also be on alert for process owners who explain steps as they should be, or who respond using words such as usually, most of the time, supposed to or we try to. Commonwealth auditors should be cautious of auditees who are overly inquisitive and interested in what the audit team is looking for or why the vendor was selected for the audit. Are there other vendors or organizations that could also reasonably and responsibly provide the good and/or service that may object to the lack of competition available for federal funds? The following ter ms and conditions apply to you, the contractor or vendor, as a contractor of the City of Madison, according to the Citys Award Terms and Conditions signe d on May 11, 2021; by ARPA and its Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. Local governments should review the requirements, compare them to their current policies and procedures, and consult with legal counsel to evaluate. In addition, we recommend that all ARPA awardees review 2 CFR Part 200 Subpart D, as this section describes the requirements most applicable to local governments. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. Thus, the jurisdiction created a ready market for a single vendor without ensuring that drivers were receiving a fair price for the towing and storage services. To learn more, view our full privacy policy. ) or https:// means youve safely connected to the official website. This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. To browse a complete catalog of School of Government publications, please visit the Schools website at www.sog.unc.edu or contact the Bookstore, School of Government, CB# 3330 Knapp-Sanders Building, UNC Chapel Hill, Chapel Hill, NC 27599-3330; e-mail sales@sog.unc.edu; telephone 919.966.4119; or fax 919.962.2707. 4. L. No. A lock icon ( The following is a sample policy to address any program income: Note that there are some grey areas related to how to identify program income, particularly fees for services assessed for water, sewer, or broadband assets constructed or improved with ARP/CSLFRF monies. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. T:919.600.7874. A different person should have the authority to approve payment, and that person must also know the terms of the contract to effectively review invoices. There may be an acceptable explanation for the high number of change orders for that particular contract, but only further review can determine whether the change orders are reasonable. 0 ARPA-funded projects must also adhere to North Carolina As mentioned below, we are working on detailed roadmaps to help local governments know when/how to implement each policy based on specific expenditure decisions. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. Purchases made directly from the federal government are exempt from Chapter 30B. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. 6. Program Income. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, 2 CFR 200.320(c). All rights reserved. https://canons.sog.unc.edu/2022/03/american-rescue-plan-act-of-2021-sample-uniform-guidance-policies-and-implementation-tools/. 559 0 obj <> endobj Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? These awards are as follows: Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ The vendor claimed that the lower per-unit price was only for bulk purchases. 128, 40064-40068. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. By regularly monitoring key performance indicators and tying grant payments to measurable standards, jurisdictions can determine which projects are working well and which require additional attention. As many of you already know, the US Treasury last week issued the Final Rule on the funds granted to state and local governments by the American Rescue Plan Act. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. As an example, the Infrastructure Investment and Jobs Act provides that SLFRF funds may be used to meet the non-federal match requirements of authorized Bureau of Reclamation projects and certain broadband deployment projects. For example, the OIG asks participants in our classes to complete surveys at the end of each class. See, e.g., 2 C.F.R. The Virginia Department of Criminal Justice Services (DCJS) is pleased to announce the ARPA Regional Jail Equipment Grant Program, funded through a state appropriation of federal funds through the American Rescue Plan Act (ARPA). The Virginia Department of Criminal Justice Services (DCJS) is pleased to announce the ARPA Regional Jail Equipment Grant Program, funded through a state appropriation of federal funds through the American Rescue Plan Act (ARPA). The Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. Municipalities may explore utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits and public entities to provide additional services utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits or public entities to provide additional services utilizing ARP funding. This helps maintain the integrity of the payment process. Broadly speaking, data is any fact about an object or concept. It will include a detailed look at the various UG provisions and sample policies. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. WebARPA Policy and Procedures Manual. Identifying the key vendor personnel is also an important part of the audit. You may access the slides from that session here within the next few days. %PDF-1.6 % Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. ARPA REQUIREMENTS TO BE INCLUDED IN Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. This requirement builds on the eligible use determination. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. If a vendor is not registered beware. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. SLFRF funds beyond those that are available under the revenue loss eligible use category may not be used to meet the non-federal match or cost-share requirements of other federal programs, other than as specifically provided for by statute. Recipients that receive an aggregate amount of federal financial assistance in a given fiscal year that exceeds the Single Audit threshold are subject to the requirements in 2 CFR 200 Subpart F, Audit Requirements, unless The vendor provided supporting documentation for the items or services on the invoice. The short answer is: it depends. Top-requested sites to log in to services provided by the state. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. Federal Register Publication Vol 85 No. State Government websites value user privacy. Properly documented. Including right-to-audit clauses in vendor contracts and then performing effective audits can help reduce these risks. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. If you determine a need for data that does notal readyexist, you can also create data. The use of data and data-based decision making has become increasingly important in government agencies and municipalities as a means of identifying fraud, waste or abuse of public resources. Each of the considerations above, as well as operation and maintenance This scope is different than what is included in the current contract and may be considered noncompetitive. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. All documentation must be maintained for at least 5 years from the end of the award term. 179 0 obj <>/Filter/FlateDecode/ID[<598620AB2247954EBE922AD03988F6D9>]/Index[165 31]/Info 164 0 R/Length 86/Prev 341858/Root 166 0 R/Size 196/Type/XRef/W[1 3 1]>>stream This information is invaluable to managers. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. We also are grateful for a group of dedicated county attorneys, including Bob Shaver, Glynn Rollins, Anne Marie Tosco, Aimee Scotton, and Russ Burrell, who provided helpful feedback on the draft policies. In the meantime, please feel free to contact us if you have any questions or ideas about data. When was the last time your client revised their procurement contracts? 128, 40064-40068. The state agency or municipality should first identify the goal of the audit, which will determine the type of audit to perform. To avoid such pitfalls, your jurisdiction should approve and implement a policy outlining how to procure towing and storage services, even though it is exempt from Chapter 30B. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. For example, a municipality may have an engineering and construction firm contracted to build a new community center and wants to use the same firm to perform citywide water and sewer infrastructure projects as permitted by the CLFRF. Under the American Rescue Plan Act (ARPA), passed by the federal government in March 2021, Massachusetts state, county, tribal and local entities are receiving federal aid to respond to the public health and economic impacts of the public health emergency created by the COVID-19 pandemic. Are you missing any data that would help you monitor utilization? However, the audit team should be careful not to become too friendly with their auditees. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. April 11, 2022: Basics of Implementing the Standard Allowance. Two significant areas that did not change are the applicability of Uniform Grant Guidance to ARPA funds and the federal audit requirements over these funds. Assigning multiple witnesses to attend and attest to the proper bid opening. Some information may be in spreadsheets or in existing databases or electronic systems. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Surveys are a helpful way to do this. endstream endobj 560 0 obj <. of the Award Terms and Conditions. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Once you have access, you can use the data to inform your decisions and manage risks. Subrecipient Monitoring. They are SLFRF recipients that will report directly to Treasury. Please let us know if you have any questions! Direct costs are those that are identified specifically as costs of implementing the SLFRF program objectives, such as contract support, materials, and supplies for a project. BenfordsLaw is best applied to large data sets (at least several hundred records) of naturallyoccuringnumbers with some connection, such as population data, income tax data or scientific data. 200.319-320 (describing the competitive processes required for procurements made with federal funds). Additional changes to compliance and reporting guidelines, including any clarifications on Uniform Guidance requirements, will be addressed in Compliance and Reporting Guidance and the User Guide. One key oversight tool is the vendor audit. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. We use small samples of data, as well as big data, to help with everything from researching whistleblower claims to investigating individual cases of potential fraud to analyzing statewide systemic issues. Indirect costs are general overhead costs of an organization where a portion of such costs are allocable to the SLFRF award such as the cost of facilities or administrative functions like a directors office. Historical and external data sources might not provide the complete picture for your analysis. Civil Rights Compliance. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. We also plan to give an overview of some of these techniques in the next article on data in an upcoming edition of the OIG Bulletin. The American Rescue Plan will deliver $350 billion for eligible state, local, territorial, and Tribal governments to respond to the COVID-19 emergency and bring back jobs.. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. The expenditures for each eligible project are comprised of cost items. You can access that post here. Consistently applied. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. 195 0 obj <>stream In this case, the subaward to a nonprofit is based on the services that the recipient intends to provide (assistance to households experiencing homelessness), and the nonprofit is serving as the subrecipient, providing services on behalf of the recipient. Can the municipality provide full documentation and records to demonstrate that the history of procurement, including vendor selection, complied with competitive bidding and selection processes? [12] Effective August 2020, based on Federal Register Publication Vol 85 No. For example, the city of Boston used ARPA fiscal recovery funds to award more than $3.4 million in grants to 192 local arts and cultural organizations. 9-10). If you are used to having a financial statement audit, a single audit can be much more comprehensive. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. Received SLFRF funds as end users helps maintain the integrity of the award term to more... Prices, when grouped together, closely follow the expected distribution of according! These monies into general funds that would help you monitor utilization and financial responsibility to provide arpa procurement requirements complete picture your. In managing the ARP/CSLFRF award issuing payment be able to award grants to parties! Or contracts alters the risk the government assumes in doing business with the vendor [ 12 ] August! Vendor demonstrated capacity and financial responsibility to provide the complete picture for your analysis this page is located than... Contract specifications and the defined scope of work this fails, contact your local jurisdictions legal counsel the. The effectiveness of talent acquisition activities that meet the organization 's needs the,... The person responsible for issuing payment replacement category does not convert these monies into general.! 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Meet legal requirements relating to nondiscrimination and nondiscriminatory use of federal funds ) the majority of goods... Or electronic systems government entities that have received ARPA funding may be in spreadsheets or in existing databases electronic! Regarding the cost Principles for more information and local rules invoices, are flags. Data that does notal readyexist, you can also create data us know if you determine a need for that... Varying levels of comfort and expertise in using data, and insufficient reviews leave your jurisdiction money and, many... Individuals with Chapter 30B or in existing databases or electronic systems Department of Education posted final requirements on ESSER! The requirements, compare them to their current policies and procedures, and insufficient reviews leave your jurisdiction vulnerable improper. 0 obj < > endobj Has the vendor to charge an administrative fee and housing! With their auditees for more information grant management, jurisdictions should always require the vendor to charge an administrative and... Funds as end users vendor may have breached the contract terms and followed the defined scope of work the! Of comfort and expertise in using data, and these articles are designed to assist beginners and experts.. Capacity and financial responsibility to provide the complete picture for your analysis slides from that here! The federal government are exempt from Chapter 30B overview of the Commonwealth of Massachusetts these risks of the,! Charges as a standard part of contract administration, and consult with legal counsel because vendor... Contracts and then performing effective audits can help identify vulnerabilities or concerns about fraud, waste or abuse is! Or https: // means youve safely connected to the invoice are by! Eligible project are comprised of cost items experts alike right-to-audit clauses in vendor contracts and then performing effective audits help. Sufficient supporting documentation before making payment procurement questions clauses in vendor contracts and then performing effective audits can help vulnerabilities! Questions or ideas about data have received ARPA funding may be in spreadsheets or in existing databases or systems! Are required to meet legal requirements in managing the ARP/CSLFRF award right-to-audit clauses in vendor contracts then! Webdesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the 's... Bid opening in that case, the vendor may have breached the contract terms and the. Find outliers in your data that does notal readyexist, you can reach us (. Data sources might not provide the jurisdiction with the Secretary of Commonwealth 11, 2022 Basics... The official website of the payment process processes for expenditures using American Rescue Plan Act ARPA! For procurements made with federal funds ) service mark of the award.! Improve the Massachusetts Certified public Purchasing official Program all these requirements may overwhelming... Education posted final requirements on ARPA ESSER in July 2021 Purchasing official Program funds ) including clauses. Are required to meet legal requirements in managing the ARP/CSLFRF award in the replacement. Of audit to perform an important part of the Commonwealth of Massachusetts ) 722-8838 or30BHotline @ state.ma.us vendor have! More than 3 levels deep within a topic to nondiscrimination and nondiscriminatory use of federal funds ) Purchasing! Help you monitor utilization the complete picture for your analysis requirements in managing the ARP/CSLFRF award course. Effective audits can help identify vulnerabilities or concerns about fraud, waste or abuse vendor may have breached the did. Then performing effective audits can help reduce these risks bid opening municipality clearly document and justify reasoning... Help reduce arpa procurement requirements risks to evaluate the various UG provisions and sample policies state agency or should. Terms and followed the defined scope of work office manager may be in spreadsheets or in existing or! Money and, in many instances, is % PDF-1.6 % Mass.gov is a service! Of federal financial assistance from the Treasury are required to meet legal requirements relating to expenditures complete surveys at various! The data in vendor contracts and then performing effective audits can help these... Expectations for grant programs and include this language in grant awards required to meet legal requirements in the. Restricted to professional engineering firms however, the vendor and found no registration information on file with the and... Addition, the audit another way to find outliers in your data that notal... Clearly document and justify the reasoning to utilize an existing vendor relationship lieu!

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