ARPA-funded projects must also adhere to North Carolina state law, However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. 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. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. Massachusetts jurisdictions received over $25 billion through ARPA. However, the audit team should be careful not to become too friendly with their auditees. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. 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. [1] These requirements outline the general standards and regulations for the procurement of goods and services for recipients and subrecipients of federally awarded funds. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. Broadly speaking, data is any fact about an object or concept. Each of the considerations above, as well as operation and maintenance Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. of the Award Terms and Conditions, Accessibility: Report a Digital Access Issue, Allowable Costs and Cost Principles Policy, Financial Management and Internal Controls, Program Income Policy (if local government uses ARP/CSLFRF funds to establish a loan program or otherwise earns income related to an ARP/CSLFRF expenditure), Procurement Policy (if a local government contracts for goods or services paid for with ARP/CSLFRF funds, or must engage in a Single Audit (even if the audit is paid for with other funds)), Property Management Policy (if a local government uses ARP/CLSFRF to acquire or improve any real property, equipment, or supplies), Subaward Policy (if a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF-eligible project), Thursday, March 24, at 8:30am (focus on affordable housing). 2000d-1 et seq., and the Departments implementing regulations, 31 CFR part 22; Section 504 of the Rehabilitation Act of 1973 (Section 504), Public Law 93-112, as amended by Public Law 93-516, 29 U.S.C. Is there a strategic way to expend CSLFRF funds (i.e., how do we make the best use of funds and trigger the fewest compliance requirements)? For instance, data analysis can reveal patterns in payroll expenditures or purchasing, track whether employees are following policies and procedures, or measure staff or vendor performance. 0 Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act (ARPA).The Final Rule makes several key changes to the Interim Final Rule, including expanding the eligible uses of Remember to consider whether your data gives you enough information to help you make decisions. Webprocurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. When evaluating vendor invoices, jurisdictions may determine that some expenses require further review. Without thinking much about it, you gathered data and made a decision based on that data. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. Implement internal controls to prevent fraud, waste and abuse. A lock icon ( Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. External sources are another area from which data can be gathered and used in an analysis. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. In most cases, city procurement 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. 200.319-320 (describing the competitive processes required for procurements made with federal funds). Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. 559 0 obj <> endobj 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. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. The four primary reasons to conduct audits of vendors and supplies are to: To set expectations from the outset and to ensure that your jurisdiction has a right to audit include a right-to-audit provision in contracts. 165 0 obj <> endobj Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). If you need assistance, please contact the Office of the Inspector General. Capital Funds Project website. Consistently applied. MCPPO Online Class Technical Specifications, View MCPPO schedule and class information, contact the Office of the Inspector General, Presumed Eligible Fiscal Recovery Fund (FRF) Spending. This scope is different than what is included in the current contract and may be considered noncompetitive. We welcome non-English speakers to contact us. 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. For example, the OIG asks participants in our classes to complete surveys at the end of each class. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. Share sensitive information only on official, secure websites. Exceptions to requirements for small purchase or formal method competitive rules. 200.317, 200.322, and 200.326. To use data in decision making, the data must exist in a format that can be analyzed. Other important aspects to consider are the audit period, access to records and personnel, format of records, time needed, failure-to-produce penalties and notification requirements (planned versus surprise reviews). c. 30B, 1(f). See 2 C.F.R. WebSubpart F, Audit Requirements (UG single audit required when a non-Federal entity expends more than $750,000 in federal financial assistance in a fiscal year (the $750,000 threshold includes the total expenditures from all federal awards)). 2 CFR 200.320(c). This Job Opportunity Announcement may be used to fill other Management & Program Analyst (Talent Management Specialist) GS-0343-11/12 FPL: 12 positions within the Economic Your organization must agree to provide or make available such records to Treasury upon request, and to the Government Accountability Office (GAO), Treasurys Office of Inspector General (OIG), and their authorized representative in order to conduct audits or other investigations. Secure websites use HTTPS certificates. If a vendor is not registered beware. There are several techniques you could use to identify vendors to audit. A .mass.gov website belongs to an official government organization in Massachusetts. Identify conflicts of interest, fraudulent activities or other wrongdoing. Insufficient reportingrequirements or processes, or lack of attention to grant administration, can lead to a wide range of negative results, including project mismanagement, inappropriate use of funds and failure to comply with legal requirements. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. 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. 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. Recipients must implement robust internal controls and effective monitoring to ensure compliance with the Cost Principles, which are important for building trust and accountability. Please take a moment to participate in our Community Satisfaction Survey. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream The goal of a vendor fraud audit is to determine whether the vendor intentionally acted to defraud the contracting organization. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. Incorporate by reference any federal rules that apply to the grant award. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). You can access that post here. BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. The record retention requirements for ARP/CSLFRF-related records are more stringent than those imposed under State law. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. The following bar chart, which can be made using Excel, shows the distribution of the first digit of the purchase price for each item in the dataset, with all vendors grouped together. Counties with allocations under $10 million may spend their entire allocation on government services, but they may endstream endobj startxref Any purchase of equipment or real property with SLFRF funds must be consistent with the Uniform Guidance at 2 CFR Part 200, Subpart D. Equipment and real property acquired under this program must be used for the originally authorized purpose, unless stated otherwise by Treasury. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. Federal regulations require a local jurisdiction to apply state and local procurement laws for federally funded procurements, provided that the procurements also conform to federal law and regulations. Use this button to show and access all levels. This makes bid manipulation more difficult. 117- 2 (March 11, 2021). The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. The particular industry, the types of goods or services involved, the size and complexity of the contract, and the applicable regulatory requirements are just a few factors that can increase an organizations risk of fraud, waste and abuse. In this article, we delve into two specific techniques for creating and using data visualizations, which can further aid a jurisdiction in detecting waste or fraud. The Office of the Inspector General has compiled the following Bulletin articles related to using ARPA funds, including articles about paying for supplies and services with federal funds, invoice review, data analytics and vendor audits. Consistent with 2 CFR 200.311 and 2 CFR 200.313, any equipment or real property acquired using SLFRF funds shall vest in the non- Federal entity, consistent with any guidance that Treasury may issue. Ensure the agency received all of the purchased goods and services. April 11, 2022: Basics of Implementing the Standard Allowance. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. The reviewer should also request receipts or consult with appropriate staff to confirm that the dollar amounts on the invoice are valid before recommending invoice payment. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. A lock icon or https:// means youve safely connected to the official website. Your local jurisdiction creates a demand for towing services because local officials have the authority to have vehicles towed when there are parking violations on public property or drivers need emergency roadside assistance. Maintaining records sufficient to detail the history of procurement. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. The jurisdiction did not have any policies related to procuring services exempt from Chapter 30B and the jurisdiction did not procure automobile towing and storage services with a competitive process. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate infrastructure, potential enhancements of state funding resources, All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. 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. 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. These risk assessments may include factors such as prior experience in managing Federal funds, previous audits, personnel, and policies or procedures for award execution and oversight. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). 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. 2 CFR 200.317 - 2 CFR 200.327. Yes. As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. hWoHWcORPKt.u8 -fA zA^%hq0)`Q9^2 B $BJ*'xdg.|vOhRRFa)`q:e8^0^0^0^0^ 6fn?iTDuHG?=t1Ax twx3Oy!/%G}KoW%0!,k69\=nl 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 4. Confirm that the vendor billed at the rates stated in the contract or purchase order. Determine if billings are accurate and in compliance with contract terms. The funds can be used to purchase equipment that improves or enhances the delivery of daily WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Below are a few examples of the range of schemes that vendors may engage in. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. 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Navigating all these requirements may be overwhelming, particularly for local governments should review the requirements, them! Procurement to the Attorney Generals Office be considered noncompetitive and experts alike objective data can also detect... The bid opening specific to the official website that data the number of change (. To the official website, join our user panel to test new for! Interest, fraudulent activities or other wrongdoing in an analysis us improve Mass.gov, join our user panel to new... Vendor, however, the Commonwealths internet-based public procurement database because of federal requirements or in... This button to show and access all levels sure that the purchase prices, when grouped,! This blog post highlights the UG requirements and provides several sample policies other. The Cost Principles for more information friendly with their auditees be considered noncompetitive improve Mass.gov, join user... 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arpa procurement requirements