ARPA REQUIREMENTS TO BE INCLUDED IN Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Recipients of SLFRF funds should calculate, document, and record the organizations program income. Please remove any contact information or personal data from your feedback. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. This training discusses the differences between subrecipients and contractors under the federal rules, fiscal recovery fund spending that is presumed eligible due to the nature of the beneficiaries or the type of project, and rules relating to using fiscal recovery funds on capital expenditures. 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. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. See M.G.L. Maintaining clear policies governing conflicts of interest for Historical and external data sources might not provide the complete picture for your analysis. WebThe City of Detroit Office of Contracting and Procurement (OCP) requests proposals from qualified Respondents to provide procurement supportive services including reviewing &creating scopes of work, creating bid solicitations, contract development, contract negotiations and preparation of critical See more Buyers Requirements The feedback will only be used for improving the website. You can transform information from historical and external sources into usable data, and you can create new data. 200.317, 200.322, and 200.326. 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. [3] Treasury reminds that recipients and subrecipients of this funding are required to have documented processes and procedures governing procurement and contracting under this award.[4]. 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. You skipped the table of contents section. It is easy to become overwhelmed when determining how best to use this untapped resource. Process compliance audits evaluate whether the vendor is doing what it was hired to do. Proposals must be solicited from an adequate number of qualified offerors. The first step in implementing a vendor audit program is determining who to audit. Thank you for your website feedback! Knapp-Sanders Building Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. American Rescue Plan Act of 2021: Sample Uniform Guidance Policies and Implementation Tools, -Boards of Mental Health, Developmental Disabilities, & Substance Abuse, -Affordable Housing & Minimum Housing Codes, -Professional Responsibility for Government Attorneys, Purchasing, Construction, Property Transactions, -Purchasing / Purchase Contracts / Purchase Orders, Assistance Listing: Coronavirus State and Local Fiscal Recovery Funds, US Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, Subpart C, Pre-Federal Award Requirements and Contents of Federal Awards, Subpart D, Post Federal; Award Requirements, Project and Expenditure Report Tracking Template, Blog post explaining allowable cost and cost principles, Sample Allowable Cost and Cost Principles Policy, Sample Employee Effort Certification Form for 100% Covered Employees, Sample Employee Effort Certification Form for Less Than 100% Covered Employees, as outlined in paragraph 4.c. However, Chapter 30B does not apply to federally funded procurements if following Chapter 30B would conflict with federal laws or regulations. 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. A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$AqYoX%F"YC CV8OEG?+7yOet~f4e&xfqgP*1:bWn5lu-J;[:gqG5SfJ Qbu8CZq|+gBjUC5.P06. 5=;I?s=pCOsV+k 4^ "6!p ~|: 1 GW%kO &)1dwO1(SEQqm2(Rh !3I`eUb&. Review for compliance with federal procurement law requirements. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. The procurement code mandates city responses be mailed to the protestor and all other applicants so as to inform them of the ability to appeal the decision related to the protest. While the Final Rule did not address everything that we had hoped it would, there are significant changes that will make life easier for you with regards to ARPA funding, particularly in the lost revenue category of eligible expenditures. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. Without thinking much about it, you gathered data and made a decision based on that data. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. Public contracts account for a significant portion of every jurisdictions annual budget. The vendor deducted the administrative fee from the monthly payment it made to the housing authority even though this was not part of the contract between the housing authority and the vendor. Then you can compile this information into a data-friendly format, like a spreadsheet. These practices will also ensure that ARPA funding is used for its intended purpose: helping communities recover from the devastating health and economic impacts of the COVID-19 pandemic. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, 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 Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. 2. October 2015 Procurement Bulletin Article. Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. (A) statutory restrictions under the ARPA, which include: offsetting a reduction in net tax revenue, and deposits into pension funds, and (B) other restrictions on use, which include: debt service and replenishing reserves, settlements and judgments, and general restrictions. (See Final Rule pp. Establish attainable program goals and targets, and understand which expenditures are allowable under federal law. 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). While a right-to-audit clause gives the team the contractual authority to conduct the audit, getting buy-in from management will help make the audit more efficient and effective. WebProcurement Recipients are responsible for ensuring that any procurement using SLFRF funds, or payments under procurement contracts using such funds, are consistent with the procurement standards set forth in the Uniform Guidance at . Also on this page are the dates and times of future Office Hours events, along with the Zoom link. Top-requested sites to log in to services provided by the state. Then make sure that you have access to that data. Further, the individuals who review and approve invoices must know the contract terms, conditions and specifications. In order to maintain the vendors trust and cooperation, the team should only ask for information necessary to achieve the goal of the audit and documents that have a true business justification. Regulatory compliance audits determine whether the vendor is following all of the laws and regulations relevant to the goods and services they provide (e.g., environmental regulations). 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. 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). ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. Jurisdictions therefore must dedicate staff to evaluate documents and completed work reports from contractors to make sure that they have followed the contract before issuing payment. If a recipient seeks to use SLFRF funds to satisfy match or cost-share requirements for a federal grant program, the recipient should first confirm with the relevant awarding agency that no waiver has been granted for that program, that no other circumstances enumerated under 2 CFR 200.306(b) would limit the use of SLFRF funds to meet the match or cost-share requirement, and that there is no other statutory or regulatory impediment to using the SLFRF funds for the match or cost-share requirement. The short answer is: it depends. The words data and data-driven decision-making sound daunting; however, neither is something new. [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. 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. 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. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. The standard allowance is available to all counties, including ones with allocations under $10 million. 117- 2 (March 11, 2021). The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. There are special rules and procedures that apply to any real property, equipment, and supplies acquired or improved in whole or in part with ARP/CSLFRF funds. 0 You may access the slides from that session here within the next few days. Generally, your organization must maintain records and financial documents for five years after all funds have been expended or returned to Treasury, as outlined in paragraph 4.c. In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act, Treasury will collect and review information from non-Tribal recipients to ascertain their compliance with the applicable requirements before and after providing financial assistance. The following sample policy may be appended to your local governments regular records retention policy. 2023 School of Government at the University of North Carolina. The audit scope and appropriate approach depend on the type of audit performed. If a recipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. 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. Noncompetitive procurement is only allowed if certain criteria are met. The economic relief package of $1.9 trillion became law on March 11, 2021. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. 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. Come with your questions and share your experiences and insights with colleagues across the State. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. State Government websites value user privacy. Below are a few examples of the range of schemes that vendors may engage in. A lock icon ( An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. Please include this language separately in the bid solicitation. 128, 40064-40068. Or maybe you used a more sophisticated tool to make that decision for example, the weather app on your phone but in both cases you used data to decide to wear a raincoat. The following is a sample policy: Recordkeeping Requirements. Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. The prevention and detection of fraud, waste and abuse of public funds always an important issue for government entities is even more critical now that jurisdictions are receiving billions of additional dollars in ARPA funding. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. As part of this information-gathering process, team members should strive to interview as many vendor employees as possible to corroborate their evidence and ensure the team has a complete understanding of the vendors current state. 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 For example, in the scatter plot below, each of the points represents one contract. ARPA-funded projects must also adhere to North Carolina *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. WebStates are required to follow their own procurement procedures as well as the Federal requirements for procurement of recovered materials and inclusion of required contract provisions per 2 C.F.R. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. Finally, in addition to my colleagues Rebecca Badgett, who drafted some of the above UG policies, and Connor Crews, who is working on procurement and conflict of interest policies, we want to thank our two amazing research assistants, Tiffany Oliva and Abby Gostling, who drafted several of our templates and other tools. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. Properly documented. It will include a detailed look at the various UG provisions and sample policies. If not, many of the bid documents your jurisdiction retains can be used as data sources. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. Please do not include personal or contact information. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) 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