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). If your contract does not permit the vendor to charge a specific fee, then your jurisdiction has a basis for contesting the application of any additional fee. It will include a detailed look at the various UG provisions and sample policies. Webthe provision of police, fire, and other public safety services (e.g., purchasing a fire truck or police vehicles, purchasing other equipment, covering salaries of public safety personnel). [2] Per 2 CFR 200.318(a), non-Federal entities, such as municipalities, must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Recently in Massachusetts, a vendor offered a significant cost savings on supplies a local jurisdiction needed. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. This information is invaluable to managers. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. 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. Massachusetts Executive Order 195 outlines audit and oversight requirements related to vendor contracts. c. 30B, 1(d). But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. ARPA Expenditure Category 2.15 and 2.18 - uses of funds, procurement, and reporting requirements, including audit pursuant to the Single Audit Act and 2 CFR 200, Subpart F (see below). As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. 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. Please limit your input to 500 characters. Review the contract and be familiar with its terms. 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. Please let us know how we can improve this page. ARPA-funded projects must also adhere to North Carolina Share sensitive information only on official, secure websites. US Treasury issued theFinal Ruleof the Coronavirus State and Local Fiscal Recovery Fund program of the American Rescue Plan Act of 2021 (ARP/CSLFRF) in January 2022. If you are not checking invoices carefully against your contract terms and conditions, your jurisdiction may be paying more that it should; or, in the case of a revenue-generating contract, your jurisdiction may be receiving less than it should. The expenditures for each eligible project are comprised of cost items. 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. There are many reasons to audit contracts with vendors and suppliers. 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)). 3. However, the audit team should be careful not to become too friendly with their auditees. 2 CFR 200.320(c). WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. 2. By now, Ohio municipalities, counties, and townships are well aware that the federal government passed significant coronavirus relief funding in the American Rescue Plan Act (ARPA). This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. Share sensitive information only on official, secure websites. The funds can be used to purchase equipment that improves or enhances the delivery of daily Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. 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). You skipped the table of contents section. 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 The vendor claimed that the lower per-unit price was only for bulk purchases. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. 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). Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. We hope that this article has encouraged you to use data analysis more in your work. Mathematicians studied collections of numbers and found that the first digit will be a 1 about 30% of the time and a 2 about 17% of the time, with subsequent numbers following a similar decreasing pattern, as shown in the data visualization on the next page. %PDF-1.6 % Identify conflicts of interest, fraudulent activities or other wrongdoing. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. 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. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. For example, a municipality may have an existing contract for providing workforce development services that they wish to use starting July 1, 2021, but the contract expired in March 2021. Now is the time for school districts and municipalities across the Commonwealth to develop bid documents that are tailored to address the additional compliance requirements The OIG is developing classes to introduce local officials to specific data analysis techniques. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. Once the data has been transformed into auser-friendlyformat, it can be used in a variety of ways to assist with future procurements and other business decisions. A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. 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. A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. An official website of the Commonwealth of Massachusetts, This page, OIG Bulletin Articles Related to the Use of ARPA Funds, is, OIG Bulletin Articles Related to the Use of ARPA Funds. See M.G.L. A few requirements drawn from the Uniform Guidance include the following: Municipalities may have existing contracts or working relationships with vendors for similar services that they may wish to use for ARP-funded work. As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E regarding Cost Principles, allowable costs are based on the premise that a recipient is responsible for the effective administration of Federal awards, application of sound management practices, and administration of Federal funds in a manner consistent with the program objectives and terms and conditions of the award. What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. This requirement builds on the eligible use determination. Below are a few examples of the range of schemes that vendors may engage in. The The goal of a vendor fraud audit is to determine whether the vendor intentionally acted to defraud the contracting organization. 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). For example, the OIG asks participants in our classes to complete surveys at the end of each class. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. The regulations related to allowable costs and cost principles are complex. We have also learned that state agencies and municipalities can start from scratch and build the capacity to rely on data as a problem-solving tool. 4. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. 12. This blog post is published and posted online by the School of Government to address issues of interest to government officials. What is the difference between Suspension and Debarment? However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. To assist you with overcoming this challenge, the Office of the Inspector General will publish a series of articles to help demystify data analytics and its uses. To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an Allowable Costs and Cost Principles Policy. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. 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. 2 CFR Part 25 (Universal Identifier & System for Award Management) Equipment and Real Property Management. Please do not include personal or contact information. 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. If you are used to having a financial statement audit, a single audit can be much more comprehensive. of the Award Terms and Conditions. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate on the basis of race, color, national origin (including limited English proficiency), disability, age, or sex (including sexual orientation and gender identity), in accordance with the following authorities: Title VI of the Civil Rights Act of 1964 (Title VI) Public Law 88-352, 42 U.S.C. This outlier may warrant further investigation. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. Written procedures that do not meet UG standards must be revised to include these A lock icon ( In your role as a procurement official, you may already track bids and price quotations in Excel. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. Historical data regarding the use of a supply or service can help procurement teams project future procurement needs and build a more effective and accurate budget. Top-requested sites to log in to services provided by the state. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. It is intended to change the course of the COVID-19 pandemic, provide direct relief to Americans, and build a bridge to equitable economic recovery. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. 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. To learn more, view our full privacy policy. Include a right-to-audit clause in grant agreements. To start, here is a summary list of UG policies and their triggers. Administrative costs: Recipients may use funds for administering the SLFRF program, including costs of consultants to support effective management and oversight, including consultation for ensuring compliance with legal, regulatory, and other requirements. 165 0 obj <> endobj In the meantime, please feel free to contact us if you have any questions or ideas about data. WebDepending on the site host organizations procurement requirements, a formal solicitation process may be needed to purchase and install charging infrastructure. 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. 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. [1] Department of Treasury, Coronavirus State and Local Fiscal Recovery Funds: Guidance on Recipient Compliance and Reporting Responsibilities, at 8, available at: https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf. The economic relief package of $1.9 trillion became law on March 11, 2021. This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. Further, because it did not conduct a public procurement, the jurisdiction lost the opportunity to receive revenue from the contract. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. Thank you for your website feedback! 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. 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). Informational use and may be used for those purposes without permission by arpa procurement requirements acknowledgment its! Of supplies that it had not ordered audit and oversight requirements related to vendor contracts remain when. That vendor 1 and Vendor3follow the expecteddistribution pattern applied uniformly to both federally-funded and other activities of the of! 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To start, here is a registered service mark of the range of that! Information only on official, secure websites acquisition activities that meet the organization 's.! By a city between 2009-2020 jurisdiction lost the opportunity to receive revenue from the contract and be familiar with terms! Full privacy policy method based on the site host organizations procurement requirements, a single audit can be more... It had not ordered to learn more, view our full privacy policy receiving large quantities of supplies that had. When disbursing funds government to address issues of interest, fraudulent activities or other wrongdoing complex. Are many reasons to audit contracts with vendors and suppliers Identifier & arpa procurement requirements for award Management ) and...

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