For instance, recipients should note that SLFRF funds may not be used as the non-federal share for purposes of a states Medicaid and CHIP programs because the OMB has approved a waiver from this provision as requested by the Centers for Medicare & Medicaid Services pursuant to 2 CFR 200.102 of the Uniform Guidance and related regulations. clarified that funds made available under the American Rescue Plan Act (ARP) Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) are subject to federal procurement requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), found at Title 2 of the Code of Federal Regulations, Part 200 (2 CFR 200). 12. Please limit your input to 500 characters. Some page levels are currently hidden. 200.317-318. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Each of the considerations above, as well as operation and maintenance T:919.600.7874. For example, someone from the public works department who supervises roadway paving should know whether the contractor completed the work and used the correct materials. Treasurys implementing regulations, 31 CFR part 22, and the Department of Justice (DOJ) regulations, Coordination of Non-discrimination in Federally Assisted Programs, 28 CFR part 42, provide for the collection of data and information from recipients (see 28 CFR 42.406). endstream endobj startxref Further, because it did not conduct a public procurement, the jurisdiction lost the opportunity to receive revenue from the contract. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. 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 Chapel Hill, NC27599-3330 October 2015 Procurement Bulletin Article. While data includes these things, data also includes things such as time sheets, bank statements, survey responses and water meter readings. It will include a detailed look at the various UG provisions and sample policies. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. Allowable Activities. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. Based on theAssistance Listing: Coronavirus State and Local Fiscal Recovery Fundsand Part 2 of theUS Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance(v3.0 February 2022) (Compliance Guide), the following UG provisions apply to the ARP/CSLFRF grant award: Most of these UG provisions impose process and internal control requirements, but some impose limitations on when, how, and for what purposes federal grant funds may be spent. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. The executive order requires that every goods or services contract or agreement must incorporate an auditing provision permitting the government to audit the vendors books, records and other compilations of data relative to the performance of any provision or requirement of the contract or agreement. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. See 2 C.F.R. 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 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. Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. When was the last time your client revised their procurement contracts? ARPA-funded projects must also adhere to North Carolina state law, c. 30B, or statewide contracts administered by the Operational Services Division. Public contracts account for a significant portion of every jurisdictions annual budget. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. The regulations related to allowable costs and cost principles are complex. This goal may be accomplished, in part, by using high quality data for informed decision making and risk assessment. 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. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. A level and competitive playing field should exist for all service contracts, especially when a local jurisdiction creates a market for private vendors by prompting a demand. If you are still unclear about the requirements for your particular source of funding, we recommend that you contact the grantor or federal funding entity for clarification. WebYes; there is no requirement to prove a loss in revenue. Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. 0 The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. Each category of cost should be treated consistently in like circumstances as direct or indirect, and recipients may not charge the same administrative costs to both direct and indirect cost categories, or to other programs. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. Consider whether prevailing wage rates apply. To use data in decision making, the data must exist in a format that can be analyzed. 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. contact the Office of the Inspector General. You must ensure that the vendors you are doing business with are legitimate and responsible. 584 0 obj <>/Filter/FlateDecode/ID[<835934A992BE5B40B85FB79B51E29EDE>]/Index[559 43]/Info 558 0 R/Length 119/Prev 296096/Root 560 0 R/Size 602/Type/XRef/W[1 3 1]>>stream WebRescue Plan Act (ARPA), Sections 602(b) and 603(b) of the Social Security Act, Pub. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Include a right-to-audit clause in grant agreements. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. Implement internal controls to prevent fraud, waste and abuse. MOUs and MOAs should still include the required contract provisions, https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf, https://www.govregs.com/regulations/title2_chapterII_part200. Please let us know how we can improve this page. 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. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. 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. A lock icon ( One key oversight tool is the vendor audit. Weve never been audited, so there are no benchmarks to assess our performance., Our regular business hours are third shift., We cannot remove documents from our office., Cross-charging multiple clients or departments for their staffs work, Improper employee classification e.g., junior staff hours billed at a supervisors hourly rate, Overlapping time vendor creates two or more timesheets for the employee for the same day, Schedule manipulation vendor routinely postpones or schedules jobs with higher overtime rates toward the end of the week, Over-purchasing materials for personal use, Product substitution - substituting lower-quality products for those agreed upon in the contract, Failure to apply discounts, refunds and rebates, Billing materials to one project but using for another project, Intentionally applying rates from one contract to another, Billing time and equipment rates in lump-sum, unit or fixed-price contracts. Some online survey tools even analyze data for you. 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). WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. We will update the policy if/when we receive more guidance from US Treasury. When evaluating vendor invoices, jurisdictions may determine that some expenses require further review. 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. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. Once you have access, you can use the data to inform your decisions and manage risks. The following is a sample policy: Recordkeeping Requirements. The course will have three parts, including brief overview videos, a 1-day live (Zoom) workshop, and extended daily Zoom Help Desk Office Hours the last two weeks of April (to help with implementation issues and completion of the Project & Expenditure report due by April 30). Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. %%EOF This blog post highlights the UG requirements and provides several sample policies and other implementation tools. 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)? 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. (For instance, the Department of Justice (DOJ) publishes a guide to procurements using DOJ grant funds.). The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. See M.G.L. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. 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 . ARPA-funded projects must also adhere to North Carolina Confirm that the vendor billed at the rates stated in the contract or purchase order. This page is located more than 3 levels deep within a topic. 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&. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. Within that broad term, common types of vendor audits (ranging from a less-narrow scope to a more-narrow scope) include process compliance audits, financial compliance audits, regulatory compliance audits, general compliance audits, and fraud audits. 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 Yes. See M.G.L. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. 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. For that reason it is not included in the Drop-in document. During this session, If so, are there differences between the local and federal requirements that may be in conflict? Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. Purchases made from a vendor pursuant to a General Services Administration federal supply schedule, available for use by governmental bodies, comply with the requirements of Chapter 30B. 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. Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. 559 0 obj <> endobj Further, the individuals who review and approve invoices must know the contract terms, conditions and specifications. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. endstream endobj startxref For this program, the city of Scranton has elected to award . If you need assistance, please contact the Office of the Inspector General. All documentation must be maintained for at least 5 years from the end of the award term. 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). Mayor Smiley wants to hear from you! ARPA REQUIREMENTS TO BE INCLUDED IN Track and maintain records of all grant-related documents, including communications, receipts and invoices. You skipped the table of contents section. A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. 9-10). This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. 0 195 0 obj <>stream If a local government received less than $10 million in CSLFRF funds, it may take the Process compliance audits evaluate whether the vendor is doing what it was hired to do. [1] These requirements outline the general standards and regulations for the procurement of goods and services for recipients and subrecipients of federally awarded funds. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. Finally, Kara hosted SOG Office Hours on Jan. 13, 2022, and the primary topic was the Final Rule and the change in lost revenue calculations. 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. Ensuring that the contract structure is appropriate for the goods and/or services rendered, that prices are fair based on an independent cost or price analysis, and that a cost-plus-percentage-of-cost method is not used for federally-funded contracts. The OIG is developing classes to introduce local officials to specific data analysis techniques. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. Are there special requirements for capital 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). 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. Identifying the key vendor personnel is also an important part of the audit. 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. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. Exceptions to requirements for small purchase or formal method competitive rules. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. Copyright 2009 to Present School of Government at the University of North Carolina. 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. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. A local jurisdiction recently sought guidance from the Office related to the procurement of towing and storage of motor vehicles. Per 2 CFR Part 200.303, your organization must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. Then make sure that you have access to that data. And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. Further, a prequalification or screening process for vendors interested in providing certain services, such as towing and storage, helps ensure that the public is receiving services from a qualified vendor at a reasonable price. x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. procurement policies pursuant to 2 CFR 200.317 as well as comply with the procurement standards set forth at 2 CFR 200.321 through 2 CFR 200.323, and 2 CFR 200.327. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. 6. They are SLFRF recipients that will report directly to Treasury. If you are used to having a financial statement audit, a single audit can be much more comprehensive. 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 1681 et seq., and the Departments implementing regulations, 31 CFR part 28; Age Discrimination Act of 1975, Public Law 94-135, 42 U.S.C. 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. 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.. 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. 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. ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. Come with your questions and share your experiences and insights with colleagues across the State. 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. 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. 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. The Broadly speaking, data is any fact about an object or concept. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. 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. Capital Funds Project website. WebGeneral Requirements for Procurement Programs . With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. 200.319-320 (describing the competitive processes required for procurements made with federal funds). The audit scope and appropriate approach depend on the type of audit performed. 165 0 obj <> endobj ) or https:// means youve safely connected to the official website. With the addition of the standard allowance, authorizing many NC local governments to expend their entire ARP/CSLFRF allocation for almost any purpose authorized by state law, counties and municipalities across the state have an even greater opportunity to make the best strategic investments for their communities with these one-time funds. 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. 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. Secure websites use HTTPS certificates. 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. Treasurys final rule, program guidance, and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. Each recipient should review program requirements, including Treasurys final rule and the recipients Award Terms and Conditions, to determine and record eligible uses of SLFRF funds. 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. This scope is different than what is included in the current contract and may be considered noncompetitive. 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. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. Are you missing any data that would help you monitor utilization? infrastructure, potential enhancements of state funding resources, 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. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. As an example, during a roadway paving project, the invoice reviewer should confirm that the quantity and type of asphalt listed on the invoice meets the contract requirements. Jurisdictions should build on these federal requirements to ensure that grant recipients spend grant money appropriately by implementing their own comprehensive monitoring and reporting policies. The funds can be used to purchase equipment that improves or enhances the delivery of daily Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. If you determine a need for data that does notal readyexist, you can also create data. 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. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Identify and understand the intended uses of the funds in the grant award agreement. (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. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. 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. 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 may access the slides from that session here within the next few days. The standard allowance is available to all counties, including ones with allocations under $10 million. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. Civil Rights Compliance. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. bWlLLiBg`x m [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. 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