The following is a sample policy: Recordkeeping Requirements. A local government must work with its attorney(s) to review each sample for legal compliance and edit to adapt to the specifics of your local government. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. 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. 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. See M.G.L. 117- 2 (March 11, 2021). Massachusetts jurisdictions received over $25 billion through ARPA. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. https://canons.sog.unc.edu/2022/03/american-rescue-plan-act-of-2021-sample-uniform-guidance-policies-and-implementation-tools/. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. We use data every day without realizing it. 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. This page is located more than 3 levels deep within a topic. February 2019 Procurement Bulletin Article. %%EOF A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. WebARPA established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), which is a a program that provides funding over a two-year period to all states, counties, and 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. It will be equally problematic from a compliance standpoint to have a policy your unit cannot or does not follow than to not have one at all. If the data is not in one of these formats, do not despair! These awards are as follows: Publishing and documenting clear standards in procurement solicitations and evaluation criteria on how a municipality will determine a responsive and responsible. Municipalities should ensure that factors that may be overly restrictive to free and open competition are not included, such as placing unreasonable requirements on vendors to qualify or establishing any steps in the procurement process that are arbitrary or irrelevant to the award of contracts necessary and reasonable for the implementation of the use of funds under this award. 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. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. 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 Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. 2 CFR 200.317 - 2 CFR 200.327. 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. Include a right-to-audit clause in grant agreements. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, 3) Consider publishing all sole source requests for public notice. Identifying the key vendor personnel is also an important part of the audit. WebOWRB ARPA Engineering Procurement Process . Please remove any contact information or personal data from your feedback. This helps maintain the integrity of the payment process. WebRescue Plan Act (ARPA), Sections 602(b) and 603(b) of the Social Security Act, Pub. 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. The regulations related to allowable costs and cost principles are complex. 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. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. 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. Remember to consider whether your data gives you enough information to help you make decisions. However, the Office of the Inspector General (Office) recommends that local jurisdictions use an open, fair and competitive process to acquire automobile towing and storage services. 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. Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. This can lead to drawing incorrect conclusions about the data and documentation available. Federal Register Publication Vol 85 No. 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. In the meantime, please feel free to contact us if you have any questions or ideas about data. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. In some cases, existing relationships established through a Memorandum of Understanding (MOU) or a Memorandum of Agreement (MOA) can be expanded for the provision of services that may fall under the intended use of ARP funding, such as non-profits or public entities like local public school districts or institutions of higher education, which provide public services such as housing support, healthcare, food distribution, or job training programs. If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. 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. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. Campus Box 3330 This page is located more than 3 levels deep within a topic. As you may know, under Section 1(b)(21) of Chapter 30B contracts for the towing and storage of motor vehicles are exempt from the Uniform Procurement Act. Process compliance audits evaluate whether the vendor is doing what it was hired to do. MOUs and MOAs should still include the required contract provisions,[24] monitoring and oversight requirements,[25] and cost principles[26] as identified by federal or local requirements, though they likely will not follow the same procurement process. See M.G.L. Some information may be in spreadsheets or in existing databases or electronic systems. First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. Capital Funds Project website. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. infrastructure, potential enhancements of state funding resources, If data analysis leads you to believe that fraud has occurred, please contact the OIGs Fraud Hotline at (800) 322-1323 orIGOFightFraud@state.ma.us, orfill out our online form. 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. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. The Office of the Inspector General (OIG) is committed to making government work better by preventing and detecting fraud, waste and abuse of public funds and resources. For this program, the city of Scranton has elected to award . Conducting a survey can be as simple as sending out an email or using a free online survey tool. Accordingly, your organization should develop written policies and procedures for subrecipient monitoring and risk assessment and maintain records of all award agreements identifying or otherwise documenting subrecipients compliance obligations. For that reason it is not included in the Drop-in document. Subrecipients are subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements, whereas contractors are not subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements. Are there special requirements for capital Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Then you can compile this information into a data-friendly format, like a spreadsheet. 6. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. This requirement builds on the eligible use determination. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) 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. WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. 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). Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. two (2) subrecipients to carry these programs. The feedback will only be used for improving the website. 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. A .mass.gov website belongs to an official government organization in Massachusetts. [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. hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. Because ARP/CSLFRF in the revenue replacement category may be spent on any government service authorized under state law (assuming allowable cost items), a local government may use ARP/CSLFRF to supplant employees salaries and benefits during the award term, thus freeing up general fund or enterprise fund monies to be spent on more complex capital projects or programs. This course is targeted to finance and management staff of smaller and mid-sized units that will be taking the standard allowance and spending most, if not all, of their ARP/CSLFRF as revenue replacement. Determine whether the contract allows the vendor to bill for the items listed on the invoice. A good way to start is by identifying data that would help you do your job. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. Exceptions to requirements for small purchase or formal method competitive rules. 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. Equipment and Real Property Management. Please let us know if you have any questions! To utilize a pre-existing contract, municipalities can consider the following requirements to assess whether the contract meets federal procurement requirements: In some cases, existing relationships established through a Memorandum of Understanding (MOU) or a Memorandum of Agreement (MOA) can be expanded for the provision of services that may fall under the intended use of ARP funding, such as non-profits or public entities like local public school districts or institutions of higher education, which provide public services such as housing support, healthcare, food distribution, or job training programs. 4. Request vendor timekeeping records if needed. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. Blackboardor other virtual platform login details will be emailed to registrants. Becoming overly friendly threatens the auditors independence in performing their review. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of Share sensitive information only on official, secure websites. 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. Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. Justifying and documenting the selection of vendors, including: (1) that a vendor is responsive to the requirements outlined in the procurement, (2) responsible, (3) not debarred from doing business with the federal government, and (4) offering a reasonable, competitive cost, based on cost or price analysis completed by the municipality. UNC Chapel Hill The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. We will update the policy if/when we receive more guidance from US Treasury. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. The vendor provided supporting documentation for the items or services on the invoice. [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. Identify conflicts of interest, fraudulent activities or other wrongdoing. Municipalities should also be prepared to justify and document the selection of the MOU or MOA as the most appropriate, reasonable, and cost-effective method to provide services utilizing ARP funds. 0 October 2015 Procurement Bulletin Article. Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. ) or https:// means youve safely connected to the official website. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= 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. T:919.600.7874. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. Thank you for your website feedback! All other recipients must follow 2 CFR 200.318, General procurement standards, through 200.327, Contract provisions. A lock icon or https:// means youve safely connected to the official website. If so, are there differences between the local and federal requirements that may be in conflict? Incorporate by Consider whether prevailing wage rates apply. 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. %%EOF Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. We will use this information to improve this page. Some of the data within your organization may already be in an analyzable format. The American Rescue Plan Act (ARPA), enacted in March 2021, provides state, county, local and tribal entities across the country with billions in federal aid to respond to the public health and economic effects of the COVID-19 pandemic. However, the audit team should be careful not to become too friendly with their auditees. 200.317, 200.322, and 200.326. 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. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. Recently in Massachusetts, a vendor offered a significant cost savings on supplies a local jurisdiction needed. [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. You can access that post here. Surveys are a helpful way to do this. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. 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. Civil Rights Compliance. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. WebGeneral Requirements for Procurement Programs . Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. What is the difference between Suspension and Debarment? contact the Office of the Inspector General. Now that you understand some specific techniques for visualizing and analyzing data, we encourage you to apply these techniques to procurements or other business decisions facing your jurisdiction. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. A .mass.gov website belongs to an official government organization in Massachusetts. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US 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 example, in the scatter plot below, each of the points represents one contract. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. 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. 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. This goal may be accomplished, in part, by using high quality data for informed decision making and risk assessment. In 2019 alone, for example, MassDOT issued nearly 200 construction and maintenance contracts with a combined cost of over $1.2 billion. During this session, Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. Where feasible, municipalities should consider taking steps to ensure competition is accessible to minority- and women-owned businesses in addition to labor surplus area firms. External sources are another area from which data can be gathered and used in an analysis. 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 collection does not apply to Tribal governments. 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. 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. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. 11 Uniform ARPA-funded projects must also adhere to 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. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. 601 0 obj <>stream Alternatively, if the recipient does not have a NICRA, the recipient may elect to use the de minimis rate of 10 percent of the modified total direct costs pursuant to 2 CFR 200.414(f). There is a visible correlation between the number of change orders and the contract length, which makes intuitive sense: generally, longer contracts have more change orders. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. When was the last time your client revised their procurement contracts? If you identify a fee or charge that is not accounted for in a contract between your jurisdiction and a vendor, contact the vendor for an explanation; or request a corrected invoice and a return of any improperly paid fees. 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). Use this button to show and access all levels. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. Use this button to show and access all levels. 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