Is the contract active and does it include the goods or services being sought? See M.G.L. The results of the survey can be transferred to a spreadsheet. The In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. Below are a few examples of the range of schemes that vendors may engage in. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. [4] 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 and 2 CFR 200.318(a). These awards are as follows: A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. As a result, your jurisdiction should consider using a competitive procurement process to ensure that there is open and fair competition with responsible vendors for these kinds of service contracts. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. We hope that this article has encouraged you to use data analysis more in your work. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. %%EOF 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 Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. When evaluating vendor invoices, jurisdictions may determine that some expenses require further review. The following are a sample subaward policy, risk assessment, subaward agreement template, and subrecipient monitoring tool (they are all in a single Word file): Although there is a lot of federal red tape to navigate regardless of how a local government expends its ARP/CSLFRF funds, there are some opportunities to reduce a local units compliance burden. All documentation must be maintained for at least 5 years from the end of the award term. Government entities that have received ARPA funding may be able to award grants to third parties. Recently, our Chapter 30B hotline has received a number of calls asking whether Chapter 30B applies when a local jurisdiction pays for supplies or services with federal funds. Some page levels are currently hidden. State Government websites value user privacy. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. Once you have access, you can use the data to inform your decisions and manage risks. (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. After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. 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. %PDF-1.6 % Government entities should only pay invoices after confirming that the vendor has satisfactorily delivered all goods, has performed all required services according to the contract and has submitted an accurate invoice. 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. 11 Uniform 117- 2 (March 11, 2021). 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. 128, 40064-40068. Determine if billings are accurate and in compliance with contract terms. 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. For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? This page is located more than 3 levels deep within a topic. 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 smallest incongruity could lead to the discovery of a large fraud. See, e.g., 2 C.F.R. 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. February 2019 Procurement Bulletin Article. They are still federal grant funds, subject to all the award terms (be sure to read this document thoroughly) and most of the provisions of the federal Uniform Guidance (UG), which is the set of regulations that apply to the administration of federal awards. Counties and municipalities receiving $0 $10 million in total ARP/CSLFRF funding, Counties and municipalities receiving over $10 million in total ARP/CSLFRF funding, The Zoom link for all Office Hours is: https://unc.zoom.us/j/94011361206?pwd=MjIzWnlzOWxtNGtoUlNjaEV3ZWNPdz09. 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. Request vendor timekeeping records if needed. Incorporate by 2023 School of Government at the University of North Carolina. 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. 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. 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. The audit scope and appropriate approach depend on the type of audit performed. 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. See M.G.L. Municipalities may explore utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits and public entities to provide additional services utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits or public entities to provide additional services utilizing ARP funding. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. Please let us know how we can improve this page. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. 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. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. Indirect costs are general overhead costs of an organization where a portion of such costs are allocable to the SLFRF award such as the cost of facilities or administrative functions like a directors office. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. 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. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. The Office of the Inspector General often reviews vendor invoices and other documents as part of its duty to prevent and detect fraud, waste and abuse. 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. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. These awards are as follows: A helpful starting point is to pull data from current and historical sources and compile it into a more data-friendly format, such as an Excel spreadsheet file. Implement internal controls to prevent fraud, waste and abuse. Yes. There are many reasons to audit contracts with vendors and suppliers. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. WebThey are awarded in accordance with the following requirements: ( i) Requests for proposals must be publicized and identify all evaluation factors and their relative importance. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. If you need assistance, please contact the Office of the Inspector General. For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. October 2015 Procurement Bulletin Article. 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). [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. The jurisdiction stopped making payments to the vendor and began to investigate whether it entered into some sort of bulk purchasing scheme. 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. two (2) subrecipients to carry these programs. We hope that this article, along with the other articles in our series on data analytics, helps you feel more confident in your ability to collect and analyze data. Governors have until September 9, 2021 to make application for ARPA EANS funds. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. The vendor provided supporting documentation for the items or services on the invoice. All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. Webprocurement can be used. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of Are there special requirements for capital A good way to start is by identifying data that would help you do your job. endstream endobj 560 0 obj <. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of In this article, we delve into two specific techniques for creating and using data visualizations, which can further aid a jurisdiction in detecting waste or fraud. Please limit your input to 500 characters. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. Share sensitive information only on official, secure websites. The U.S. Department of the Treasury (Treasury) 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). If you are used to having a financial statement audit, a single audit can be much more comprehensive. 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. Allowable Activities. If not, many of the bid documents your jurisdiction retains can be used as data sources. 9-10). 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 can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. 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. 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. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. Procurement and contracting requirements are in place as best practices to mitigate the risk of fraud, waste, or abuse of federal funds and are designed to ensure that federally funded contracts are competitive and fair. This page is located more than 3 levels deep within a topic. To learn more, view our full privacy policy. The following is the schedule for the next several weeks. In the meantime, please feel free to contact us if you have any questions or ideas about data. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. 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 . The audit team should also obtain buy-in and support from the vendors management before initiating the audit. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. Top-requested sites to log in to services provided by the state. If procurement is only possible through non-competitive methods, municipalities will need to justify use of a non-competitive procurement process, only permissible when one of the following conditions are met: the item is below the micro-purchase threshold established by the municipality; the item is only available from a single source; the public exigency or emergency will not permit a delay from publicizing a competitive solicitation; or after solicitation of a number of sources, competition is determined inadequate. See M.G.L. You skipped the table of contents section. Please include this language separately in the bid solicitation. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22, ARPA Subgrantee Agreement Template Reimbursement Based rev11.3.22, ARPA Subgrantee Agreement Template 100% Advance Payment (Very Rare-Special Circumstances) rev11.3.22, ARPA Subgrantee Agreement Template 25% Advance Payment rev11.3.22, ARPA Beneficiary Agreement Template rev11.3.22, SLFRF_Subgrantee_Budget_Exhibit 3_ 11.3.2022, SLFRF_Subgrantee_Invoice_Exhibit 4_11.3.2022. We welcome non-English speakers to contact us. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. During this session, c. 30B, 1(f). This requirement builds on the eligible use determination. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. Copyright 2009 to Present School of Government at the University of North Carolina. Likewise, auditors and investigators should be prepared for individuals who become angry or aggressive in response to routine questions, or key vendor personnel who disappear during a critical part of the audit. The standard allowance is available to all counties, including ones with allocations under $10 million. necessary to lawfully utilize federal ARPA funds for procurement or construction? We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. 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 Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. What is the difference between Suspension and Debarment? In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. Program Income. Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. 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. 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. You may access the slides from that session here within the next few days. Conducting a survey can be as simple as sending out an email or using a free online survey tool. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. Then you can compile this information into a data-friendly format, like a spreadsheet. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. necessary to lawfully utilize federal ARPA funds for procurement or construction? 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. 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