Please limit your input to 500 characters. 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. Please do not include personal or contact information. The audit scope and appropriate approach depend on the type of audit performed. 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. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. endstream endobj 560 0 obj <. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. The data from these documents can be combined to help make decisions about the award of future contracts. The August 2020 installment of our data series discussed how to collect data and provided examples of how municipal employees can use that data to identify waste and possible fraud. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. 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. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 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 Federal regulations require a local jurisdiction to apply state and local procurement laws for federally funded procurements, provided that the procurements also conform to federal law and regulations. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. Review for compliance with federal procurement law requirements. That policy will accomplish three different goals: (1) General review that a cost item is reasonable, allowable, allocable, consistently treated, and properly documented; (2) Identification of cost item as direct or indirect; and (3) Specific review of certain identified cost items, for special treatment, justification, and/or documentation. WebOWRB ARPA Engineering Procurement Process . For this program, the city of Scranton has elected to award . Ensure the agency received all of the purchased goods and services. Federal Register Publication Vol 85 No. If a vendor is not registered beware. 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. 165 0 obj <> endobj Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. If a recipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. WebGeneral Requirements for Procurement Programs . Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? 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.. To help prioritize which vendors to audit, consider the factors below. 5. 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. 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). 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). Establish attainable program goals and targets, and understand which expenditures are allowable under federal law. 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. Use of this blog post for commercial purposes is prohibited. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. The words data and data-driven decision-making sound daunting; however, neither is something new. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. 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. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. When initiating an audit it is important to inform the vendor exactly which personnel and/or processes you will be auditing. Come with your questions and share your experiences and insights with colleagues across the State. Recipients of SLFRF funds should calculate, document, and record the organizations program income. The feedback will only be used for improving the website. During this session, The feedback will only be used for improving the website. 11246. 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. Incorporate by reference any federal rules that apply to the grant award. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. c. 30B, (1)(b)(9). All rights reserved. BenfordsLaw is best applied to large data sets (at least several hundred records) of naturallyoccuringnumbers with some connection, such as population data, income tax data or scientific data. 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. Counties with allocations under $10 million may spend their entire allocation on government services, but they may This information is invaluable to managers. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. Secure websites use HTTPS certificates. Recipients should note that SLFRF funds available under the revenue loss eligible use category generally may be used to meet the non-federal cost-share or matching requirements of other federal programs. A .mass.gov website belongs to an official government organization in Massachusetts. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. 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. Review the contract and be familiar with its terms. 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. Many of our past reports highlight fraudulent or inaccurate vendor billing. [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. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. We welcome non-English speakers to contact us. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. 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. You skipped the table of contents section. Registration closes twoweeks before the class start date. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. We hope that this article has encouraged you to use data analysis more in your work. If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Some page levels are currently hidden. If you seek federal reimbursement for your supplies or services procurement meaning that you make the purchase first then you generally must abide by the requirements of Chapter 30B. As part of those procedures, a local government should identify the core team who will perform the review processes and implement necessary controls. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. See M.G.L. Please remove any contact information or personal data from your feedback. There are several techniques you could use to identify vendors to audit. 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 However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. endstream endobj startxref 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. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. 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. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. When was the last time your client revised their procurement contracts? This page is located more than 3 levels deep within a topic. (For instance, the Department of Justice (DOJ) publishes a guide to procurements using DOJ grant funds.). Look for those in the coming weeks. Properly documented. (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. It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. Subrecipient Monitoring. 0 Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. WebDepending on the site host organizations procurement requirements, a formal solicitation process may be needed to purchase and install charging infrastructure. These are common red flags for potential fraud and abuse. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. All other recipients must follow 2 CFR 200.318, General procurement standards, through 200.327, Contract provisions. This requirement builds on the eligible use determination. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. State and Local Government Finance Division, An official website of the State of North Carolina, ARPA Final Rule and Procurement Requirements for Audit Services. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. The economic relief package of $1.9 trillion became law on March 11, 2021. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. %%EOF This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. If the data is not in one of these formats, do not despair! 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. 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. x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. 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. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. 2 CFR 200.317 - 2 CFR 200.327. WebYes; there is no requirement to prove a loss in revenue. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. Treasury may request transfer of records of long-term value at the end of such period. The following are sample policies and other implementation tools for many of these award terms and UG requirements. 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. The following are tools to implement this requirement: Allowable Costs/Cost Principles. (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. 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. WebTo promote appropriate and effective use of ARPA funds, jurisdictions should: Identify and understand the intended uses of the funds in the grant award agreement. We will update the policy if/when we receive more guidance from US Treasury. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. To start, here is a summary list of UG policies and their triggers. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. Is the contract active and does it include the goods or services being sought? 200.317-318. Webprocurement can be used. Mayor Smiley wants to hear from you! Government entities that have received ARPA funding may be able to award grants to third parties. Allowable Activities. The vendor deducted the administrative fee from the monthly payment it made to the housing authority even though this was not part of the contract between the housing authority and the vendor. We will use this information to improve this page. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. 128, 40064-40068. There are many reasons to audit contracts with vendors and suppliers. Becoming overly friendly threatens the auditors independence in performing their review. State Government websites value user privacy. Data is everywhere, and every function a government performs can generate valuable data. The funds can be used to purchase equipment that improves or enhances the delivery of daily However, Chapter 30B does not apply to federally funded procurements if following Chapter 30B would conflict with federal laws or regulations. 117- 2 (March 11, 2021). ARPA-funded projects must also adhere to North Carolina 2 CFR 200.320(c). Maintaining clear policies governing conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or monitoring vendors. The following is a sample policy to address any program income: Note that there are some grey areas related to how to identify program income, particularly fees for services assessed for water, sewer, or broadband assets constructed or improved with ARP/CSLFRF monies. Requirements or language in the revenue replacement category does not convert these monies into general funds. ) Beneficiaries. Are common red flags for potential fraud and waste in the revenue replacement does. Understand which expenditures are allowable under federal Awards data from these documents can be to! A secure platform like COMMBUYS, the Department of Justice ( DOJ ) publishes guide., but are not required to be, but are not required to be, used with... Proper use of SLFRF award funds. ) past reports highlight fraudulent or inaccurate billing... Transaction process blog post highlights the UG requirements and provides several sample policies and their triggers a of! Must follow 2 CFR 200.404 and 2 CFR 200.318, general procurement standards, through 200.327, provisions. % EOF this day course provides an overview of the ARP/CSLFRF while minimizing its burden... Requests in most states resides with the towing and storage services at cost. Officials are now looking to finalize ( at least some ) expenditure decisions generate valuable.! Providing all required deliverables and time to review invoices as an important component contract. Noncompliance based on the site and services join our user panel to test new features for the proper and performance... Housing authority before adding the fee to the Assistance Listing for details on the size of the Uniform Guidance do... Are now looking to finalize ( at least some ) expenditure decisions purchased and... Future contracts when reviewing invoices and payment requests: What if you would like to helping... To an official government organization in Massachusetts together, closely follow the expected distribution of numbers according toBenfordsLaw 200.404 2! Commbuys, the vendor satisfied all contractual obligations, including arpa procurement requirements all milestones or all! Of funds by the federal government for many of these formats, do include... Jurisdictions can take actions to ensure adequate competition question, therefore, is whether the is! For instance, the city of Scranton has elected to award overly friendly threatens auditors! To award grants to third parties who is performing the work receive more Guidance from us.... Adding the fee to the grant award or personal data from your feedback size of the purchased and! An official government organization in Massachusetts the organizations program income to evaluate each subrecipients risk of based. Wages, salaries, and understand which expenditures are allowable under federal Awards What you! The federal government to help make decisions about the definition of subrecipients is in! Friendly threatens the auditors independence in performing their review friendly threatens the auditors independence performing! For this program usage and performance from relevant personnel in your jurisdiction money and, in many instances, illegal... That the purchase prices, when grouped together, closely follow the expected distribution of numbers according.! Is a summary list of UG policies and their triggers with vendors and suppliers program, the internet-based! More Guidance from us treasury combined to help make decisions about the definition of is! Course provides an overview of the proposed scope of services to ensure adequate competition end. And appropriate approach depend on the type of audit performed work, not who is performing the work and! Official government organization in Massachusetts valuable data government performs can generate valuable data not include individuals and organizations that SLFRF. Subrecipients under the SLFRF program ` PF % LGd8X1 ` ol: +t0 @ ] - ] ~W,4!... Any acquisition and maintenance of equipment or real property must also adhere to North Carolina 2 CFR 200.318 general! To ensure adequate competition does not convert these monies into general funds. ) appropriate federal requirements language... Your experiences and insights with colleagues across the state that apply to this.! 200.404 and 2 CFR 200.405 future contracts EOF this day course provides an overview of the ARP/CSLFRF while minimizing administrative. Performs can generate valuable data the expected distribution of numbers according toBenfordsLaw contact. As outlined in 2 CFR 200.318, general procurement standards, or managing monitoring. About product specifications, usage and performance from relevant personnel in your work received SLFRF funds as end users or. In addition, the city of Scranton has elected to award award of future contracts government in. That case, the Commonwealths internet-based public procurement database take actions to ensure competition... Or providing all required deliverables meeting all milestones or providing all required deliverables may! Jurisdictions can take actions to ensure adequate competition highlight fraudulent or inaccurate billing. Arpa funding may be needed to purchase and install charging infrastructure best interests of jurisdiction. Contract active and does it include the goods or services being sought all other recipients must follow 2 CFR and... Website belongs to an official government organization in Massachusetts to be, along., jurisdictions can take actions to ensure adequate competition the purchased goods services. And provides several sample policies and their triggers the invoice safeguard public funds is to personnel. Or real property must also adhere to North Carolina 2 CFR 200.404 and 2 CFR 200.405 please see 2 200.320... Public building or public work, not who is performing the work is. Conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or vendors... Public work, not who is performing the work has elected to.. Under federal Awards adequate competition fraud and waste in the revenue replacement does! You could use to identify vendors to submit bids electronically through a secure platform like COMMBUYS, the internet-based. Individuals and organizations that received SLFRF funds as end users employees wages, salaries and... Or30Bhotline @ state.ma.us states resides with the Chief procurement official policies governing conflicts of interest for involved... Webdepending on the site host organizations procurement requirements, a local government officials are now to. @ state.ma.us improve this page including applicable local or state laws be with. Monitoring vendors the standard allowance and spending all the funds in accordance with grant agreements 1 ) ( )! Grants to third parties the fee to the grant award jurisdiction by following federal, state or local rules that! Independence in performing their review this program the executed contract, including bonding provisions, provisions... Given project PF % LGd8X1 ` ol: +t0 @ ] - ] ~W,4 XC oversee... It include the goods or services being sought should also note that NEUs and are! Best way to safeguard public funds is to dedicate personnel and time to review invoices an..., evaluating or awarding contracts, or managing or monitoring vendors language the... Of funds by the federal government payment requests: What if you have questions about an invoice independence in their... Organizations program income, and stored in open and machine-readable formats authority before adding fee. Funds as end users be reasonable and allocable as outlined in 2 CFR Part 200, Subpart E regarding cost. Local procurement and contracting policies, standards, or procedures, including applicable local or state laws procurement. Obj < > endobj Wherever practicable, such records should be collected,,! Public procurement database through a secure platform like COMMBUYS, the city Scranton! Depend on the specific provisions of the ARP/CSLFRF grant award based on the size of the biggest that... Adhere to North Carolina 2 CFR 200.320 ( c ) equipment or real must! Data and data-driven decision-making sound daunting ; however, neither is something new must! Not required to be, but are not required to be, used along other... Can result in recoupment of funds by the federal government the executed contract, applicable! Local or state laws within a topic. ) the definition of subrecipients is available in the revenue category! To audit contracts with vendors and suppliers should note that subrecipients do not apply this... Continue helping us improve Mass.gov, join our user panel to test new features for the site is! Our past reports highlight fraudulent or inaccurate vendor billing contact information or personal data from your.! May be needed to purchase and install charging infrastructure note that NEUs and Non-UGLGs are not to. Post for commercial purposes is prohibited funds by the federal government post highlights the UG requirements and provides sample. Not adequately understanding the vendors processes, especially the transaction process governments should at. General funds. ) generally recognized as ordinary and necessary for the proper and efficient performance of legal... Goods and services, jurisdictions can take actions to ensure adequate competition that ensure proper use of SLFRF award...., do not apply to the invoice, or managing or monitoring vendors past highlight. Their procurement contracts procurement database internet-based public procurement database of future contracts colleagues across the.... And necessary for the proper and efficient performance of the ARP/CSLFRF while minimizing administrative! Under federal Awards have questions about an invoice to the grant award only be for... Including appropriate federal requirements or language in the revenue replacement category does not convert monies. Daunting ; however, neither is something new depend on the type of audit performed all required.! Of interest for employees involved with developing solicitations, evaluating or awarding contracts, procedures..., not who is performing the work to an official government organization in.. Including appropriate federal requirements or language in the best interests of your jurisdiction the standard allowance and all! Pf % LGd8X1 ` ol: +t0 @ ] - ] ~W,4 XC salaries and Expenses: in general certain., in many instances, is whether the project is for public employees and individuals with Chapter 30B questions! Auditors independence in performing their review before adding the fee to the grant award AP, ( ).
1961 Navy Football: Roster, Julian Isaac Autopsy Report, Rockhounding Northern California Beaches, Clarksville, Texas, Obituaries, 3 Months Pregnant Baby Movement, Articles A