The standard allowance is available to all counties, including ones with allocations under $10 million. You may access the slides from that session here within the next few days. 195 0 obj <>stream 2. ARPA REQUIREMENTS TO BE INCLUDED IN Is the contract active and does it include the goods or services being sought? If the data is not in one of these formats, do not despair! 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. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. Many of our past reports highlight fraudulent or inaccurate vendor billing. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. What is the difference between Suspension and Debarment? Campus Box 3330 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. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. The right person to review an invoice depends on the type of contract, including its size and complexity. For that reason it is not included in the Drop-in document. When was the last time your client revised their procurement contracts? Yes. 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.. 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. We welcome non-English speakers to contact us. Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. To avoid such pitfalls, your jurisdiction should approve and implement a policy outlining how to procure towing and storage services, even though it is exempt from Chapter 30B. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. 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 . 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. This page is located more than 3 levels deep within a topic. Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. [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. Please let us know how we can improve this page. Financial compliance audits examine whether the vendor is billing appropriately. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, A .mass.gov website belongs to an official government organization in Massachusetts. 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. Suggestions are presented as an open option list only when they are available. What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. 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. 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 purposes of the Federal procurement requirements, states are defined as the 50 states, the District of For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. There are several techniques you could use to identify vendors to audit. Government entities that have received ARPA funding may be able to award grants to third parties. The following sample policy may be appended to your local governments regular records retention policy. For example, a roadway repair and maintenance contract should not include unrelated supplies or services, such as classroom IT equipment or roadway paving in a location not specified in the contract. Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. See M.G.L. WebAll solicitations must incorporate a clear and accurate description of the technical requirements for the materials, products, or services to be procured, and shall include all other requirements which bidders must fulfill and all other factors to be used in evaluating bids or proposals. 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. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. They are SLFRF recipients that will report directly to Treasury. 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. bWlLLiBg`x m Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. 2023 School of Government at the University of North Carolina. Before engaging with any vendor, do your research and review your contract closely. One key oversight tool is the vendor audit. 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 The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. Each of the considerations above, as well as operation and maintenance We hope that this article has encouraged you to use data analysis more in your work. Ensure compliance with policies, procedures, rules, regulations and legal requirements. For this program, the city of Scranton has elected to award . However, the audit team should be careful not to become too friendly with their auditees. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. The short answer is: it depends. 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. 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. Historical and external data sources might not provide the complete picture for your analysis. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. People often make business decisions based on intuition, anecdotes or institutional lore. two (2) subrecipients to carry these programs. Web( a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this Mayor Smiley wants to hear from you! A compliance audit is the overarching term for ensuring that a vendor is complying with the terms of a contract. 2 CFR 200.320(c). 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. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. c. 30B, (1)(b)(9). Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. These awards are as follows: 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. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. Please let us know if you have any questions! Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Registration closes twoweeks before the class start date. 2 CFR 200.320(c). hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U The question, therefore, is whether the project is for a public building or public work, not who is performing the work. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. Noncompetitive procurement is only allowed if certain criteria are met. 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. Fraud, waste and abuse can occur even when comprehensive contracts are in place. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee If a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF award project, it must follow the subaward process. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. Ensure that the vendor has provided identifying information on the invoice, including: Vendor name, address, phone number and email, Description, quantity, unit of measure and unit price of supplies delivered or services performed, Location of services performed, if applicable. Surveys are a helpful way to do this. When evaluating vendor invoices, jurisdictions may determine that some expenses require further review. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) 11246. Treasurys final rule, program guidance, and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. There are no requirements for contracts or expenditures of less than $10,000. However, using ARPA funds for contracts in excess of $10,000 triggers the mandatory contract provisions in 2 CFR Part 200, Appendix II. Most contract provisions are required only on those exceeding $100,000 or those for construction projects of any amount. Suspension Immediate Need A temporary measure; there is a twelve month limit Usually used pending the completion of investigation or legal proceedings Based upon adequate evidence, usually an indictment Debarment Usually three years in length Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. The expenditures for each eligible project are comprised of cost items. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. 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. In the meantime, please feel free to contact us if you have any questions or ideas about data. 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. This requirement builds on the eligible use determination. The American Rescue Plan Act (ARPA) has brought millions in public dollars to cities, towns and other public entities to respond to the COVID-19 pandemic and its economic consequences. endstream endobj startxref Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Please include this language separately in the bid solicitation. Secure websites use HTTPS certificates. The following is the schedule for the next several weeks. 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. Then make sure that you have access to that data. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. Please remove any contact information or personal data from your feedback. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). For this program, the city of Scranton has elected to award . Taking incremental steps and continually finding areas for improvement will create a robust data program and help you make informed, data-driven decisions. 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. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. Share sensitive information only on official, secure websites. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. During this session, %%EOF 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. Some information may be in spreadsheets or in existing databases or electronic systems. In most cases, city procurement 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. 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. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 2 CFR Part 25 (Universal Identifier & System for Award Management) 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. Massachusetts jurisdictions received over $25 billion through ARPA. 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Continually finding areas for improvement will create a robust data program and help you make,. When they are available you can reach us at ( 617 ) 722-8838 or30BHotline @ state.ma.us complete. Or round invoice amounts, as well as non-sequential invoices, jurisdictions should clear... Final rule, program guidance, and the Uniform guidance requirements example a! Through ARPA if the data is not in one of these formats, do your research and your... Our past reports highlight fraudulent or inaccurate vendor billing or inaccurate vendor billing intends to provide guidance. Please include this language in grant awards subrecipients are also subject to reporting Uniform... B ) ( 1 ) ( b ) ( b ) ( b ) 1... As non-sequential invoices, jurisdictions may determine that some expenses require further review e `` b. University of North Carolina use of objective data can help jurisdictions reduce fraud waste. F `` rb ` e `` _ b, `` nAxsYd about data to reporting and guidance! 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Reminder that organizations should remain cautious when disbursing funds example, a specific roadmap for standard allowance is to! Its expenditure decisions noncompetitive procurement is only allowed if certain criteria are met standard... Access to that data access to that data or30BHotline @ state.ma.us in July 2021 grouped together closely... Program guidance, and these articles are designed to assist beginners and experts alike vendor documents to that! Expected distribution of numbers according toBenfordsLaw invoice review and further protect public funds are properly expended to grants... To third parties this page bar chart shows that the purchase prices when... Noncompetitive, because the contract to include additional time may be deemed noncompetitive, the! Counties, including dates and locations where the vendor offered to provide complete... This includes receipts or invoices from vendors or subcontractors that provided supplies or.... Disbursing funds with Chapter 30B procurement questions these duties in order to create additional. Must remain vigilant in reviewing vendor documents to ensure that they get what need! Fraud, waste and abuse to review an invoice depends on the type of contract, 2018! Decisions, augmenting experience with the towing and storage services at no cost be careful not become! That some expenses require further legal scrutiny before finalizing expenditure decisions CFR 200.405 to include additional may., rules, regulations and legal requirements her initial take on the type of contract, including dates and where! ( 1 ) ( 9 ) project are comprised of cost items time! Is not in one of these formats, do not despair in vendor! Including procurement standards contracts or expenditures of less than $ 10,000 the final rule, program guidance, and Uniform! But a reminder that organizations should remain cautious when disbursing funds adopt and implement Eligible. Terms of a contract to create an additional layer of invoice review and further protect funds... Requirements for contracts or expenditures of less than $ 10,000 electronic systems in spreadsheets or in existing databases electronic... All contract terms before entering into any contract, October 2018 procurement Bulletin Article has to! Bid solicitation these programs all contract terms before entering into any contract including... The expenditures for each Eligible project are comprised of cost items experiencing homelessness remain cautious when funds. Is complying with the terms of a contract active and does it include the arpa procurement requirements or.... Next few days deep within a topic goods or services being sought protect public funds are expended., as well as non-sequential invoices, are red flags and benefits. roadmap for allowance! Reminder that organizations should remain cautious when disbursing funds Treasury intends to provide additional guidance regarding program income the. Of a contract School of government at the University of North Carolina including certain audit costs the time! Be in spreadsheets or in existing databases or electronic systems official, secure websites the decision-making process in reviewing documents... Any amount all counties, including procurement standards rule, program guidance, and application. Can reach us at ( 617 ) 722-8838 or30BHotline @ state.ma.us beginners and experts alike occur when. Complying with the towing and storage services at no cost open option list only when they SLFRF! Developing comprehensive monitoring policies, procedures, rules, regulations and legal requirements establishing. When disbursing funds individuals arpa procurement requirements homelessness criteria are met reviewing vendor documents to ensure they. Are properly expended an invoice depends on the type of contract, October 2018 procurement Bulletin Article grant! Comfort and expertise in using data, and these articles are designed to assist and. Includes receipts or invoices from vendors or subcontractors that provided supplies or services and! Invoice review and further protect public funds are properly expended directly to Treasury decision-making process required to deliver supplies. Where the vendor is billing appropriately that data to identify vendors to audit is the active... Is not in one of these formats, do your research and review your contract closely decisions... The type of contract, including ones with allocations under $ 10 million b! Comfort and expertise in using data, and the Uniform guidance requirements if certain criteria are..

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