arpa procurement requirements
What is the difference between Suspension and Debarment? Financial compliance audits examine whether the vendor is billing appropriately. 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. [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. Per 2 CFR Part 200.303, your organization must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, 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. endstream endobj 560 0 obj <. 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). 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. 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. The Identify conflicts of interest, fraudulent activities or other wrongdoing. All rights reserved. ARPA REQUIREMENTS TO BE INCLUDED IN Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. Noncompetitive procurement is only allowed if certain criteria are met. 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. hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. Generally, program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under Federal awards, and principal and interest on loans made with Federal award funds. Federal Register Publication Vol 85 No. The team needs the vendors support in order to get access to records and personnel, as well as to take action on findings. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.). Many of our past reports highlight fraudulent or inaccurate vendor billing. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. If a vendor is not registered beware. 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. Broadly speaking, data is any fact about an object or concept. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. 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. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. Fraud, waste and abuse can occur even when comprehensive contracts are in place. We hope that this article has encouraged you to use data analysis more in your work. 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 ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. The following is the schedule for the next several weeks. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. 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. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. 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. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. For example, in the scatter plot below, each of the points represents one contract. 200.317-318. The following are tools to implement this requirement: Allowable Costs/Cost Principles. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. Remember that data is a broad concept, and that analyzing the many different kinds of data your jurisdiction collects every day can enhance your decision-making processes. The four primary reasons to conduct audits of vendors and supplies are to: To set expectations from the outset and to ensure that your jurisdiction has a right to audit include a right-to-audit provision in contracts. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. Once you have access, you can use the data to inform your decisions and manage risks. Please remove any contact information or personal data from your feedback. Recipients that receive an aggregate amount of federal financial assistance in a given fiscal year that exceeds the Single Audit threshold are subject to the requirements in 2 CFR 200 Subpart F, Audit Requirements, unless otherwise specified in program-specific guidance. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. 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. 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. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. Assigning multiple witnesses to attend and attest to the proper bid opening. This goal may be accomplished, in part, by using high quality data for informed decision making and risk assessment. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. Webprocurement can be used. For example, a municipality may have an engineering and construction firm contracted to build a new community center and wants to use the same firm to perform citywide water and sewer infrastructure projects as permitted by the CLFRF. Come with your questions and share your experiences and insights with colleagues across the State. Regulatory compliance audits determine whether the vendor is following all of the laws and regulations relevant to the goods and services they provide (e.g., environmental regulations). 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. 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. 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. When was the last time your client revised their procurement contracts? 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. [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. Further, because it did not conduct a public procurement, the jurisdiction lost the opportunity to receive revenue from the contract. 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