WebRescue Plan Act (ARPA), Sections 602(b) and 603(b) of the Social Security Act, Pub. As an example, the Infrastructure Investment and Jobs Act provides that SLFRF funds may be used to meet the non-federal match requirements of authorized Bureau of Reclamation projects and certain broadband deployment projects. Data is everywhere, and every function a government performs can generate valuable data. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. 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 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. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U Webprocurement can be used. 2 CFR Part 25 (Universal Identifier & System for Award Management) 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. Determine if billings are accurate and in compliance with contract terms. c. 30B, 1(d). The course will have three parts, including brief overview videos, a 1-day live (Zoom) workshop, and extended daily Zoom Help Desk Office Hours the last two weeks of April (to help with implementation issues and completion of the Project & Expenditure report due by April 30). October 2015 Procurement Bulletin Article. 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.. 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. If you are used to having a financial statement audit, a single audit can be much more comprehensive. Civil Rights Compliance. ARPA REQUIREMENTS TO BE INCLUDED IN 2000d-1 et seq., and the Departments implementing regulations, 31 CFR part 22; Section 504 of the Rehabilitation Act of 1973 (Section 504), Public Law 93-112, as amended by Public Law 93-516, 29 U.S.C. The following is a sample policy to address the specifics of property management: Note that there are some grey areas related to whether and how a local government must seek US Treasurys approval for disposal of real property, equipment, or supplies over $5,000, and whether or not a local government will have to repay US Treasury its federal share. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate 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. The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. Fraud, waste and abuse can occur even when comprehensive contracts are in place. 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. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. Copyright 2009 to Present School of Government at the University of North Carolina. BenfordsLaw should not be applied to data sets that have stated minimum and maximum values or are assigned numbers, such as interest rates, telephone numbers or social security numbers. 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. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. You skipped the table of contents section. See M.G.L. 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. October 2017 Procurement Bulletin Article, Recently, our Office learned that a vendor included administrative fees in invoices issued to a housing authority under a revenue-generating contract. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. Counties with allocations under $10 million may spend their entire allocation on government services, but they may 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. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. The first step in implementing a vendor audit program is determining who to audit. endstream endobj 560 0 obj <. Recipients of SLFRF funds should calculate, document, and record the organizations program income. 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. Look for those in the coming weeks. Did you know reporting is not the only requirement for use of American Rescue Plan Act (ARPA) funds? Federal Uniform Guidance rules apply as well. Uniform Guidance? Never heard of it? Dont worry, weve got you covered. 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). The audit team should also obtain buy-in and support from the vendors management before initiating the audit. ) or https:// means youve safely connected to the official website. 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. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. If you determine a need for data that does notal readyexist, you can also create data. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. WebStates are required to follow their own procurement procedures as well as the Federal requirements for procurement of recovered materials and inclusion of required contract provisions per 2 C.F.R. We will use this information to improve this page. Right-to-audit clauses should be specific, yet not overly restrictive, to allow the procuring entity the ability to interview key vendor personnel and review applicable documentation and records. 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. (For instance, the Department of Justice (DOJ) publishes a guide to procurements using DOJ grant funds.). It will include a detailed look at the various UG provisions and sample policies. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. The reviewer should also request receipts or consult with appropriate staff to confirm that the dollar amounts on the invoice are valid before recommending invoice payment. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. Maintaining clear policies governing conflicts of interest for c. 30B, (1)(b)(9). Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. 11 Uniform 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. Please limit your input to 500 characters. 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. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. If you are not checking invoices carefully against your contract terms and conditions, your jurisdiction may be paying more that it should; or, in the case of a revenue-generating contract, your jurisdiction may be receiving less than it should. 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 Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? In most cases, city procurement Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. Please limit your input to 500 characters. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. 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. Now is the time for school districts and municipalities across the Commonwealth to develop bid documents that are tailored to address the additional compliance requirements 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 page levels are currently hidden. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? 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. 3) Consider publishing all sole source requests for public notice. WebYes; there is no requirement to prove a loss in revenue. The public expects that the local jurisdiction protected their interests, including ensuring that the vendor is qualified and that the towing charges are reasonable; and vendors expect open and fair competitive processes when a local jurisdiction contracts for a service that it needs. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. 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. Use this button to show and access all levels. We have also learned that state agencies and municipalities can start from scratch and build the capacity to rely on data as a problem-solving tool. A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. 559 0 obj <> endobj Direct questions related to design and construction procurement to the Attorney Generals Office. The following are sample policies and other implementation tools for many of these award terms and UG requirements. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. Please include this language separately in the bid solicitation. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Please include this language separately in the bid solicitation. Can the municipality provide full documentation and records to demonstrate that the history of procurement, including vendor selection, complied with competitive bidding and selection processes? [1] These requirements outline the general standards and regulations for the procurement of goods and services for recipients and subrecipients of federally awarded funds. Is there a strategic way to expend CSLFRF funds (i.e., how do we make the best use of funds and trigger the fewest compliance requirements)? 117- 2 (March 11, 2021). Remember to consider whether your data gives you enough information to help you make decisions. A .mass.gov website belongs to an official government organization in Massachusetts. This requirement builds on the eligible use determination. To ensure that jurisdictions get the supplies and services they need and to combat fraud, waste and abuse, it is essential that jurisdictions carefully review all vendor payment requests. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. 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. 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. 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). 0 These are common red flags for potential fraud and abuse. 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