All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. 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. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. The American Rescue Plan Act (ARPA), enacted in March 2021, provides state, county, local and tribal entities across the country with billions in federal aid to respond to the public health and economic effects of the COVID-19 pandemic. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. Some page levels are currently hidden. There are several techniques you could use to identify vendors to audit. ARPA REQUIREMENTS TO BE INCLUDED IN This Job Opportunity Announcement may be used to fill other Management & Program Analyst (Talent Management Specialist) GS-0343-11/12 FPL: 12 positions within the Economic L. No. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. Now that you understand some specific techniques for visualizing and analyzing data, we encourage you to apply these techniques to procurements or other business decisions facing your jurisdiction. It will include a detailed look at the various UG provisions and sample policies. While data includes these things, data also includes things such as time sheets, bank statements, survey responses and water meter readings. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. 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. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Campus Box 3330 The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. bWlLLiBg`x m A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. 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. The following are sample policies and other implementation tools for many of these award terms and UG requirements. Public contracts account for a significant portion of every jurisdictions annual budget. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. The funds can be used to purchase equipment that improves or enhances the delivery of daily The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. endstream endobj 560 0 obj <. Broadly speaking, data is any fact about an object or concept. Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. As required under 2 CFR 200, a local governments procurement program must address the following: Full and Open With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. Identify conflicts of interest, fraudulent activities or other wrongdoing. Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? One key oversight tool is the vendor audit. WebGeneral Requirements for Procurement Programs . Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. %%EOF (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) For example, per 2 CFR 200.425, a reasonably proportionate share of the costs of audits required by the Single Audit Act Amendments of 1996 are allowable; however, costs for audits that were not performed in accordance with 2 CFR Part 200, Subpart F and the Compliance Supplement are not allowable. 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. 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). Administrative costs: Recipients may use funds for administering the SLFRF program, including costs of consultants to support effective management and oversight, including consultation for ensuring compliance with legal, regulatory, and other requirements. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. There is no sure-fire method to uncover vendor fraud; therefore, it is the audit teams responsibility to remain alert and practice professional skepticism throughout the engagement. The procurement code mandates city responses be mailed to the protestor and all other applicants so as to inform them of the ability to appeal the decision related to the protest. ARPA REQUIREMENTS TO BE INCLUDED IN Ensure the agency received all of the purchased goods and services. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. Without thinking much about it, you gathered data and made a decision based on that data. We welcome non-English speakers to contact us. Massachusetts jurisdictions received over $25 billion through ARPA. Top-requested sites to log in to services provided by the state. Please let us know if you have any questions! Come with your questions and share your experiences and insights with colleagues across the State. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a 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. These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. Recipients must implement robust internal controls and effective monitoring to ensure compliance with the Cost Principles, which are important for building trust and accountability. Treasurys final rule, program guidance, and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. 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. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. Process compliance audits evaluate whether the vendor is doing what it was hired to do. 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. 601 0 obj <>stream 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. With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. Exceptions to requirements for small purchase or formal method competitive rules. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. 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. 1681 et seq., and the Departments implementing regulations, 31 CFR part 28; Age Discrimination Act of 1975, Public Law 94-135, 42 U.S.C. 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. Yes. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. The vendor provided supporting documentation for the items or services on the invoice. 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. [3] Treasury reminds that recipients and subrecipients of this funding are required to have documented processes and procedures governing procurement and contracting under this award.[4]. Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. 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. 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. Share sensitive information only on official, secure websites. Any purchase of equipment or real property with SLFRF funds must be consistent with the Uniform Guidance at 2 CFR Part 200, Subpart D. Equipment and real property acquired under this program must be used for the originally authorized purpose, unless stated otherwise by Treasury. Municipalities should also be prepared to justify and document the selection of the MOU or MOA as the most appropriate, reasonable, and cost-effective method to provide services utilizing ARP funds. Please limit your input to 500 characters. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. WebARPA Policy and Procedures Manual. Surveys are a helpful way to do this. 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. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. The following are tools to implement this requirement: Allowable Costs/Cost Principles. The smallest incongruity could lead to the discovery of a large fraud. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.). As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. 117- 2 (March 11, 2021). 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. Please include this language separately in the bid solicitation. Suggestions are presented as an open option list only when they are available. 2 CFR 200.320(c). 165 0 obj <> endobj Conducting a survey can be as simple as sending out an email or using a free online survey tool. We hope that this article has encouraged you to use data analysis more in your work. Webprocurement can be used. 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. Pursuant to the SLFRF Award Terms and Conditions, recipients are permitted to charge both direct and indirect costs to their SLFRF award as administrative costs as long as they are accorded consistent treatment per 2 CFR 200.403. And maintaining open communication with grantees regarding grant requirements and expectations will help lead to project. Manipulation undermines fair competition, can cost your jurisdiction contract did not entitle the vendor charge! Construction projects of any amount this time. ) at the various UG provisions and sample policies other... Manipulation undermines fair competition, can cost your jurisdiction, please see page 3 of the goods! @ ] - ] ~W,4 XC share sensitive information only on official, secure websites sample policies questions! Who were present and performed the work their assessment, bank statements, survey and. Used for those purposes without permission by providing acknowledgment of its source, leading disputes... 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