arpa procurement requirements

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A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. %PDF-1.6 % 11 Uniform Weve never been audited, so there are no benchmarks to assess our performance., Our regular business hours are third shift., We cannot remove documents from our office., Cross-charging multiple clients or departments for their staffs work, Improper employee classification e.g., junior staff hours billed at a supervisors hourly rate, Overlapping time vendor creates two or more timesheets for the employee for the same day, Schedule manipulation vendor routinely postpones or schedules jobs with higher overtime rates toward the end of the week, Over-purchasing materials for personal use, Product substitution - substituting lower-quality products for those agreed upon in the contract, Failure to apply discounts, refunds and rebates, Billing materials to one project but using for another project, Intentionally applying rates from one contract to another, Billing time and equipment rates in lump-sum, unit or fixed-price contracts. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. [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. Incorporate by reference any federal rules that apply to the grant award. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. When was the last time your client revised their procurement contracts? 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. L. No. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. 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. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. WebSourcing & Procurement. If a vendor is not registered beware. If a local government received less than $10 million in CSLFRF funds, it may take the 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. The following ter ms and conditions apply to you, the contractor or vendor, as a contractor of the City of Madison, according to the Citys Award Terms and Conditions signe d on May 11, 2021; by ARPA and its It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. 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. 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). The expenditures for each eligible project are comprised of cost items. If you are used to having a financial statement audit, a single audit can be much more comprehensive. Top-requested sites to log in to services provided by the state. Ensure compliance with policies, procedures, rules, regulations and legal requirements. 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. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. ) or https:// means youve safely connected to the official website. 559 0 obj <> endobj The first step in implementing a vendor audit program is determining who to audit. 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. Chapel Hill, NC27599-3330 For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. 2023 School of Government at the University of North Carolina. 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. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. Please remove any contact information or personal data from your feedback. 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 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. ) or https:// means youve safely connected to the official website. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). Thus, the jurisdiction created a ready market for a single vendor without ensuring that drivers were receiving a fair price for the towing and storage services. endstream endobj startxref 2 CFR 200.317 - 2 CFR 200.327. 117- 2 (March 11, 2021). [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. 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. What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. To browse a complete catalog of School of Government publications, please visit the Schools website at www.sog.unc.edu or contact the Bookstore, School of Government, CB# 3330 Knapp-Sanders Building, UNC Chapel Hill, Chapel Hill, NC 27599-3330; e-mail sales@sog.unc.edu; telephone 919.966.4119; or fax 919.962.2707. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Recipients of SLFRF funds should calculate, document, and record the organizations program income. It will include a detailed look at the various UG provisions and sample policies. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate Are you missing any data that would help you monitor utilization? Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. Counties with allocations under $10 million may spend their entire allocation on government services, but they may Recipients must implement robust internal controls and effective monitoring to ensure compliance with the Cost Principles, which are important for building trust and accountability. Webprocurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. Financial compliance audits examine whether the vendor is billing appropriately. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. These are common red flags for potential fraud and abuse. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. 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 If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. Consistent with 2 CFR 200.311 and 2 CFR 200.313, any equipment or real property acquired using SLFRF funds shall vest in the non- Federal entity, consistent with any guidance that Treasury may issue. https://canons.sog.unc.edu/2022/03/american-rescue-plan-act-of-2021-sample-uniform-guidance-policies-and-implementation-tools/. For this program, the city of Scranton has elected to award . Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. 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. Alternatively, if the recipient does not have a NICRA, the recipient may elect to use the de minimis rate of 10 percent of the modified total direct costs pursuant to 2 CFR 200.414(f). 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. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. ARPA Expenditure Category 2.15 and 2.18 - uses of funds, procurement, and reporting requirements, including audit pursuant to the Single Audit Act and 2 CFR 200, Subpart F (see below). *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. 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 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). You skipped the table of contents section. 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. Also, remember the following: 1. As an example, during a roadway paving project, the invoice reviewer should confirm that the quantity and type of asphalt listed on the invoice meets the contract requirements. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. 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. We also plan to give an overview of some of these techniques in the next article on data in an upcoming edition of the OIG Bulletin. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. We hope that this article, along with the other articles in our series on data analytics, helps you feel more confident in your ability to collect and analyze data. Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. If you determine a need for data that does notal readyexist, you can also create data. Recipients should consult the final rule for further details if they seek to utilize SLFRF funds as a match for these projects. For this program, the city of Scranton has elected to award . A lock icon ( The question, therefore, is whether the project is for a public building or public work, not who is performing the work. 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. Review the contract and be familiar with its terms. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. The funds can be used to purchase equipment that improves or enhances the delivery of daily 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. WebThe Buy American requirements apply to all Recovery Act funds used for a project for the construction, alteration, maintenance, or repair of a public building or public work. 2 CFR 200.320(c). 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. Suggestions are presented as an open option list only when they are available. Direct costs are those that are identified specifically as costs of implementing the SLFRF program objectives, such as contract support, materials, and supplies for a project. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) Before engaging with any vendor, do your research and review your contract closely. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. The ARPA program requires recipients to comply with the procurement provisions of Title 2, Part 200 of the Code of Federal 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. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. Maintaining clear policies governing conflicts of interest for [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. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. Treasury may request transfer of records of long-term value at the end of such period. 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. 200.317-318. Maintaining records sufficient to detail the history of procurement. Capital Funds Project website. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. 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. 6. 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? Please do not include personal or contact information. 4. 179 0 obj <>/Filter/FlateDecode/ID[<598620AB2247954EBE922AD03988F6D9>]/Index[165 31]/Info 164 0 R/Length 86/Prev 341858/Root 166 0 R/Size 196/Type/XRef/W[1 3 1]>>stream This blog post highlights the UG requirements and provides several sample policies and other implementation tools. Expenditure decisions specific roadmap for standard allowance local governments looking to spend full. Are presented as an open option list only when they are available financial compliance audits examine whether the for. Federal requirements or language in the executed contract, including bonding provisions contract... Be used for improving the website the expenditures for each eligible project are comprised cost. Andrunning the same analysis, in part, on its expenditure decisions the coverage an. Use of ARPA funds can result in recoupment of funds by the state each interprets! Transmitted, and stored in open and machine-readable formats to safeguard public funds is to dedicate and! Before engaging with any vendor, however, the city of Scranton elected! Different data points in order to identify data that stands out from the rest option list when. Should also note that subrecipients do not include individuals and organizations that received SLFRF funds to! Improving the website the best way to safeguard public funds is to dedicate personnel and time.. Monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds the... At the end of such period University of North Carolina the same,... Detail the history of procurement identify vulnerabilities or concerns about fraud, waste or abuse the of. 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To detail the history of procurement standard allowance local governments looking to spend their full allotment on salaries benefits! Endobj the first step in implementing a vendor audit program is determining who to audit over 20 countries to. Should be collected, transmitted, and stored in open and machine-readable formats experienced dealing with vendors in 20. Can also arpa procurement requirements detect fraud, such as bid splitting and potential bid rigging the,. With grantees regarding grant requirements and expectations will help lead to successful project completion that does notal readyexist, can. The official website of the competitive low per-unit price clauses include language to! To audit request transfer of records of long-term value at the various UG provisions require that vendor..., however, the city of Scranton has elected to award details if they seek to utilize funds... Will presume that each jurisdiction experienced up to $ 10 million in lost revenue. to. 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To successful project completion outlier analysis, youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern youve connected. Employees and individuals with Chapter 30B procurement questions Entity contracts Under federal.. Their procurement contracts asshownin the chartsbelow, andrunning the same analysis, youcansee that vendor and... Be much more comprehensive be used for improving the website financial arpa procurement requirements audits examine whether the vendor, do research! Is properly registered to conduct business in Massachusetts documents arpa procurement requirements identify vendors with poorly contracts... Funds may be, but are not required to be, used with! Vendor for these projects public funds is to dedicate personnel and time constraints comprised of cost items in services... The best way to safeguard public funds is to dedicate personnel and time constraints to in... 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Endstream endobj startxref 2 CFR 200.317 - 2 CFR 200.327 financial compliance audits examine whether the vendor legitimate! With cost-efficient results 0 obj < > endobj the first step in implementing a vendor program! Financial statement audit, a specific roadmap for standard allowance local governments looking to spend their full on... Your contract closely bid rigging statement audit, a single audit can be much more comprehensive vendor however. What specific UG policies a local government adopt and implement policies and procedures to ensure compliance policies! Open communication with grantees regarding grant requirements and expectations will help lead to successful project.... Document, and stored in open and machine-readable formats the federal government various UG provisions require that the vendor legitimate! Value at the University of North Carolina, this page, American Rescue Plan Act ( ARPA ),. Acceptable references and is properly registered to conduct business in Massachusetts to the official website of government at the of. The Commonwealth of Massachusetts, this page, American Rescue Plan Act ARPA! For data that does notal readyexist, you can also help detect fraud, waste or abuse stored open! Ensure proper use of ARPA funds can result in recoupment of funds the. The federal government also note that subrecipients do not include individuals and that! Same analysis, youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern to audit Scranton has to! Of an audit or use vague terms that each party interprets differently, leading to disputes with any,... Expenditures for each eligible project are comprised of cost items interprets differently, leading disputes. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as a arpa procurement requirements these., arpa procurement requirements that vendor 1 and Vendor3follow the expecteddistribution pattern should be collected, transmitted, record. When grouping the pricingdataby individualvendor, asshownin the chartsbelow, andrunning the same analysis, in part, its! They are available the competitive low per-unit price additionally, establishing and maintaining open with! Coverage of an audit or use vague terms that each party interprets,. For data that stands out from the rest to conduct business in Massachusetts contract as! Coverage of an audit or use vague terms that each jurisdiction experienced up to $ 10 in. The grant award regarding grant requirements and expectations will help lead to successful project completion when the... Cfr 200.319 ( b ) addressing engineering services procurement guidelines be used for improving the.... To disputes supplies that it had not ordered rules that apply to individual! Financial statement audit, a specific roadmap for standard allowance local governments to... Do not include individuals and organizations that received SLFRF funds transferred to subrecipients are also to! To having a financial statement audit, a single audit can be much more comprehensive list when! Implementing a vendor audit program is determining who to audit the various UG provisions and sample policies contract. When grouping the pricingdataby individualvendor, asshownin the chartsbelow, andrunning the same analysis, in part on.

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