As required under 2 CFR 200, a local governments procurement program must address the following: Full and Open If you are used to having a financial statement audit, a single audit can be much more comprehensive. The following is a sample policy: Recordkeeping Requirements. The following is the schedule for the next several weeks. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. The OIG is developing classes to introduce local officials to specific data analysis techniques. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U 601 0 obj <>stream If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. Some page levels are currently hidden. Remember to consider whether your data gives you enough information to help you make decisions. Local governments should review the requirements, compare them to their current policies and procedures, and consult with legal counsel to evaluate. In addition, we recommend that all ARPA awardees review 2 CFR Part 200 Subpart D, as this section describes the requirements most applicable to local governments. The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. [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. 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. Track and maintain records of all grant-related documents, including communications, receipts and invoices. Some of the data within your organization may already be in an analyzable format. The jurisdiction did not have any policies related to procuring services exempt from Chapter 30B and the jurisdiction did not procure automobile towing and storage services with a competitive process. Mayor Smiley wants to hear from you! 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 Use this button to show and access all levels. 2 CFR 200.317 - 2 CFR 200.327. Thank you for your website feedback! If your contract does not permit the vendor to charge a specific fee, then your jurisdiction has a basis for contesting the application of any additional fee. WebSourcing & Procurement. If a vendor is not registered beware. 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). 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. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. 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. To utilize a pre-existing contract, municipalities can consider the following requirements to assess whether the contract meets federal procurement requirements: In some cases, existing relationships established through a Memorandum of Understanding (MOU) or a Memorandum of Agreement (MOA) can be expanded for the provision of services that may fall under the intended use of ARP funding, such as non-profits or public entities like local public school districts or institutions of higher education, which provide public services such as housing support, healthcare, food distribution, or job training programs. Maintaining records sufficient to detail the history of procurement. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? Please limit your input to 500 characters. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. 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 Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Exceptions to requirements for small purchase or formal method competitive rules. Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. 200.317-318. infrastructure, potential enhancements of state funding resources, Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. We welcome non-English speakers to contact us. Share sensitive information only on official, secure websites. Knapp-Sanders Building When was the last time your client revised their procurement contracts? Publishing and documenting clear standards in procurement solicitations and evaluation criteria on how a municipality will determine a responsive and responsible. Municipalities should ensure that factors that may be overly restrictive to free and open competition are not included, such as placing unreasonable requirements on vendors to qualify or establishing any steps in the procurement process that are arbitrary or irrelevant to the award of contracts necessary and reasonable for the implementation of the use of funds under this award. Auditors should also be on alert for process owners who explain steps as they should be, or who respond using words such as usually, most of the time, supposed to or we try to. Commonwealth auditors should be cautious of auditees who are overly inquisitive and interested in what the audit team is looking for or why the vendor was selected for the audit. 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. We use small samples of data, as well as big data, to help with everything from researching whistleblower claims to investigating individual cases of potential fraud to analyzing statewide systemic issues. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. 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). [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. This includes setting specific requirements and expectations, providing an audit timeline, including when and where you will visit, who you will interview, and which documents you will need. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Some page levels are currently hidden. 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 Treasury may request transfer of records of long-term value at the end of such period. 11246. 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. c. 30B, or statewide contracts administered by the Operational Services Division. Or maybe you used a more sophisticated tool to make that decision for example, the weather app on your phone but in both cases you used data to decide to wear a raincoat. When procuring goods or services, the state agency or municipal department typically executes a contract with the vendor to outline the scope of the parties agreement. 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. Share sensitive information only on official, secure websites. 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. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. 6101 et seq., and the Department implementing regulations at 31 CFR part 23. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. See, e.g., 2 C.F.R. [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. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. The first step in implementing a vendor audit program is determining who to audit. This outlier may warrant further investigation. You may access the slides from that session here within the next few days. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. 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). Program Income. Implement internal controls to prevent fraud, waste and abuse. Government entities that have received ARPA funding may be able to award grants to third parties. To start, here is a summary list of UG policies and their triggers. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? Each recipient should review program requirements, including Treasurys final rule and the recipients Award Terms and Conditions, to determine and record eligible uses of SLFRF funds. Blackboardor other virtual platform login details will be emailed to registrants. 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). Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. See M.G.L. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. 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. 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. WebThe State will comply with 200.321, 200.322, and 200.323 and ensure that every purchase order or other contract includes any clauses required by 200.327. Ensuring that the contract structure is appropriate for the goods and/or services rendered, that prices are fair based on an independent cost or price analysis, and that a cost-plus-percentage-of-cost method is not used for federally-funded contracts. For instance, data analysis can reveal patterns in payroll expenditures or purchasing, track whether employees are following policies and procedures, or measure staff or vendor performance. 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. Look for those in the coming weeks. If you need assistance, please contact the Office of the Inspector General. Please limit your input to 500 characters. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. 5. 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. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. These risk assessments may include factors such as prior experience in managing Federal funds, previous audits, personnel, and policies or procedures for award execution and oversight. 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. Conducting a survey can be as simple as sending out an email or using a free online survey tool. Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. A few requirements drawn from the Uniform Guidance include the following: Municipalities may have existing contracts or working relationships with vendors for similar services that they may wish to use for ARP-funded work. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate However, the audit team should be careful not to become too friendly with their auditees. We use data every day without realizing it. 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. Come with your questions and share your experiences and insights with colleagues across the State. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. Maintaining clear policies governing conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or monitoring vendors. There are several techniques you could use to identify vendors 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. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? procurement policies pursuant to 2 CFR 200.317 as well as comply with the procurement standards set forth at 2 CFR 200.321 through 2 CFR 200.323, and 2 CFR 200.327. 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. 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. Are there special requirements for capital Therefore, when your jurisdiction uses federal funds to pay for supplies or services, you need to check your federal funding documents and any other federal guidance applicable to the type of funding you received to determine which procurement laws to follow. The record retention requirements for ARP/CSLFRF-related records are more stringent than those imposed under State law. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. If you identify a fee or charge that is not accounted for in a contract between your jurisdiction and a vendor, contact the vendor for an explanation; or request a corrected invoice and a return of any improperly paid fees. All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. If a local government received less than $10 million in CSLFRF funds, it may take the Each of the considerations above, as well as operation and maintenance The funds can be used to purchase equipment that improves or enhances the delivery of daily Jurisdictions therefore must dedicate staff to evaluate documents and completed work reports from contractors to make sure that they have followed the contract before issuing payment. You must ensure that the vendors you are doing business with are legitimate and responsible. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. Allowable Activities. Consider whether prevailing wage rates apply. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. The Assistance Listing is available on SAM.gov. 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. Further, a prequalification or screening process for vendors interested in providing certain services, such as towing and storage, helps ensure that the public is receiving services from a qualified vendor at a reasonable price. The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. [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]. 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. Some online survey tools even analyze data for you. Federal procurement laws and regulations typically require that you use a fair, open and competitive process, even though price thresholds, advertising requirements and contract award language may differ from the requirements of Chapter 30B. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. The following are tools to implement this requirement: Allowable Costs/Cost Principles. WebGeneral Requirements for Procurement Programs . The Office of Management and Budget recently published guidance on how auditors should conduct Single Audits for ARPA Recovery Fund investments and the Emergency Rental Assistance Program County auditors should consult OMBs Compliance Supplement when constructing Single Audits for county investments of federal funds. 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. 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. 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 Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. Remember to check debarment lists, as well as the Secretary of the Commonwealths business registration database or a local municipal clerks office to determine if a business is properly registered to conduct business within Massachusetts. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. 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. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. 4. The funds can be used to purchase equipment that improves or enhances the delivery of daily Confirm that the vendor billed at the rates stated in the contract or purchase order. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. Data is everywhere, and every function a government performs can generate valuable data. What is the difference between Suspension and Debarment? WebARPA established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), which is a a program that provides funding over a two-year period to all states, counties, and In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. American Rescue Plan Act of 2021: Sample Uniform Guidance Policies and Implementation Tools, -Boards of Mental Health, Developmental Disabilities, & Substance Abuse, -Affordable Housing & Minimum Housing Codes, -Professional Responsibility for Government Attorneys, Purchasing, Construction, Property Transactions, -Purchasing / Purchase Contracts / Purchase Orders, Assistance Listing: Coronavirus State and Local Fiscal Recovery Funds, US Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, Subpart C, Pre-Federal Award Requirements and Contents of Federal Awards, Subpart D, Post Federal; Award Requirements, Project and Expenditure Report Tracking Template, Blog post explaining allowable cost and cost principles, Sample Allowable Cost and Cost Principles Policy, Sample Employee Effort Certification Form for 100% Covered Employees, Sample Employee Effort Certification Form for Less Than 100% Covered Employees, as outlined in paragraph 4.c. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. Fraud, waste and abuse can occur even when comprehensive contracts are in place. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22, ARPA Subgrantee Agreement Template Reimbursement Based rev11.3.22, ARPA Subgrantee Agreement Template 100% Advance Payment (Very Rare-Special Circumstances) rev11.3.22, ARPA Subgrantee Agreement Template 25% Advance Payment rev11.3.22, ARPA Beneficiary Agreement Template rev11.3.22, SLFRF_Subgrantee_Budget_Exhibit 3_ 11.3.2022, SLFRF_Subgrantee_Invoice_Exhibit 4_11.3.2022. While a right-to-audit clause gives the team the contractual authority to conduct the audit, getting buy-in from management will help make the audit more efficient and effective. Without thinking much about it, you gathered data and made a decision based on that data. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). Also on this page are the dates and times of future Office Hours events, along with the Zoom link. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. The audit scope and appropriate approach depend on the type of audit performed. Then make sure that you have access to that data. Becoming overly friendly threatens the auditors independence in performing their review. Webprocurement can be used. To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an Allowable Costs and Cost Principles Policy. 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. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. The smallest incongruity could lead to the discovery of a large fraud. 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