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. This collection does not apply to Tribal governments. It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. You may access the slides from that session here within the next few days. In this article, we delve into two specific techniques for creating and using data visualizations, which can further aid a jurisdiction in detecting waste or fraud. 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). 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. Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. Review the contract and be familiar with its terms. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? 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. %%EOF For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. 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 Incorporate by reference any federal rules that apply to the grant award. Accordingly, your organization should develop written policies and procedures for subrecipient monitoring and risk assessment and maintain records of all award agreements identifying or otherwise documenting subrecipients compliance obligations. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. 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. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. A helpful starting point is to pull data from current and historical sources and compile it into a more data-friendly format, such as an Excel spreadsheet file. In the meantime, please feel free to contact us if you have any questions or ideas about data. There are many reasons to audit contracts with vendors and suppliers. 2. 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. 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. The Assistance Listing is available on SAM.gov. 2 CFR 200.320(c). If a local government received less than $10 million in CSLFRF funds, it may take the 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. Use of this blog post for commercial purposes is prohibited. The team should consider gaining direct access to the vendors systems to facilitate its review. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. October 2015 Procurement Bulletin Article. The following are a sample subaward policy, risk assessment, subaward agreement template, and subrecipient monitoring tool (they are all in a single Word file): Although there is a lot of federal red tape to navigate regardless of how a local government expends its ARP/CSLFRF funds, there are some opportunities to reduce a local units compliance burden. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. 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)? The following is the schedule for the next several weeks. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. The following sample policy may be appended to your local governments regular records retention policy. of the Award Terms and Conditions, Accessibility: Report a Digital Access Issue, Allowable Costs and Cost Principles Policy, Financial Management and Internal Controls, Program Income Policy (if local government uses ARP/CSLFRF funds to establish a loan program or otherwise earns income related to an ARP/CSLFRF expenditure), Procurement Policy (if a local government contracts for goods or services paid for with ARP/CSLFRF funds, or must engage in a Single Audit (even if the audit is paid for with other funds)), Property Management Policy (if a local government uses ARP/CLSFRF to acquire or improve any real property, equipment, or supplies), Subaward Policy (if a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF-eligible project), Thursday, March 24, at 8:30am (focus on affordable housing). As part of this information-gathering process, team members should strive to interview as many vendor employees as possible to corroborate their evidence and ensure the team has a complete understanding of the vendors current state. Ensure the agency received all of the purchased goods and services. hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. 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. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. c. 30B, 1(d). contact the Office of the Inspector General. Require regular and thorough reporting from grantees relating to expenditures. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. All rights reserved. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. Direct questions related to design and construction procurement to the Attorney Generals Office. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. 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. A level and competitive playing field should exist for all service contracts, especially when a local jurisdiction creates a market for private vendors by prompting a demand. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. https://canons.sog.unc.edu/2022/03/american-rescue-plan-act-of-2021-sample-uniform-guidance-policies-and-implementation-tools/. 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 Incorporate by Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. The funds can be used to purchase equipment that improves or enhances the delivery of daily Assigning multiple witnesses to attend and attest to the proper bid opening. 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. Then you can compile this information into a data-friendly format, like a spreadsheet. All other recipients must follow 2 CFR 200.318, General procurement standards, through 200.327, Contract provisions. February 2019 Procurement Bulletin Article. Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. Therefore, support from potential stakeholders senior management, the Board of Directors, department decision-makers is important for a successful audit engagement. 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. endstream endobj 560 0 obj <. 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. The feedback will only be used for improving the website. Equipment and Real Property Management. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, Implement internal controls to prevent fraud, waste and abuse. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. Taking incremental steps and continually finding areas for improvement will create a robust data program and help you make informed, data-driven decisions. 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. Is it something you can collect in the future? [1] These requirements outline the general standards and regulations for the procurement of goods and services for recipients and subrecipients of federally awarded funds. A local government should craft its policies and procedures so that they can be reasonably implemented by its staff. 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). 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 ARPA-funded projects must also adhere to North Carolina state law, Massachusetts Executive Order 195 outlines audit and oversight requirements related to vendor contracts. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. ) or https:// means youve safely connected to the official website. Purchases made directly from the federal government are exempt from Chapter 30B. 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. Conducting a survey can be as simple as sending out an email or using a free online survey tool. 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. Surveys are a helpful way to do this. Federal regulations require a local jurisdiction to apply state and local procurement laws for federally funded procurements, provided that the procurements also conform to federal law and regulations. 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. ARPA REQUIREMENTS TO BE INCLUDED IN endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. 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. %%EOF This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. 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. 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. Thank you for your website feedback! For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. Of any amount ordinary and necessary for the next several weeks, and other similar arrangements. The Massachusetts Certified Public Purchasing Official Program COMMBUYS, contact the Operational Division... Exempt from Chapter 30B because of federal requirements, make sure you document this in writing in procurement... 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