We welcome non-English speakers to contact us. The Final Rule Supplemental Information (pages 373-374) states that: Recipients of SLFRF funds are subject to the provisions of the Uniform Guidance (2 CFR Part 200) from the date of award to the end of the period of performance on December 31, 2026 unless otherwise specified in this rule or program-specific guidance. After the official bid opening requiring a review of the bid submittals and verification of the bid results by a party not involved in the bid process. Program Income. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. Mayor Smiley wants to hear from you! 9-10). It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. Maintaining records sufficient to detail the history of procurement. 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. 559 0 obj
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When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. Consistently applied. 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. Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. WebARPA Policy and Procedures Manual. October 2015 Procurement Bulletin Article. It will be equally problematic from a compliance standpoint to have a policy your unit cannot or does not follow than to not have one at all. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. The first step in implementing a vendor audit program is determining who to audit. Capital Funds Project website. Some page levels are currently hidden. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. 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.) This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. Each category of cost should be treated consistently in like circumstances as direct or indirect, and recipients may not charge the same administrative costs to both direct and indirect cost categories, or to other programs. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. Use this button to show and access all levels. Are you missing any data that would help you monitor utilization? The Assistance Listing is available on SAM.gov. 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. 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. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. Confirm that the vendor billed at the rates stated in the contract or purchase order. Fraud, waste and abuse can occur even when comprehensive contracts are in place. UNC Chapel Hill
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. If you need assistance, please contact the Office of the Inspector General. 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. 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). 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. Civil Rights Compliance. Further, the individuals who review and approve invoices must know the contract terms, conditions and specifications. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. 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. Ensure the agency received all of the purchased goods and services. If you are still unclear about the requirements for your particular source of funding, we recommend that you contact the grantor or federal funding entity for clarification. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. 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] This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. Some page levels are currently hidden. The vendor claimed that the lower per-unit price was only for bulk purchases. Additional controls that your organization should implement include written policies that explicitly identify appropriate allocation methods, accounting standards and principles, compliance monitoring checks for program income calculations, and records. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. c. 30B, (1)(b)(9). For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. In order to maintain the vendors trust and cooperation, the team should only ask for information necessary to achieve the goal of the audit and documents that have a true business justification. This blog post is published and posted online by the School of Government to address issues of interest to government officials. Proposals must be solicited from an adequate number of qualified offerors. Noncompetitive procurement is only allowed if certain criteria are met.
We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). Is it something you can collect in the future? S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$AqYoX%F"YC
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&)1dwO1(SEQqm2(Rh !3I`eUb&. 5. Written procedures that do not meet UG standards must be revised to include these ) or https:// means youve safely connected to the official website. Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. 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. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. Once the data has been transformed into auser-friendlyformat, it can be used in a variety of ways to assist with future procurements and other business decisions. 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. 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). 2 CFR 200.317 - 2 CFR 200.327. Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. 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. Blackboardor other virtual platform login details will be emailed to registrants. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). Maintaining clear policies governing conflicts of interest for Direct questions related to design and construction procurement to the Attorney Generals Office. 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. [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. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Once you have access, you can use the data to inform your decisions and manage risks. To start, here is a summary list of UG policies and their triggers. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. Top-requested sites to log in to services provided by the state. When was the last time your client revised their procurement contracts? 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 For this program, the city of Scranton has elected to award . The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of two (2) subrecipients to carry these programs. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. Generally, your organization must maintain records and financial documents for five years after all funds have been expended or returned to Treasury, as outlined in paragraph 4.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. 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. Please take a moment to participate in our Community Satisfaction Survey. 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. If you determine a need for data that does notal readyexist, you can also create data. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. For example, in the scatter plot below, each of the points represents one contract. This course is targeted to finance and management staff of smaller and mid-sized units that will be taking the standard allowance and spending most, if not all, of their ARP/CSLFRF as revenue replacement. While data includes these things, data also includes things such as time sheets, bank statements, survey responses and water meter readings. Please include this language separately in the bid solicitation. 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. Web( a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. 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. To avoid such pitfalls, your jurisdiction should approve and implement a policy outlining how to procure towing and storage services, even though it is exempt from Chapter 30B. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? 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. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. Restricting access to the submitted bids. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. 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). Subrecipients are subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements, whereas contractors are not subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements. This collection does not apply to Tribal governments. 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. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. 2. hWoHWcORPKt.u8 -fA zA^%hq0)`Q9^2
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