arpa procurement requirements

The vendor provided supporting documentation for the items or services on the invoice. 2 CFR 200.317 - 2 CFR 200.327. Maintaining records sufficient to detail the history of procurement. 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 Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. endstream endobj startxref The following is a sample policy to address any program income: Note that there are some grey areas related to how to identify program income, particularly fees for services assessed for water, sewer, or broadband assets constructed or improved with ARP/CSLFRF monies. 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. The feedback will only be used for improving the website. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Therefore, support from potential stakeholders senior management, the Board of Directors, department decision-makers is important for a successful audit engagement. Government entities that have received ARPA funding may be able to award grants to third parties. Maintaining clear policies governing conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or monitoring vendors. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. Once the audit team selects the type of audit to perform, the team must clearly prepare an audit plan and outline the expected audit procedures. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. 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. 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. 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 executive order requires that every goods or services contract or agreement must incorporate an auditing provision permitting the government to audit the vendors books, records and other compilations of data relative to the performance of any provision or requirement of the contract or agreement. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Is the contract active and does it include the goods or services being sought? This scope is different than what is included in the current contract and may be considered noncompetitive. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. We welcome non-English speakers to contact us. 11246. For example, someone from the public works department who supervises roadway paving should know whether the contractor completed the work and used the correct materials. Treasurys implementing regulations, 31 CFR part 22, and the Department of Justice (DOJ) regulations, Coordination of Non-discrimination in Federally Assisted Programs, 28 CFR part 42, provide for the collection of data and information from recipients (see 28 CFR 42.406). MOUs and MOAs should still include the required contract provisions,[24] monitoring and oversight requirements,[25] and cost principles[26] as identified by federal or local requirements, though they likely will not follow the same procurement process. Remember that data is a broad concept, and that analyzing the many different kinds of data your jurisdiction collects every day can enhance your decision-making processes. 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). During this session, 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. And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. 12. Use of this blog post for commercial purposes is prohibited. During this session, T:919.600.7874. 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. Before engaging with any vendor, do your research and review your contract closely. If the data is not in one of these formats, do not despair! If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. There are several techniques you could use to identify vendors to audit. WebThe City of Detroit Office of Contracting and Procurement (OCP) requests proposals from qualified Respondents to provide procurement supportive services including reviewing &creating scopes of work, creating bid solicitations, contract development, contract negotiations and preparation of critical See more Buyers Requirements 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 The following is the schedule for the next several weeks. 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. 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. endstream endobj 560 0 obj <. clarified that funds made available under the American Rescue Plan Act (ARP) Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) are subject to federal procurement requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), found at Title 2 of the Code of Federal Regulations, Part 200 (2 CFR 200). See M.G.L. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E regarding Cost Principles, allowable costs are based on the premise that a recipient is responsible for the effective administration of Federal awards, application of sound management practices, and administration of Federal funds in a manner consistent with the program objectives and terms and conditions of the award. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. This training discusses the differences between subrecipients and contractors under the federal rules, fiscal recovery fund spending that is presumed eligible due to the nature of the beneficiaries or the type of project, and rules relating to using fiscal recovery funds on capital expenditures. Finally, in addition to my colleagues Rebecca Badgett, who drafted some of the above UG policies, and Connor Crews, who is working on procurement and conflict of interest policies, we want to thank our two amazing research assistants, Tiffany Oliva and Abby Gostling, who drafted several of our templates and other tools. We also are grateful for a group of dedicated county attorneys, including Bob Shaver, Glynn Rollins, Anne Marie Tosco, Aimee Scotton, and Russ Burrell, who provided helpful feedback on the draft policies. x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a You can access that post here. 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. Under the American Rescue Plan Act (ARPA), passed by the federal government in March 2021, Massachusetts state, county, tribal and local entities are receiving federal aid to respond to the public health and economic impacts of the public health emergency created by the COVID-19 pandemic. 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)? 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. infrastructure, potential enhancements of state funding resources, (A) statutory restrictions under the ARPA, which include: offsetting a reduction in net tax revenue, and deposits into pension funds, and (B) other restrictions on use, which include: debt service and replenishing reserves, settlements and judgments, and general restrictions. (See Final Rule pp. Identify and understand the intended uses of the funds in the grant award agreement. Government entities should only pay invoices after confirming that the vendor has satisfactorily delivered all goods, has performed all required services according to the contract and has submitted an accurate invoice. Each of the considerations above, as well as operation and maintenance Please do not include personal or contact information. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. Taking incremental steps and continually finding areas for improvement will create a robust data program and help you make informed, data-driven decisions. 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. To learn more, view our full privacy policy. The particular industry, the types of goods or services involved, the size and complexity of the contract, and the applicable regulatory requirements are just a few factors that can increase an organizations risk of fraud, waste and abuse. Use this button to show and access all levels. To promote accountability, ARPA includes requirements for the administration, monitoring and reporting of funds. The words data and data-driven decision-making sound daunting; however, neither is something new. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. Broadly speaking, data is any fact about an object or concept. ) or https:// means youve safely connected to the official website. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. Webprocurement can be used. c. 30B, (1)(b)(9). The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. 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 SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream Financial compliance audits examine whether the vendor is billing appropriately. 6. October 2017 Procurement Bulletin Article, Recently, our Office learned that a vendor included administrative fees in invoices issued to a housing authority under a revenue-generating contract. two (2) subrecipients to carry these programs. The OIG is developing classes to introduce local officials to specific data analysis techniques. 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. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. 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. Please remove any contact information or personal data from your feedback. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, There are many reasons to audit contracts with vendors and suppliers. To help prioritize which vendors to audit, consider the factors below. Historical and external data sources might not provide the complete picture for your analysis. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. 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