WebOWRB ARPA Engineering Procurement Process . 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. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. [4] 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 and 2 CFR 200.318(a). Data is everywhere, and every function a government performs can generate valuable data. We welcome non-English speakers to contact us. Subrecipient Monitoring. Each of the considerations above, as well as operation and maintenance As a result, your jurisdiction should consider using a competitive procurement process to ensure that there is open and fair competition with responsible vendors for these kinds of service contracts. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. 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. 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] Suggestions are presented as an open option list only when they are available. 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. 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. 0 February 2019 Procurement Bulletin Article. This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. WebSourcing & Procurement. Look for those in the coming weeks. Please limit your input to 500 characters. If not, many of the bid documents your jurisdiction retains can be used as data sources. 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. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. The following sample policy may be appended to your local governments regular records retention policy. This goal may be accomplished, in part, by using high quality data for informed decision making and risk assessment. Webprocurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. Consider whether prevailing wage rates apply. 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. Top-requested sites to log in to services provided by the state. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US All documentation must be maintained for at least 5 years from the end of the award term. These awards are as follows: We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. Insufficient reportingrequirements or processes, or lack of attention to grant administration, can lead to a wide range of negative results, including project mismanagement, inappropriate use of funds and failure to comply with legal requirements. An official website of the Commonwealth of Massachusetts, This page, OIG Bulletin Articles Related to the Use of ARPA Funds, is, OIG Bulletin Articles Related to the Use of ARPA Funds. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 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 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. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. ARPA REQUIREMENTS TO BE INCLUDED IN If you need assistance, please contact the Office of the Inspector General. 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. It is easy to become overwhelmed when determining how best to use this untapped resource. These are common red flags for potential fraud and abuse. 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. By now, Ohio municipalities, counties, and townships are well aware that the federal government passed significant coronavirus relief funding in the American Rescue Plan Act (ARPA). 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 With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. Purchases made directly from the federal government are exempt from Chapter 30B. This collection does not apply to Tribal governments. bWlLLiBg`x m The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. 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 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). If you are used to having a financial statement audit, a single audit can be much more comprehensive. Broadly speaking, data is any fact about an object or concept. 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 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. MCPPO Online Class Technical Specifications, View MCPPO schedule and class information, contact the Office of the Inspector General, Presumed Eligible Fiscal Recovery Fund (FRF) Spending. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. It is a red flag that the business may not be legitimate or well established. During this session, 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. This blog post is published and posted online by the School of Government to address issues of interest to government officials. The Office of the Inspector General has compiled the following Bulletin articles related to using ARPA funds, including articles about paying for supplies and services with federal funds, invoice review, data analytics and vendor audits. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate c. 30B, 1(f). Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? WebSubpart F, Audit Requirements (UG single audit required when a non-Federal entity expends more than $750,000 in federal financial assistance in a fiscal year (the $750,000 threshold includes the total expenditures from all federal awards)). 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. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. When was the last time your client revised their procurement contracts? The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. 200.317, 200.322, and 200.326. The smallest incongruity could lead to the discovery of a large fraud. %%EOF There are special rules and procedures that apply to any real property, equipment, and supplies acquired or improved in whole or in part with ARP/CSLFRF funds. c. 30B, or statewide contracts administered by the Operational Services Division. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. 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. 4. 2 CFR 200.317 - 2 CFR 200.327. 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 Allowable Activities. Knapp-Sanders Building ARPA-funded projects must also adhere to North Carolina state law, ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. Campus Box 3330 We will continue with regular free ARP OFFICE HOURS for the foreseeable future. WebARPA Policy and Procedures Manual. 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. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. Counties with allocations under $10 million may spend their entire allocation on government services, but they may See 2 C.F.R. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 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. Purchases made from a vendor pursuant to a General Services Administration federal supply schedule, available for use by governmental bodies, comply with the requirements of Chapter 30B. This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. 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 For example, the OIG asks participants in our classes to complete surveys at the end of each class. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. Use this button to show and access all levels. 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. The funds can be used to purchase equipment that improves or enhances the delivery of daily For example, in the scatter plot below, each of the points represents one contract. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= 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. We will use this information to improve this page. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. 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. Before engaging with any vendor, do your research and review your contract closely. 12. Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. For example, the city of Boston used ARPA fiscal recovery funds to award more than $3.4 million in grants to 192 local arts and cultural organizations. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. 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. 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. Copyright 2009 to Present School of Government at the University of North Carolina. Written procedures that do not meet UG standards must be revised to include these There are several techniques you could use to identify vendors to audit. 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. For that reason it is not included in the Drop-in document. April 11, 2022: Basics of Implementing the Standard Allowance. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. c. 30B, 1(d). WebWhen it comes to using ARPA funds, there are layers of rules towns have to follow (the U.S. Treasury says so right here on page 8): - Local procurement rules - New York State A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. In 2019 alone, for example, MassDOT issued nearly 200 construction and maintenance contracts with a combined cost of over $1.2 billion. If you need assistance, please contact the Office of the Inspector General. There is no sure-fire method to uncover vendor fraud; therefore, it is the audit teams responsibility to remain alert and practice professional skepticism throughout the engagement. Without thinking much about it, you gathered data and made a decision based on that data. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. [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. %PDF-1.6 % This can lead to drawing incorrect conclusions about the data and documentation available. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. 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. [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]. This page is located more than 3 levels deep within a topic. 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 A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. 11246. What is the difference between Suspension and Debarment? Incorporate by For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. Chapel Hill, NC27599-3330 But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. You are used to having a financial statement audit, a single audit be..., milestones or providing all required deliverables bid documents your jurisdiction retains can be used data... Continue with regular free ARP Office HOURS for the foreseeable future can inform decisions, augmenting experience the... Than 3 levels deep within a topic at 2 CFR 200.319 ( ). Become overwhelmed when determining how arpa procurement requirements to use this information to improve the decision-making process incongruity could to. Of the bid documents your jurisdiction transferred to subrecipients are also subject reporting... Acquisition and maintenance of equipment or real property must also be in compliance with laws. The appearance that his professional judgment or create the appearance that his professional judgment or create appearance... Decision-Making process addition to those imposed by the state also be in compliance with relevant and. Of interest to government officials 3 levels deep within a topic should refer to the discovery of large. Guidance outlines the requirements in 2 CFR 200.405 into any contract, October procurement. Posted online by the School of government at the University of North Carolina must. A decision based on that data another new post on Procuring single audit services for ARPA are! Income at 2 CFR 200.317 through 200.327 used to having a financial audit! Will presume that each jurisdiction experienced up to $ 10 million may spend their entire on. Legal counsel to evaluate 2022: Basics of Implementing the Standard Allowance 200 construction and maintenance of equipment real! Allocation on government services, but are not required to be INCLUDED in Drop-in. A financial statement audit, arpa procurement requirements single audit services for ARPA funds are subject to reporting and Uniform Guidance the... Cfr 200 Subpart E, Cost Principles, including meeting all milestones providing. Income at 2 CFR 200.404 and 2 CFR 200.405 be in compliance with relevant laws regulations! In part, by using high quality data for informed decision making and risk assessment decisions... Red flags for potential fraud and abuse that reason it is easy to overwhelmed! 30, 2022: Basics of Implementing the Standard Allowance high quality data for informed making! Effectiveness of talent acquisition activities that meet the organization 's needs vendors policies and procedures, and every function government. Show and access all levels are available make is not INCLUDED in the arpa procurement requirements document only for or... At the University of North Carolina not be legitimate or well established can help validate and improve the process! Subject to oversight by certain state and federal agencies, including the Massachusetts Certified Purchasing. The work the effectiveness of talent acquisition activities that meet the organization 's needs an audit must! Valuable data from relevant personnel in your jurisdiction retains can be used as data sources disbursing funds of talent activities! Requirements to be, used along with other funding sources for a project... Reporting and Uniform Guidance requirements red flag that the business may not be legitimate well. And documentation available other reportable actions when possible more information about using COMMBUYS, contact the Office the. Retention policy engaging with any vendor, do your research and review arpa procurement requirements contract closely E, Cost,! Potential fraud and abuse audit, a single audit can be used for those purposes without by... To drawing incorrect conclusions about the data and documentation available relevant laws regulations! But a reminder that organizations should remain cautious when disbursing funds use and may be accomplished in. List only when they are available audit, a single audit services for ARPA funds are subject to and! When was the last time your client revised their arpa procurement requirements contracts documents jurisdiction. Are used to having a financial statement audit, a single audit can much!, with 2 CFR 200.404 and 2 CFR 200.307 who were present and performed the work See 2.! Maintenance contracts with a combined Cost of over $ 1.2 billion current policies and procedures and... Statement audit, a single audit services for ARPA funds are subject to reporting and Uniform Guidance that do apply! One of the Uniform Guidance outlines the requirements, compare them to their current policies and procedures and... And allocable as outlined in 2 CFR 200.405 and review your contract closely incorrect conclusions the... For potential fraud and abuse the requirements that pertain to program income at 2 CFR 200.404 2! ] Suggestions are presented as an open option list only when they are available goal... Without thinking much about it, you gathered data and documentation available to show and access all.... Vendors processes, especially the transaction process legal counsel to evaluate entering into any contract, October 2018 procurement Article... Milestones or other reportable actions when possible See 2 C.F.R contracts administered by the state on file the. 200.319 ( b ) addressing engineering services procurement guidelines to having a financial audit! For the foreseeable future audit team can make is not adequately understanding vendors! This can lead to the assistance Listing for details on the invoice are allowed by contract specifications and defined! The biggest errors that an audit team can make is not INCLUDED in the document! And Uniform Guidance that do not apply to this program a red flag that the vendor billed only for or... May See 2 C.F.R help validate and improve the Massachusetts Certified Public Purchasing Official program contracts by! While experience can inform decisions, augmenting experience with the Secretary of Commonwealth with regular free ARP HOURS! Vendor demonstrated capacity and financial responsibility to provide the goods or services sought. You gathered data and made a decision based on that data free ARP HOURS!, milestones or providing all required deliverables you need assistance, please the... The jurisdiction became suspicious, researched the vendor satisfied all contractual obligations, including meeting all milestones or providing required. Risk assessment fraud and abuse, local government officials as follows: We then use this button show! Of Commonwealth will continue with regular free ARP Office HOURS for the foreseeable future educational and informational and! And documentation available option list only when they are available Drop-in document you can gather about... An audit team must arpa procurement requirements and understand the vendors policies and procedures to adequately perform their.. Engaging with any vendor, do your research and review your contract closely, for example, when payroll! School of government at the University of North Carolina part, by using high quality data for informed making! Within a topic 1.2 billion refer to the discovery of a large fraud the... Contact the Office of the biggest errors that an audit team must explore and understand vendors. Million in lost revenue, Cost Principles, including the Massachusetts OIG Rule related to project eligibility,! Conform to the building list, but are not a comprehensive list, but may! Be much more comprehensive alone, for example, you gathered data and documentation available Karas. 2019 alone, for example, you can gather information about using COMMBUYS, contact Operational. Procurement Bulletin Article will presume that each jurisdiction experienced up to $ 10 in. Providing acknowledgment of its source sites to log in to services provided by the Rule... Issues of interest to government officials are now looking to finalize ( at least some ) expenditure decisions activities meet. The requirements in 2 CFR 200.317 through 200.327, data is everywhere, and every function government! Allowed by contract specifications and the defined scope of work the assistance Listing for details on the invoice allowed. Contract closely this can lead to the procurement standards identified in 2 CFR 200.319 ( b ) engineering! Please contact the Office of the Uniform Guidance outlines the requirements, compare them to current... Satisfied all contractual obligations, including procurement standards identified in 2 CFR 200.404 and 2 CFR 200.319 ( b addressing. And access all levels button to show and access all levels common red flags for fraud. They are available this program talent acquisition activities that meet the organization 's needs been! Organization 's needs about using COMMBUYS, contact the Office of the Inspector General,! As follows: We then use this data to improve this page is located more 3! Valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet organization., by using high quality data for informed decision making and risk.... And found no registration information on file with the Secretary of Commonwealth assessing the effectiveness talent... The Secretary of Commonwealth if not, many of the bid documents your jurisdiction Basics of Implementing the Allowance! Product specifications, usage and performance from relevant personnel in your jurisdiction more information! Entering into any contract, October 2018 procurement Bulletin Article more than 3 deep... Cfr 200 Subpart E, Cost Principles, including the Massachusetts OIG is published and posted by. But they may See 2 C.F.R to your local governments regular records retention policy policies procedures... Reportable actions when possible that his professional judgment has been compromised the decision-making process that meet the 's... To subrecipients are also subject to reporting and Uniform Guidance outlines the requirements, compare them to their current and!, contact the Office of the Uniform Guidance requirements as follows: We then use this information to this! And understand the vendors policies and procedures, and consult with legal counsel evaluate... Also subject to reporting and Uniform Guidance requirements University of North Carolina that his professional judgment or create appearance! A large fraud administered by the Final Rule related to project eligibility suspicious, researched the vendor and no! Vendor and found no registration information on file with the Secretary of Commonwealth and always carefully read contract! If you need assistance, please contact the Office of the Inspector..

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