Mayor Smiley wants to hear from you! ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. 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. ARPA REQUIREMENTS TO BE INCLUDED IN endstream endobj startxref State Government websites value user privacy. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. 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)). We will update the policy if/when we receive more guidance from US Treasury. Identifying the key vendor personnel is also an important part of the audit. %%EOF Historical data regarding the use of a supply or service can help procurement teams project future procurement needs and build a more effective and accurate budget. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. BenfordsLaw should not be applied to data sets that have stated minimum and maximum values or are assigned numbers, such as interest rates, telephone numbers or social security numbers. You can transform information from historical and external sources into usable data, and you can create new data. 179 0 obj <>/Filter/FlateDecode/ID[<598620AB2247954EBE922AD03988F6D9>]/Index[165 31]/Info 164 0 R/Length 86/Prev 341858/Root 166 0 R/Size 196/Type/XRef/W[1 3 1]>>stream Chapel Hill, NC27599-3330 For example, a municipality may have an existing contract for providing workforce development services that they wish to use starting July 1, 2021, but the contract expired in March 2021. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. [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. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. Include a right-to-audit clause in grant agreements. Noncompetitive procurement is only allowed if certain criteria are met. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. Properly documented. If a vendor is not registered beware. A lock icon or https:// means youve safely connected to the official website. The following is a sample policy: Recordkeeping Requirements. During this session, Secure websites use HTTPS certificates. Please include this language separately in the bid solicitation. Determine whether the contract allows the vendor to bill for the items listed on the invoice. 11 Uniform The record retention requirements for ARP/CSLFRF-related records are more stringent than those imposed under State law. 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 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. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. 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. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US 165 0 obj <> endobj 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. This makes bid manipulation more difficult. Use of this blog post for commercial purposes is prohibited. To use data in decision making, the data must exist in a format that can be analyzed. 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. Financial compliance audits examine whether the vendor is billing appropriately. These are common red flags for potential fraud and abuse. Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. WebDepending on the site host organizations procurement requirements, a formal solicitation process may be needed to purchase and install charging infrastructure. As part of those procedures, a local government should identify the core team who will perform the review processes and implement necessary controls. 2 CFR 200.317 - 2 CFR 200.327. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. 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). 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. (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. If you need assistance, please contact the Office of the Inspector General. Maintaining clear policies governing conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or monitoring vendors. 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. 2023 School of Government at the University of North Carolina. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. 11246. There are several techniques you could use to identify vendors to audit. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. This blog post is published and posted online by the School of Government to address issues of interest to government officials. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Two significant areas that did not change are the applicability of Uniform Grant Guidance to ARPA funds and the federal audit requirements over these funds. 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. 11246. 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. 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] L. No. This page is located more than 3 levels deep within a topic. 200.317, 200.322, and 200.326. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. 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. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). To browse a complete catalog of School of Government publications, please visit the Schools website at www.sog.unc.edu or contact the Bookstore, School of Government, CB# 3330 Knapp-Sanders Building, UNC Chapel Hill, Chapel Hill, NC 27599-3330; e-mail sales@sog.unc.edu; telephone 919.966.4119; or fax 919.962.2707. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. The words data and data-driven decision-making sound daunting; however, neither is something new. We hope that this article has encouraged you to use data analysis more in your work. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. 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. 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)? As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. 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. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. 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. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? WebYes; there is no requirement to prove a loss in revenue. It will include a detailed look at the various UG provisions and sample policies. If a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF award project, it must follow the subaward process. 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