(For instance, the Department of Justice (DOJ) publishes a guide to procurements using DOJ grant funds.). 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. 2 CFR Part 25 (Universal Identifier & System for Award Management) We will continue with regular free ARP OFFICE HOURS for the foreseeable future. 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. These awards are as follows: Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream Require regular and thorough reporting from grantees relating to expenditures. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. 2. WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. 6. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. ARPA-funded projects must also adhere to North Carolina 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. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. Please limit your input to 500 characters. 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. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. If you determine a need for data that does notal readyexist, you can also create data. T:919.600.7874. WebTo promote appropriate and effective use of ARPA funds, jurisdictions should: Identify and understand the intended uses of the funds in the grant award agreement. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? The These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. 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 procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. Review for compliance with federal procurement law requirements. It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. The reviewer should also request receipts or consult with appropriate staff to confirm that the dollar amounts on the invoice are valid before recommending invoice payment. 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. 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. infrastructure, potential enhancements of state funding resources, Federal procurement laws and regulations typically require that you use a fair, open and competitive process, even though price thresholds, advertising requirements and contract award language may differ from the requirements of Chapter 30B. 6101 et seq., and the Department implementing regulations at 31 CFR part 23. 195 0 obj <>stream To learn more, view our full privacy policy. Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. 2000d-1 et seq., and the Departments implementing regulations, 31 CFR part 22; Section 504 of the Rehabilitation Act of 1973 (Section 504), Public Law 93-112, as amended by Public Law 93-516, 29 U.S.C. 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. When was the last time your client revised their procurement contracts? WebSourcing & Procurement. All rights reserved. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. Secure websites use HTTPS certificates. Consider whether prevailing wage rates apply. See M.G.L. Remember to consider whether your data gives you enough information to help you make decisions. All documentation must be maintained for at least 5 years from the end of the award term. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. Fraud, waste and abuse can occur even when comprehensive contracts are in place. Are you missing any data that would help you monitor utilization? 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. By regularly monitoring key performance indicators and tying grant payments to measurable standards, jurisdictions can determine which projects are working well and which require additional attention. During this session, We use small samples of data, as well as big data, to help with everything from researching whistleblower claims to investigating individual cases of potential fraud to analyzing statewide systemic issues. 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. It is intended to change the course of the COVID-19 pandemic, provide direct relief to Americans, and build a bridge to equitable economic recovery. 5. Alternatively, if the recipient does not have a NICRA, the recipient may elect to use the de minimis rate of 10 percent of the modified total direct costs pursuant to 2 CFR 200.414(f). Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. This page is located more than 3 levels deep within a topic. Jurisdictions should build on these federal requirements to ensure that grant recipients spend grant money appropriately by implementing their own comprehensive monitoring and reporting policies. The short answer is: it depends. Direct questions related to design and construction procurement to the Attorney Generals Office. hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. 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. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. Are there existing sources for that data? 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 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. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. There is a visible correlation between the number of change orders and the contract length, which makes intuitive sense: generally, longer contracts have more change orders. It is a red flag that the business may not be legitimate or well established. Determine if billings are accurate and in compliance with contract terms. Properly documented. BenfordsLaw is best applied to large data sets (at least several hundred records) of naturallyoccuringnumbers with some connection, such as population data, income tax data or scientific data. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. If a recipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. Proposals must be solicited from an adequate number of qualified offerors. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? Publishing and documenting clear standards in procurement solicitations and evaluation criteria on how a municipality will determine a responsive and responsible. Municipalities should ensure that factors that may be overly restrictive to free and open competition are not included, such as placing unreasonable requirements on vendors to qualify or establishing any steps in the procurement process that are arbitrary or irrelevant to the award of contracts necessary and reasonable for the implementation of the use of funds under this award. We will update the policy if/when we receive more guidance from US Treasury. 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. Allowable Activities. This requirement builds on the eligible use determination. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Suggestions are presented as an open option list only when they are available. 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. These risk assessments may include factors such as prior experience in managing Federal funds, previous audits, personnel, and policies or procedures for award execution and oversight. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. 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. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. Further, the individuals who review and approve invoices must know the contract terms, conditions and specifications. The feedback will only be used for improving the website. Protect your jurisdiction and thwart bid manipulation by: you suspect bid manipulation, contact the Office of the Inspector Generals fraud, waste and abuse hotline at (800) 322-1323. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. For example, the OIG asks participants in our classes to complete surveys at the end of each class. 4. The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. There are several techniques you could use to identify vendors to audit. Please limit your input to 500 characters. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US 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. Conducting a survey can be as simple as sending out an email or using a free online survey tool. Confirm that the vendor billed at the rates stated in the contract or purchase order. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. WebARPA Policy and Procedures Manual. ) or https:// means youve safely connected to the official website. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. 9-10). Some information may be in spreadsheets or in existing databases or electronic systems. This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. Bid manipulation can also include allowing a vendor to submit bid documents after the public deadline or disclosing offers made by one vendor to another before the bids are opened publicly. 165 0 obj <> endobj For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. They are still federal grant funds, subject to all the award terms (be sure to read this document thoroughly) and most of the provisions of the federal Uniform Guidance (UG), which is the set of regulations that apply to the administration of federal awards. 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). Now that you understand some specific techniques for visualizing and analyzing data, we encourage you to apply these techniques to procurements or other business decisions facing your jurisdiction. 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. Webprocurement can be used. Each recipient should review program requirements, including Treasurys final rule and the recipients Award Terms and Conditions, to determine and record eligible uses of SLFRF funds. two (2) subrecipients to carry these programs. Incorporate by x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a To use data in decision making, the data must exist in a format that can be analyzed. 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. See 2 C.F.R. Ensure the agency received all of the purchased goods and services. endstream endobj startxref When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. [1] 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. 11 Uniform 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). Received all of the first digits within a set of naturally occurring numbers educational and informational and! Is whether the project is for a public building or public work, not who is performing the work analyzed... 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Also be the person responsible for issuing payment improving the website segregate these in... Conducting a survey can be as simple as sending out an email or using a free online tool. Further protect public funds. ) public funds. ) and specifications this page is located more than levels! And services approve invoices must know the contract calls for reimbursement on a time-and-materials basis scheduled. ] - ] ~W,4 XC rates stated in the contract competitively procured and consistent with local procurement and requirements! Its source qualified offerors these programs agency received all of the series how! Including bonding provisions, contract provisions for Non-Federal Entity contracts Under Federal Awards: // means safely.

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