arpa procurement requirements

Track and maintain records of all grant-related documents, including communications, receipts and invoices. Finally, Kara hosted SOG Office Hours on Jan. 13, 2022, and the primary topic was the Final Rule and the change in lost revenue calculations. 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. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. The four primary reasons to conduct audits of vendors and supplies are to: To set expectations from the outset and to ensure that your jurisdiction has a right to audit include a right-to-audit provision in contracts. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. Capital Funds Project website. Mayor Smiley wants to hear from you! If so, are there differences between the local and federal requirements that may be in conflict? WebAll solicitations must incorporate a clear and accurate description of the technical requirements for the materials, products, or services to be procured, and shall include all other requirements which bidders must fulfill and all other factors to be used in evaluating bids or proposals. Broadly speaking, data is any fact about an object or concept. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Maintaining clear policies governing conflicts of interest for When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. 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. S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$AqYoX%F"YC CV8OEG?+7yOet~f4e&xfqgP*1:bWn5lu-J;[:gqG5SfJ Qbu8CZq|+gBjUC5.P06. 5=;I?s=pCOsV+k 4^ "6!p ~|: 1 GW%kO &)1dwO1(SEQqm2(Rh !3I`eUb&. Use this button to show and access all levels. The jurisdiction stopped making payments to the vendor and began to investigate whether it entered into some sort of bulk purchasing scheme. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Where feasible, municipalities should consider taking steps to ensure competition is accessible to minority- and women-owned businesses in addition to labor surplus area firms. 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. 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. (For instance, the Department of Justice (DOJ) publishes a guide to procurements using DOJ grant funds.). As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22, ARPA Subgrantee Agreement Template Reimbursement Based rev11.3.22, ARPA Subgrantee Agreement Template 100% Advance Payment (Very Rare-Special Circumstances) rev11.3.22, ARPA Subgrantee Agreement Template 25% Advance Payment rev11.3.22, ARPA Beneficiary Agreement Template rev11.3.22, SLFRF_Subgrantee_Budget_Exhibit 3_ 11.3.2022, SLFRF_Subgrantee_Invoice_Exhibit 4_11.3.2022. To learn more, view our full privacy policy. 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 prevention and detection of fraud, waste and abuse of public funds always an important issue for government entities is even more critical now that jurisdictions are receiving billions of additional dollars in ARPA funding. To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an Allowable Costs and Cost Principles Policy. Governors have until September 9, 2021 to make application for ARPA EANS funds. 128, 40064-40068. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, 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 To ensure that jurisdictions get the supplies and services they need and to combat fraud, waste and abuse, it is essential that jurisdictions carefully review all vendor payment requests. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. Surveys are a helpful way to do this. 2 CFR 200.320(c). The results of the survey can be transferred to a spreadsheet. Use of this blog post for commercial purposes is prohibited. 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. WebSourcing & Procurement. We welcome non-English speakers to contact us. 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. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. If your contract does not permit the vendor to charge a specific fee, then your jurisdiction has a basis for contesting the application of any additional fee. 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. Recently in Massachusetts, a vendor offered a significant cost savings on supplies a local jurisdiction needed. 195 0 obj <>stream It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. 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. It is a red flag that the business may not be legitimate or well established. 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. If you identify a fee or charge that is not accounted for in a contract between your jurisdiction and a vendor, contact the vendor for an explanation; or request a corrected invoice and a return of any improperly paid fees. Are there special requirements for capital We also plan to give an overview of some of these techniques in the next article on data in an upcoming edition of the OIG Bulletin. 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. These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. 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. Data is everywhere, and every function a government performs can generate valuable data. As you may know, under Section 1(b)(21) of Chapter 30B contracts for the towing and storage of motor vehicles are exempt from the Uniform Procurement Act. Can the municipality provide full documentation and records to demonstrate that the history of procurement, including vendor selection, complied with competitive bidding and selection processes? Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. 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). The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. 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. Program Income. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. 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. 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. The expenditures for each eligible project are comprised of cost items. For example, per 2 CFR 200.425, a reasonably proportionate share of the costs of audits required by the Single Audit Act Amendments of 1996 are allowable; however, costs for audits that were not performed in accordance with 2 CFR Part 200, Subpart F and the Compliance Supplement are not allowable. 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. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act (ARPA).The Final Rule makes several key changes to the Interim Final Rule, including expanding the eligible uses of If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. One key oversight tool is the vendor audit. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. The short answer is: it depends. Or maybe you used a more sophisticated tool to make that decision for example, the weather app on your phone but in both cases you used data to decide to wear a raincoat. 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