200.319-320 (describing the competitive processes required for procurements made with federal funds). Each of the considerations above, as well as operation and maintenance Some of these are associated with a particular project; others are associated with the entire grant award. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. 584 0 obj <>/Filter/FlateDecode/ID[<835934A992BE5B40B85FB79B51E29EDE>]/Index[559 43]/Info 558 0 R/Length 119/Prev 296096/Root 560 0 R/Size 602/Type/XRef/W[1 3 1]>>stream For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. 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). After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. Are there other vendors or organizations that could also reasonably and responsibly provide the good and/or service that may object to the lack of competition available for federal funds? If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. 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 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 otherwise specified in program-specific guidance. Further, the individuals who review and approve invoices must know the contract terms, conditions and specifications. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. T:919.600.7874. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. necessary to lawfully utilize federal ARPA funds for procurement or construction? If you are still unclear about the requirements for your particular source of funding, we recommend that you contact the grantor or federal funding entity for clarification. 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. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. Look for those in the coming weeks. 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. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Please take a moment to participate in our Community Satisfaction Survey. Review for compliance with federal procurement law requirements. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. Once you have access, you can use the data to inform your decisions and manage risks. Capital Funds Project website. They are SLFRF recipients that will report directly to Treasury. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. Review the contract and be familiar with its terms. Thus, the jurisdiction created a ready market for a single vendor without ensuring that drivers were receiving a fair price for the towing and storage services. Mathematicians studied collections of numbers and found that the first digit will be a 1 about 30% of the time and a 2 about 17% of the time, with subsequent numbers following a similar decreasing pattern, as shown in the data visualization on the next page. The following are tools to implement this requirement: Allowable Costs/Cost Principles. 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. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. The following are a sample subaward policy, risk assessment, subaward agreement template, and subrecipient monitoring tool (they are all in a single Word file): Although there is a lot of federal red tape to navigate regardless of how a local government expends its ARP/CSLFRF funds, there are some opportunities to reduce a local units compliance burden. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act, Treasury will collect and review information from non-Tribal recipients to ascertain their compliance with the applicable requirements before and after providing financial assistance. 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. One key oversight tool is the vendor audit. If data analysis leads you to believe that fraud has occurred, please contact the OIGs Fraud Hotline at (800) 322-1323 orIGOFightFraud@state.ma.us, orfill out our online form. 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. Incorporate by Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? infrastructure, potential enhancements of state funding resources, The economic relief package of $1.9 trillion became law on March 11, 2021. Knapp-Sanders Building If a local government received less than $10 million in CSLFRF funds, it may take the Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. A good way to start is by identifying data that would help you do your job. ) or https:// means youve safely connected to the official website. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. 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. 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. Treasury may request transfer of records of long-term value at the end of such period. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. The feedback will only be used for improving the website. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. 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). Properly documented. Additional changes to compliance and reporting guidelines, including any clarifications on Uniform Guidance requirements, will be addressed in Compliance and Reporting Guidance and the User Guide. Are there existing sources for that data? 9-10). of the Award Terms and Conditions, Accessibility: Report a Digital Access Issue, Allowable Costs and Cost Principles Policy, Financial Management and Internal Controls, Program Income Policy (if local government uses ARP/CSLFRF funds to establish a loan program or otherwise earns income related to an ARP/CSLFRF expenditure), Procurement Policy (if a local government contracts for goods or services paid for with ARP/CSLFRF funds, or must engage in a Single Audit (even if the audit is paid for with other funds)), Property Management Policy (if a local government uses ARP/CLSFRF to acquire or improve any real property, equipment, or supplies), Subaward Policy (if a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF-eligible project), Thursday, March 24, at 8:30am (focus on affordable housing). The goal of a vendor fraud audit is to determine whether the vendor intentionally acted to defraud the contracting organization. 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. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. SLFRF funds beyond those that are available under the revenue loss eligible use category may not be used to meet the non-federal match or cost-share requirements of other federal programs, other than as specifically provided for by statute. ARPA REQUIREMENTS TO BE INCLUDED IN These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. This collection does not apply to Tribal governments. 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. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. Once the data has been transformed into auser-friendlyformat, it can be used in a variety of ways to assist with future procurements and other business decisions. Upon arpa procurement requirements audit fees compliance audits might evolve into a fraud audit is to determine whether the vendor not. Order with the vendor intentionally acted to defraud the contracting organization must conform to the invoice the feedback only! 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