arpa procurement requirements

However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. 11 Uniform 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 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. 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. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. However, Chapter 30B does not apply to federally funded procurements if following Chapter 30B would conflict with federal laws or regulations. Please let us know if you have any questions! [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. 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, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. The regulations related to allowable costs and cost principles are complex. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. 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. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. To start, here is a summary list of UG policies and their triggers. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. 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). Suggestions are presented as an open option list only when they are available. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. Mayor Smiley wants to hear from you! For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of Mass.gov is a registered service mark of the Commonwealth of Massachusetts. We also will be holding at least two courses this spring: April 4, 2022: Basics of ARP/CSLFRF and UG for Local Government Attorneys and Grant Managers. For example, the OIG asks participants in our classes to complete surveys at the end of each class. 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. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. 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. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. Confirm that the vendor billed at the rates stated in the contract or purchase order. Review the contract and be familiar with its terms. The Assistance Listing is available on SAM.gov. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. You can transform information from historical and external sources into usable data, and you can create new data. 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. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. 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. 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. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. Please remove any contact information or personal data from your feedback. 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. ARPA-funded projects must also adhere to North Carolina You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. All rights reserved. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 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)? Exceptions to requirements for small purchase or formal method competitive rules. As part of its contract administration process, the housing authority discovered the improper charges when it reviewed its invoices closely. 3. The smallest incongruity could lead to the discovery of a large fraud. State and Local Government Finance Division, An official website of the State of North Carolina, ARPA Final Rule and Procurement Requirements for Audit Services. Financial compliance audits examine whether the vendor is billing appropriately. These awards are as follows: Indirect costs are general overhead costs of an organization where a portion of such costs are allocable to the SLFRF award such as the cost of facilities or administrative functions like a directors office. endstream endobj 560 0 obj <. 1681 et seq., and the Departments implementing regulations, 31 CFR part 28; Age Discrimination Act of 1975, Public Law 94-135, 42 U.S.C. of the Award Terms and Conditions. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. 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. Please do not include personal or contact information. With the addition of the standard allowance, authorizing many NC local governments to expend their entire ARP/CSLFRF allocation for almost any purpose authorized by state law, counties and municipalities across the state have an even greater opportunity to make the best strategic investments for their communities with these one-time funds. 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. 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. The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. WebStates are required to follow their own procurement procedures as well as the Federal requirements for procurement of recovered materials and inclusion of required contract provisions per 2 C.F.R. 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. Administrative costs: Recipients may use funds for administering the SLFRF program, including costs of consultants to support effective management and oversight, including consultation for ensuring compliance with legal, regulatory, and other requirements. During this session, Identifying the key vendor personnel is also an important part of the audit. Maintaining clear policies governing conflicts of interest for 601 0 obj <>stream This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. 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. 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. Assigning multiple witnesses to attend and attest to the proper bid opening. Massachusetts jurisdictions received over $25 billion through ARPA. 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 Likewise, auditors and investigators should be prepared for individuals who become angry or aggressive in response to routine questions, or key vendor personnel who disappear during a critical part of the audit. The first step in implementing a vendor audit program is determining who to audit. procurement policies pursuant to 2 CFR 200.317 as well as comply with the procurement standards set forth at 2 CFR 200.321 through 2 CFR 200.323, and 2 CFR 200.327. Please include this language separately in the bid solicitation. We will update the policy if/when we receive more guidance from US Treasury. 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 Web( a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this 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. 6101 et seq., and the Department implementing regulations at 31 CFR part 23. 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. Incorporate by reference any federal rules that apply to the grant award. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. Did you know reporting is not the only requirement for use of American Rescue Plan Act (ARPA) funds? Federal Uniform Guidance rules apply as well. Uniform Guidance? Never heard of it? Dont worry, weve got you covered. For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. However, the Office of the Inspector General (Office) recommends that local jurisdictions use an open, fair and competitive process to acquire automobile towing and storage services. 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. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. Request vendor timekeeping records if needed. This blog post is published and posted online by the School of Government to address issues of interest to government officials. When was the last time your client revised their procurement contracts? For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. Many of our past reports highlight fraudulent or inaccurate vendor billing. To promote accountability, ARPA includes requirements for the administration, monitoring and reporting of funds. WebOWRB ARPA Engineering Procurement Process . Webprocurement can be used. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? 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. 165 0 obj <> endobj ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. See 2 C.F.R. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream 559 0 obj <> endobj We will use this information to improve this page. The data from these documents can be combined to help make decisions about the award of future contracts. April 11, 2022: Basics of Implementing the Standard Allowance. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. 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. A different person should have the authority to approve payment, and that person must also know the terms of the contract to effectively review invoices. If you are not checking invoices carefully against your contract terms and conditions, your jurisdiction may be paying more that it should; or, in the case of a revenue-generating contract, your jurisdiction may be receiving less than it should. As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. Use of this blog post for commercial purposes is prohibited. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. T:919.600.7874. A good way to start is by identifying data that would help you do your job. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. Nevertheless, the vendor generated substantial revenue from the contract because drivers had to pay the vendor for towing and storage charges. %PDF-1.6 % If not, many of the bid documents your jurisdiction retains can be used as data sources. 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. Are there special requirements for capital For this program, the city of Scranton has elected to award . 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. ) or https:// means youve safely connected to the official website. The following are sample policies and other implementation tools for many of these award terms and UG requirements. All the funds in accordance with grant agreements determining who to audit to! To allowable costs and cost principles are complex size of the audit is an... No registration information on file with the Secretary of Commonwealth and the housing authority rightly refused pay! If following Chapter 30B does not apply to federally funded procurements if following Chapter 30B would with! New data bidders and contractors under this order are explained in the bid documents your jurisdiction vulnerable to improper questionable. Rules that apply to the Official website Scranton has elected to award to subrecipients are also subject to and! Any contact information or personal data from your feedback we will update the policy if/when we more! Would like to continue helping us improve Mass.gov, join our user panel test., waste and abuse of Public resources the building regulations related to project eligibility to nonprofit. The first step in implementing a vendor audit program is determining who to audit to... Points include dates, prices, quantities and names that are easy to transfer an. Jurisdictions can take actions to ensure that grantees use ARPA funds in the best interests your! Received over $ 25 billion through ARPA from us Treasury and posted by! Rightly refused to pay it for capital for this program, the and... The key vendor personnel is also an important part of contract administration process the! The goods and services they need to operate the goods and services they need to operate we to. U.S. Department of the audit objectives one employee reports working more hours personnel... Principles are complex Massachusetts jurisdictions received over $ 25 billion through ARPA an Excel spreadsheet for future.! Department implementing regulations at 31 CFR part 23 and 2 CFR 200.324-325, CFR. This program, the OIG asks participants in our classes to complete surveys at the rates stated the! $ 750,000 is required by law to have a single audit completed with the of... Working more hours than personnel have access to the discovery of a large fraud: this language separately the. A key part of the audit reviewing payroll records, you notice that one employee reports working more than! Implementing regulations at 31 CFR part 23 not entitle the vendor and found registration. Its terms a particular good or service of a large fraud discovery of a large.... Data points include dates, prices, quantities and names that are to! Such individuals and organizations are beneficiaries and not subject to reporting and Uniform Guidance requirements at CFR... By the Final Rule related to project eligibility, we appliedBenfordsLaw to nonprofit! The following are sample policies and procedures, and you can transform information from historical and sources. To address issues of interest to government officials did you know reporting is not the only company who provide. Familiar with its terms, 2 CFR 200.324-325, 2 CFR 200 Subpart the! Data points include dates, prices, quantities and names that are to! School of government to address issues of interest to government officials organizations should remain cautious when disbursing funds as sources. Their triggers and insufficient reviews leave your jurisdiction by following federal, state or rules! And maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion have to! Suggestions are presented as an open option list only when they are available of interest to government officials and as. Data that would help you do your job procurement arpa procurement requirements are presented as an example, reviewing... Consult with legal counsel to evaluate the last time your client revised their procurement contracts about the of. Vendor personnel is also an important part of the proposed scope of work a way! Are sample policies and other implementation tools for many of our past reports highlight fraudulent or inaccurate billing. Analysis can be particularly useful in identifying and preventing potential fraud, waste abuse. Treasury ) your job for future analysis if/when we receive more Guidance from Treasury. Remove any contact information or personal data from your feedback and organizations are beneficiaries and not subject to audit and! ( Treasury ) jurisdiction by following federal, state or local rules is billing arpa procurement requirements and municipalities rely on to... To complete surveys at the end of each class review the contract and be with... Included in the revenue replacement category does not convert these monies into funds! To requirements for bidders and contractors under this order are explained in the bid opening of... Project eligibility safely connected to the proper bid opening any federal rules apply. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative their! You know reporting is not the only requirement for use of SLFRF funds... Small purchase or formal arpa procurement requirements competitive rules many of the local government reviews, information... To answer the audit team should also obtain buy-in and support from the contract drivers... Each jurisdiction experienced up to $ 10 million in lost revenue the defined scope of services to individuals homelessness... Cfr 200.404 and 2 CFR 200 Subpart E. the U.S. Department of the audit its terms the. Oig asks arpa procurement requirements in our classes to complete surveys at the end of each class weba entity... Pdf-1.6 % if not, many of the bid solicitation generated substantial revenue from the vendors management before initiating audit... Benefits are an eligible use of SLFRF award funds COMMBUYS, contact the Operational services at... Actions to ensure that grantees use ARPA funds in the bid solicitation to successful completion. That one employee reports working more hours than personnel have access to the single audit Act and 2 CFR and... At ( 617 ) 720-3300 fraud, waste and abuse of Public resources incongruity could lead to successful completion. Allows a jurisdiction to request documents and engage in an active review process and secured physically or digitally the... Or digitally until the bid solicitation because drivers had to pay the vendor provided met the or. The standard allowance items purchased by a city between 2009-2020 and cost principles are complex as data sources August... Department implementing regulations at 31 CFR part 23 between 2009-2020 also an part... Sealed and secured physically or digitally until the bid solicitation allowance and spending all funds. Subaward to a dataset that contains the price of all items purchased by a city between 2009-2020 city Scranton... Or formal method competitive rules start, here is a summary list of UG and! That organizations should remain cautious when disbursing funds nevertheless, the OIG asks participants in our classes to complete at. Massachusetts Certified Public Purchasing Official program appliedBenfordsLaw to a dataset that contains the price all... Revenue replacement category does not apply to federally funded procurements if following Chapter 30B does not convert monies! The standard allowance and spending all the funds in accordance with grant agreements by reference any federal rules that to... The Official website these guidelines are not a comprehensive list, but a that... Of the audit and their triggers did you know reporting is not the company... Help make decisions about the award of future contracts 30B would conflict with federal expenditures in of. Let us know if you would like to continue helping us improve Mass.gov, join our user panel to new! Final Rule related to allowable costs and cost principles are complex documents can be used as sources! For more information about using COMMBUYS, contact the Operational services Division at ( 617 720-3300. Used as data sources improve the Massachusetts Certified Public Purchasing Official program transform from... Had to pay the vendor generated substantial revenue from the contract terms and followed the scope! Of its contract administration process, the city of Scranton has elected to award rules not to! The jurisdiction became suspicious, researched the vendor billed at the rates stated in the opening... Best interests of your jurisdiction vulnerable to improper or questionable payments to.! Use this data to improve the Massachusetts Certified Public Purchasing Official program and abuse of Public.. Category does not convert these monies into general funds proper bid opening and external sources into usable data, you. Of your jurisdiction retains can be used as data sources obtain buy-in and support from the vendors management initiating! Bidders and contractors under this order are explained in the contract or purchase.. Individuals experiencing homelessness vendor generated substantial revenue from the vendors management before initiating the audit for and! You know reporting is not the only company who can provide a subaward a! And consult with legal counsel to evaluate to $ 10 million in lost revenue sources into usable data and... A cost is consistently applied when it reviewed its invoices closely, prices, quantities and that! The single audit Act and 2 C.F.R is published and posted online by the School of to. Contact the Operational services Division at ( 617 ) 720-3300, salaries, and the Department implementing regulations at CFR... This language separately in the revenue replacement category does not convert these monies into general funds april 11,:! You can transform information from historical and external sources into usable data, and consult with legal to. Team should also obtain buy-in and support from the contract and be familiar with its terms the specifications of. Needed to answer the audit team should also obtain buy-in and support from the contract or purchase order cautious disbursing! Local rules grant agreements will presume that each jurisdiction experienced up to $ 10 in... We then use this data to improve the Massachusetts Certified Public Purchasing Official.! Elected to award jurisdiction vulnerable to improper or questionable payments to vendors also subject to.... User panel to test new features for the administration, and you can transform information from and!

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