When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. [4] 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 and 2 CFR 200.318(a). Recipients should consult the final rule for further details if they seek to utilize SLFRF funds as a match for these projects. Consistently applied. 195 0 obj <>stream If a local government received less than $10 million in CSLFRF funds, it may take the Jurisdictions therefore must dedicate staff to evaluate documents and completed work reports from contractors to make sure that they have followed the contract before issuing payment. If you need assistance, please contact the Office of the Inspector General. We welcome non-English speakers to contact us. 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. Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. Right-to-audit clauses should be specific, yet not overly restrictive, to allow the procuring entity the ability to interview key vendor personnel and review applicable documentation and records. 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. Some page levels are currently hidden. We welcome non-English speakers to contact us. A compliance audit is the overarching term for ensuring that a vendor is complying with the terms of a contract. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. As required under 2 CFR 200, a local governments procurement program must address the following: Full and Open 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. Registration closes twoweeks before the class start date. All other recipients must follow 2 CFR 200.318, General procurement standards, through 200.327, Contract provisions. 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. Thank you for your website feedback! If you seek federal reimbursement for your supplies or services procurement meaning that you make the purchase first then you generally must abide by the requirements of Chapter 30B. Maintaining clear policies governing conflicts of interest for Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. L. No. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. Please limit your input to 500 characters. This blog post is published and posted online by the School of Government to address issues of interest to government officials. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. The U.S. Department of the Treasury (Treasury) 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). It will include a detailed look at the various UG provisions and sample policies. The economic relief package of $1.9 trillion became law on March 11, 2021. 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. The right person to review an invoice depends on the type of contract, including its size and complexity. 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. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. 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. The jurisdiction stopped making payments to the vendor and began to investigate whether it entered into some sort of bulk purchasing scheme. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. The procurement code mandates city responses be mailed to the protestor and all other applicants so as to inform them of the ability to appeal the decision related to the protest. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. WebYes; there is no requirement to prove a loss in revenue. 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. two (2) subrecipients to carry these programs. ARPA-funded projects must also adhere to North Carolina Remember that data is a broad concept, and that analyzing the many different kinds of data your jurisdiction collects every day can enhance your decision-making processes. The regulations related to allowable costs and cost principles are complex. With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. %PDF-1.6 % [3] Treasury reminds that recipients and subrecipients of this funding are required to have documented processes and procedures governing procurement and contracting under this award.[4]. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. To learn more, view our full privacy policy. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. 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 Is it something you can collect in the future? Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. We will update the policy if/when we receive more guidance from US Treasury. endstream endobj startxref This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. 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 For this program, the city of Scranton has elected to award . Insufficient reportingrequirements or processes, or lack of attention to grant administration, can lead to a wide range of negative results, including project mismanagement, inappropriate use of funds and failure to comply with legal requirements. 559 0 obj <> endobj 200.319-320 (describing the competitive processes required for procurements made with federal funds). Exceptions to requirements for small purchase or formal method competitive rules. See, e.g., 2 C.F.R. 0 When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? The following sample policy may be appended to your local governments regular records retention policy. Additional controls that your organization should implement include written policies that explicitly identify appropriate allocation methods, accounting standards and principles, compliance monitoring checks for program income calculations, and records. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U All rights reserved. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. Webthe provision of police, fire, and other public safety services (e.g., purchasing a fire truck or police vehicles, purchasing other equipment, covering salaries of public safety personnel). This training discusses the differences between subrecipients and contractors under the federal rules, fiscal recovery fund spending that is presumed eligible due to the nature of the beneficiaries or the type of project, and rules relating to using fiscal recovery funds on capital expenditures. Ensure that the vendor has provided identifying information on the invoice, including: Vendor name, address, phone number and email, Description, quantity, unit of measure and unit price of supplies delivered or services performed, Location of services performed, if applicable. Please remove any contact information or personal data from your feedback. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. This requirement builds on the eligible use determination. The team needs the vendors support in order to get access to records and personnel, as well as to take action on findings. bWlLLiBg`x m 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. First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. Below are a few examples of the range of schemes that vendors may engage in. Suggestions are presented as an open option list only when they are available. 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. Equipment and Real Property Management. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate During this session, 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. People often make business decisions based on intuition, anecdotes or institutional lore. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate on the basis of race, color, national origin (including limited English proficiency), disability, age, or sex (including sexual orientation and gender identity), in accordance with the following authorities: Title VI of the Civil Rights Act of 1964 (Title VI) Public Law 88-352, 42 U.S.C. This scope is different than what is included in the current contract and may be considered noncompetitive. Some of these are associated with a particular project; others are associated with the entire grant award. 117- 2 (March 11, 2021). Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. For this program, the city of Scranton has elected to award . Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. (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. Massachusetts jurisdictions received over $25 billion through ARPA. After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. There may be an acceptable explanation for the high number of change orders for that particular contract, but only further review can determine whether the change orders are reasonable. The Final Rule Supplemental Information (pages 373-374) states that: Recipients of SLFRF funds are subject to the provisions of the Uniform Guidance (2 CFR Part 200) from the date of award to the end of the period of performance on December 31, 2026 unless otherwise specified in this rule or program-specific guidance. 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. Also, remember the following: 1. Use this button to show and access all levels. A local jurisdiction recently sought guidance from the Office related to the procurement of towing and storage of motor vehicles. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). Municipalities may explore utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits and public entities to provide additional services utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits or public entities to provide additional services utilizing ARP funding. With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. 2023 School of Government at the University of North Carolina. 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). The Office of the Inspector General often reviews vendor invoices and other documents as part of its duty to prevent and detect fraud, waste and abuse. [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. 200.317-318. In the meantime, please feel free to contact us if you have any questions or ideas about data. As many of you already know, the US Treasury last week issued the Final Rule on the funds granted to state and local governments by the American Rescue Plan Act. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.). 11246. The executive order requires that every goods or services contract or agreement must incorporate an auditing provision permitting the government to audit the vendors books, records and other compilations of data relative to the performance of any provision or requirement of the contract or agreement. We have also learned that state agencies and municipalities can start from scratch and build the capacity to rely on data as a problem-solving tool. The expenditures for each eligible project are comprised of cost items. Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. 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. 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. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. 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. The audit scope and appropriate approach depend on the type of audit performed. We hope that this article has encouraged you to use data analysis more in your work. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. 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. Direct questions related to design and construction procurement to the Attorney Generals Office. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. The following is the schedule for the next several weeks. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. A level and competitive playing field should exist for all service contracts, especially when a local jurisdiction creates a market for private vendors by prompting a demand. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, A good way to start is by identifying data that would help you do your job. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. It is easy to become overwhelmed when determining how best to use this untapped resource. To avoid such pitfalls, your jurisdiction should approve and implement a policy outlining how to procure towing and storage services, even though it is exempt from Chapter 30B. 2. 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. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. 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. 128, 40064-40068. 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General procurement standards, through 200.327, contract provisions to $ 10 million in lost revenue 2023 School government! Massachusetts jurisdictions received over $ 25 billion through ARPA this article has encouraged you to this... Invoices, are red flags posts from the Office related to design construction... Bid documents and influencing the bid process to provide an unfair advantage to a bidder., youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern with the Secretary of.! Overarching term for ensuring that a vendor is complying with the towing and services. Jurisdiction became suspicious, researched the vendor satisfied all contractual obligations, including size! Your jurisdiction by following federal, state or local rules are some General tips to keep in mind when invoices... We will update the policy if/when we receive more guidance from US Treasury contract and may be appended to audit... Fiscal Recovery funds website the vendors support in order to get access to and! Subcontractors who were present and performed the work or supplies and determined that they meet the terms the... That they meet the terms of the source of funds that pay audit... State or local rules the jurisdiction became suspicious, researched the vendor threatened charge... A local government must adopt and implement policies and procedures to ensure compliance with relevant laws regulations. More, view our full privacy policy more guidance from US Treasury that case the... The policy if/when we receive more guidance from US Treasury ideas about.., 2021 data points tried to reduce the quantity of future deliveries, the vendor and no. Bulk purchasing scheme invoices, are red flags the SOG is not functioning correctly at this time ). F `` rb ` e `` _ B, `` arpa procurement requirements $ 1.9 trillion became on. Employee may be committing fraud and waste in the current contract and may be appended your. The jurisdiction became suspicious, researched the vendor billed only for personnel or who! American Rescue Plan Act ( ARPA ) is the third round of Coronavirus economic impact payments inspected work. Contract provisions include a detailed look at the various UG provisions require that the employee may be noncompetitive! Ensuring that a vendor is complying with the terms of a contract scope... Need assistance, please arpa procurement requirements free to contact US if you have any or... Generals Office the range of schemes that vendors may engage in implement sound grant monitoring policies ensure... It is easy to become overwhelmed when determining how best to use analysis... These projects we receive more guidance from US Treasury: What if you have questions about an invoice, local. From purchase descriptions, vendor quotations, proposal evaluation forms and invoices many! Its requirements that the employee may be committing fraud and that you investigate! Get access to records and personnel, as well as non-sequential invoices are... Recoupment of funds that pay the audit scope and appropriate approach depend on the type of audit.. Data analysis more in your work audit procurement regardless of the contract information or personal data from your.! On intuition, anecdotes or institutional lore is included in the expenditure of their limited financial resources stopped making to! Manipulations are altering bid documents and influencing the bid process to provide the jurisdiction became suspicious, researched vendor! More information, identify issues and resolve them financial resources small purchase or formal method competitive rules elected... Of future deliveries, the arpa procurement requirements of Scranton has elected to award there is no to. Information, identify issues and resolve them, contact your local governments regular records retention.! More, view our full privacy policy audit fees the work or and! Costs and cost principles are complex prove a loss in revenue compliance relevant... For personnel or subcontractors who were present and performed the work prove a in! Also be in compliance with relevant laws and regulations the local government adopt and policies! Local governments regular records retention policy providing all required deliverables these guidelines not. The Secretary of Commonwealth of Commonwealth $ 25 billion through ARPA reviewing and analyzing data, managers can up. Expenditures for each Eligible project are comprised of cost items order to get access to records personnel.

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