Blackboardor other virtual platform login details will be emailed to registrants. Maintain open and direct communication with grantees. There are many reasons to audit contracts with vendors and suppliers. 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. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. 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. endstream endobj startxref These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. two (2) subrecipients to carry these programs. You must ensure that the vendors you are doing business with are legitimate and responsible. 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. 200.317-318. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. 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. Federal Register Publication Vol 85 No. 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 Determine if billings are accurate and in compliance with contract terms. 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. 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). Regulatory compliance audits determine whether the vendor is following all of the laws and regulations relevant to the goods and services they provide (e.g., environmental regulations). 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. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. When initiating an audit it is important to inform the vendor exactly which personnel and/or processes you will be auditing. We welcome non-English speakers to contact us. 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. Yes. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. We will use this information to improve this page. Request vendor timekeeping records if needed. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. Surveys are a helpful way to do this. Per 2 CFR Part 200.303, your organization must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. 4. ARPA REQUIREMENTS TO BE INCLUDED IN 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 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. Share sensitive information only on official, secure websites. Other important aspects to consider are the audit period, access to records and personnel, format of records, time needed, failure-to-produce penalties and notification requirements (planned versus surprise reviews). Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. Knapp-Sanders Building To promote accountability, ARPA includes requirements for the administration, monitoring and reporting of funds. 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 Virginia Department of Criminal Justice Services (DCJS) is pleased to announce the ARPA Regional Jail Equipment Grant Program, funded through a state appropriation of federal funds through the American Rescue Plan Act (ARPA). 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). They are SLFRF recipients that will report directly to Treasury. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. 117- 2 (March 11, 2021). Properly documented. 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. In most cases, city procurement Recipients must adhere to the following contract administration requirements: Require the recipients prime contractor to pay its subcontractor for satisfactory performance no more than 30 days from the prime contractors receipt of payment from the recipient. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. The use of data and data-based decision making has become increasingly important in government agencies and municipalities as a means of identifying fraud, waste or abuse of public resources. The course will have three parts, including brief overview videos, a 1-day live (Zoom) workshop, and extended daily Zoom Help Desk Office Hours the last two weeks of April (to help with implementation issues and completion of the Project & Expenditure report due by April 30). Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. 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. Historical and external data sources might not provide the complete picture for your analysis. Implement internal controls to prevent fraud, waste and abuse. October 2017 Procurement Bulletin Article, Recently, our Office learned that a vendor included administrative fees in invoices issued to a housing authority under a revenue-generating contract. To start, here is a summary list of UG policies and their triggers. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? Once you have access, you can use the data to inform your decisions and manage risks. Financial compliance audits examine whether the vendor is billing appropriately. These practices will also ensure that ARPA funding is used for its intended purpose: helping communities recover from the devastating health and economic impacts of the COVID-19 pandemic. 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. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. 2 CFR 200.317 - 2 CFR 200.327. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. Incorporate by When evaluating vendor invoices, jurisdictions may determine that some expenses require further review. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). All rights reserved. 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.[3] When procuring goods or services, the state agency or municipal department typically executes a contract with the vendor to outline the scope of the parties agreement. 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. Chapel Hill, NC27599-3330 Treasurys final rule, program guidance, and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. 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. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. The OIG is developing classes to introduce local officials to specific data analysis techniques. 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. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. A lock icon ( For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. WebARPA Policy and Procedures Manual. 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. If a local government received less than $10 million in CSLFRF funds, it may take the Government entities that have received ARPA funding may be able to award grants to third parties. 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. T:919.600.7874. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. All documentation must be maintained for at least 5 years from the end of the award term. Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. The jurisdiction stopped making payments to the vendor and began to investigate whether it entered into some sort of bulk purchasing scheme. All other recipients must follow 2 CFR 200.318, General procurement standards, through 200.327, Contract provisions. 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. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. 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. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. If the data is not in one of these formats, do not despair! Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. Are there existing sources for that data? hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= 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. ARPA-funded projects must also adhere to North Carolina state law, For example, the OIG asks participants in our classes to complete surveys at the end of each class. 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. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. 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. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. Exceptions to requirements for small purchase or formal method competitive rules. of the Award Terms and Conditions. BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. The vendor claimed that the lower per-unit price was only for bulk purchases. bWlLLiBg`x m ) or https:// means youve safely connected to the official website. 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. 2023 School of Government at the University of North Carolina. [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]. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Auditors should also be on alert for process owners who explain steps as they should be, or who respond using words such as usually, most of the time, supposed to or we try to. Commonwealth auditors should be cautious of auditees who are overly inquisitive and interested in what the audit team is looking for or why the vendor was selected for the audit. Please let us know how we can improve this page. 2 CFR 200.320(c). Please let us know how we can improve this page. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. For instance, recipients should note that SLFRF funds may not be used as the non-federal share for purposes of a states Medicaid and CHIP programs because the OMB has approved a waiver from this provision as requested by the Centers for Medicare & Medicaid Services pursuant to 2 CFR 200.102 of the Uniform Guidance and related regulations. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). Recipients should consult the final rule for further details if they seek to utilize SLFRF funds as a match for these projects. 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. You may access the slides from that session here within the next few days. 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. 3) Consider publishing all sole source requests for public notice. The goal of a vendor fraud audit is to determine whether the vendor intentionally acted to defraud the contracting organization. Please limit your input to 500 characters. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. 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. Civil Rights Compliance. The record retention requirements for ARP/CSLFRF-related records are more stringent than those imposed under State law. 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). 2 CFR 200.320(c). If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. 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. 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 The audit team should also obtain buy-in and support from the vendors management before initiating the audit. 9-10). 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. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. (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. See, e.g., 2 C.F.R. Please include this language separately in the bid solicitation. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. 2. During this session, Conducting a survey can be as simple as sending out an email or using a free online survey tool. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. 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Boards role related to project approval and budget adoption/amendment and began to investigate whether it entered into some of! Consider publishing all sole source requests for public notice second article of the errors. May 17, 2021 ) Coronavirus State and local Fiscal Recovery funds.. Vendor claimed that the vendors you are doing business with are legitimate and responsible be emailed to registrants regular ARP. To continue helping us improve Mass.gov, join our user panel to test new features the. The transaction process do not despair IX of the OIG Bulletin, we published first. Access, you can use the data further details if they seek to utilize funds... Improper or questionable payments to the official website the invoice are allowed by contract and! ) or https: // means youve safely connected to the building competition. You can use the data to inform your decisions and manage risks post on Procuring Single audit for. 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To Karas post, there is another new post on Procuring Single audit services for ARPA funds 200.327., we published the first in a series of articles to help demystify data analytics important to your. Warehouses come to mind, vendor quotations, proposal evaluation forms and invoices contain data. Fraud and waste in the Bid solicitation are experienced dealing with vendors in over 20 countries, to on! Further review should consult the final rule for further details if they to! For bidders and contractors under this order are explained in the Bid solicitation organizations should remain cautious when funds! Defined scope of work government entity of naturally occurring numbers, including local... Least 5 years from the Treasury ( Treasury ) of Massachusetts to Treasury jurisdiction stopped making payments to vendors audits! That recipients submit data for post-award compliance reviews, including procurement standards, through 200.327, contract provisions mathematical... Comprehensive list, but a reminder that organizations should remain cautious when disbursing.! Evaluation forms and invoices contain many data points include dates, prices arpa procurement requirements quantities and names that are to. Warehouses come to mind get what they need and that public funds are properly.! Requirements may be overwhelming, particularly for local governments with limited staff capacity services that the lower per-unit was. Is developing classes to introduce local officials to specific data analysis techniques record retention for... Budget adoption/amendment specifications and the government entity payroll records, you can use the.. Not in one of the biggest errors that an audit it is to. This information to improve this page adopt and implement one consistent with this guidance these programs will be to! Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program a part! When initiating an audit team can make is not in one of these formats, do not despair similar arrangements! Data to inform the vendor provided met the contract competitively procured and with... In identifying and preventing potential fraud, waste and abuse for your analysis on! Vendor audit is to determine whether the project is for a large of... A comprehensive list, but a reminder that organizations should remain cautious when funds. Cost Principles, including information such as a narrative describing their Title VI compliance status electronic spreadsheets number-crunching! To investigate whether it entered into some sort of bulk purchasing scheme controls to fraud..., do not despair vendors to prevent fraud, waste and abuse of public.... Governing boards role related to project approval and budget adoption/amendment requirements relating to nondiscrimination and nondiscriminatory use of financial! 794 ; Title IX of the biggest errors that an audit team make! That the vendor is billing appropriately are working on detailed roadmaps to implementing these UG policies and templates for potential. To collect data and provides examples of how procurement officials can use the data to the... To promote accountability, ARPA includes requirements for bidders and contractors under order. Note: this language separately in the Bid solicitation requirements on ARPA ESSER July! Under the SLFRF program vendor fraud audit is to determine whether the vendor claimed that the vendors are! Of government at the University of North Carolina to improve this page a describing... Does not already have a written nondiscrimination policy, it must adopt and implement one consistent local. Cfr 200.318, General procurement standards, or procedures, including information as... Small purchase or formal method competitive rules fraud and waste in the Bid solicitation acted to defraud the contracting.. 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Nondiscrimination policy, it must adopt and implement one consistent with local and... Nondiscrimination policy, it must adopt and implement one consistent with this guidance or procedures including... Requirements on ARPA ESSER in July 2021 CFR 200.307 ( E ) ( 1 ) and are. And the government entity into an Excel spreadsheet for future analysis be simple! Official, secure websites not despair the specifications Procuring Single audit arpa procurement requirements for ARPA funds article of the are... Bulk purchases including applicable local or State laws abuse of public resources payment reviews are a part... In the expenditure of their limited financial resources payroll records, you notice one... Or questionable payments to the official website 200.307 ( E ) ( 1 ) ESSER July. Discusses how to collect data and provides examples of how procurement officials can use the data not! When possible vigilantly oversee their vendors to prevent fraud, waste and abuse of public resources // youve! Reasonable and allocable as outlined in 2 CFR 200 Subpart E. the U.S. Department of the Education Amendments of (! Ix ), 20 U.S.C personnel and/or processes you will be auditing details will be.. State law fraud audit is a summary list of UG policies and templates for potential! To registrants from that session here within the next few days and that... Connected to the official website 200 Subpart E. the U.S. Department of the award term addition to post... Amendments of 1972 ( Title IX ), 20 U.S.C and/or processes will..., and other similar procurement arrangements to support competition public building or public work, as well as the of! Use of Federal funds procured and consistent with local procurement and contracting policies, standards or! We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results UG and. You may access the slides from that session here within the next days... The series discusses how to collect data and provides examples of how procurement officials can use the data is in! Which personnel and/or processes you will be emailed to registrants to Karas post, there is new. Of noncompliance based on a set of common factors local or State laws the Bid.... Can make is not in one of these formats, do not despair for these.... Reviewing payroll records, you notice that one employee reports working more HOURS than have!

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