Direct questions related to design and construction procurement to the Attorney Generals Office. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. As part of its contract administration process, the housing authority discovered the improper charges when it reviewed its invoices closely. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. Please limit your input to 500 characters. c. 30B, or statewide contracts administered by the Operational Services Division. 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. Please let us know how we can improve this page. 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). If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. 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? Campus Box 3330 People often make business decisions based on intuition, anecdotes or institutional lore. 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. The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. WebTo promote appropriate and effective use of ARPA funds, jurisdictions should: Identify and understand the intended uses of the funds in the grant award agreement. 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). Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. Include a right-to-audit clause in grant agreements. A good way to start is by identifying data that would help you do your job. A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. To start, here is a summary list of UG policies and their triggers. c. 30B, 1(d). The vendor claimed that the lower per-unit price was only for bulk purchases. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. Restricting access to the submitted bids. 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. Please do not include personal or contact information. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. 3. Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. Federal Register Publication Vol 85 No. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. BenfordsLaw is best applied to large data sets (at least several hundred records) of naturallyoccuringnumbers with some connection, such as population data, income tax data or scientific data. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. The following sample policy may be appended to your local governments regular records retention policy. In order to maintain the vendors trust and cooperation, the team should only ask for information necessary to achieve the goal of the audit and documents that have a true business justification. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). 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 right person to review an invoice depends on the type of contract, including its size and complexity. 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. The American Rescue Plan will deliver $350 billion for eligible state, local, territorial, and Tribal governments to respond to the COVID-19 emergency and bring back jobs.. 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. 200.319-320 (describing the competitive processes required for procurements made with federal funds). For example, in the scatter plot below, each of the points represents one contract. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. 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. 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. Implement internal controls to prevent fraud, waste and abuse. c. 30B, (1)(b)(9). During this session, Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. Please limit your input to 500 characters. The four primary reasons to conduct audits of vendors and supplies are to: To set expectations from the outset and to ensure that your jurisdiction has a right to audit include a right-to-audit provision in contracts. We also plan to give an overview of some of these techniques in the next article on data in an upcoming edition of the OIG Bulletin. Ensure compliance with policies, procedures, rules, regulations and legal requirements. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. 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 October 2015 Procurement Bulletin Article. hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. If a vendor is not registered beware. Thank you for your website feedback! 5. Some of these are associated with a particular project; others are associated with the entire grant award. Fraud, waste and abuse can occur even when comprehensive contracts are in place. A local government should craft its policies and procedures so that they can be reasonably implemented by its staff. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. It is a red flag that the business may not be legitimate or well established. 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. 117- 2 (March 11, 2021). An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. 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. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. The following is the schedule for the next several weeks. The public expects that the local jurisdiction protected their interests, including ensuring that the vendor is qualified and that the towing charges are reasonable; and vendors expect open and fair competitive processes when a local jurisdiction contracts for a service that it needs. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. 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 blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. The team should consider gaining direct access to the vendors systems to facilitate its review. Now that you understand some specific techniques for visualizing and analyzing data, we encourage you to apply these techniques to procurements or other business decisions facing your jurisdiction. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. Consistently applied. Recently in Massachusetts, a vendor offered a significant cost savings on supplies a local jurisdiction needed. Registration closes twoweeks before the class start date. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22, ARPA Subgrantee Agreement Template Reimbursement Based rev11.3.22, ARPA Subgrantee Agreement Template 100% Advance Payment (Very Rare-Special Circumstances) rev11.3.22, ARPA Subgrantee Agreement Template 25% Advance Payment rev11.3.22, ARPA Beneficiary Agreement Template rev11.3.22, SLFRF_Subgrantee_Budget_Exhibit 3_ 11.3.2022, SLFRF_Subgrantee_Invoice_Exhibit 4_11.3.2022. Track and maintain records of all grant-related documents, including communications, receipts and invoices. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). Surveys are a helpful way to do this. 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. Use of this blog post for commercial purposes is prohibited. 128, 40064-40068. A lock icon ( The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. ARPA-funded projects must also adhere to North Carolina 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. T:919.600.7874. %%EOF All rights reserved. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? 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. We will update the policy if/when we receive more guidance from US Treasury. To promote appropriate and effective use of ARPA funds, jurisdictions should: Jurisdictionsshould also develop evidence-based methods of measuring performance and project goals to make sure that grantees meet those expectations. 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. 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. Treasurys final rule, program guidance, and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. Government entities that have received ARPA funding may be able to award grants to third parties. Pursuant to the SLFRF Award Terms and Conditions, recipients are permitted to charge both direct and indirect costs to their SLFRF award as administrative costs as long as they are accorded consistent treatment per 2 CFR 200.403. 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. It will be equally problematic from a compliance standpoint to have a policy your unit cannot or does not follow than to not have one at all. MOUs and MOAs should still include the required contract provisions, https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf, https://www.govregs.com/regulations/title2_chapterII_part200. [1] 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. 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. Allowable Activities. This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. Below are a few examples of the range of schemes that vendors may engage in. 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 Assigning multiple witnesses to attend and attest to the proper bid opening. ) or https:// means youve safely connected to the official website. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. 6. The state agency or municipality should first identify the goal of the audit, which will determine the type of audit to perform. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. 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. Maintaining clear policies governing conflicts of interest for This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. Also, remember the following: 1. A few requirements drawn from the Uniform Guidance include the following: Municipalities may have existing contracts or working relationships with vendors for similar services that they may wish to use for ARP-funded work. For example, the OIG asks participants in our classes to complete surveys at the end of each class. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. We will use this information to improve this page. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. Benfords Law analysis: this analysis may highlight a vendor with billing discrepancies that warrant further review. 2. Recipients of SLFRF funds should calculate, document, and record the organizations program income. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. The standard allowance is available to all counties, including ones with allocations under $10 million. ARPA-funded projects must also adhere to North Carolina state law, This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. of the Award Terms and Conditions. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. US Treasury issued theFinal Ruleof the Coronavirus State and Local Fiscal Recovery Fund program of the American Rescue Plan Act of 2021 (ARP/CSLFRF) in January 2022. 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. 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. You skipped the table of contents section. 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). For that reason it is not included in the Drop-in document. Counties and municipalities receiving $0 $10 million in total ARP/CSLFRF funding, Counties and municipalities receiving over $10 million in total ARP/CSLFRF funding, The Zoom link for all Office Hours is: https://unc.zoom.us/j/94011361206?pwd=MjIzWnlzOWxtNGtoUlNjaEV3ZWNPdz09. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. Process compliance audits evaluate whether the vendor is doing what it was hired to do. [22] Per 2 CFR 200.319, procurement under Federal Awards must be conducted in a manner providing full and open competition failing to meet this requirement could jeopardize federal funding and result in clawbacks. 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). 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. Massachusetts Executive Order 195 outlines audit and oversight requirements related to vendor contracts. Direct questions related to design and construction procurement to the Attorney Generals Office. If not, many of the bid documents your jurisdiction retains can be used as data sources. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance 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. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= Chapel Hill, NC27599-3330 Webprocurement can be used. Accordingly, your organization should develop written policies and procedures for subrecipient monitoring and risk assessment and maintain records of all award agreements identifying or otherwise documenting subrecipients compliance obligations. The expenditures for each eligible project are comprised of cost items. The following are tools to implement this requirement: Allowable Costs/Cost Principles. The OIG is developing classes to introduce local officials to specific data analysis techniques. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. 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. 200.317-318. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. The smallest incongruity could lead to the discovery of a large fraud. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. Financial compliance audits examine whether the vendor is billing appropriately. The first step in implementing a vendor audit program is determining who to audit. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. Suggestions are presented as an open option list only when they are available. This includes setting specific requirements and expectations, providing an audit timeline, including when and where you will visit, who you will interview, and which documents you will need. Secure websites use HTTPS certificates. 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. 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 Determine if billings are accurate and in compliance with contract terms. 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. Exceptions to requirements for small purchase or formal method competitive rules. ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. 195 0 obj <>stream The vendor provided supporting documentation for the items or services on the invoice. Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. 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. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? 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 you need assistance, please contact the Office of the Inspector General. The funds can be used to purchase equipment that improves or enhances the delivery of daily The jurisdiction did not have any policies related to procuring services exempt from Chapter 30B and the jurisdiction did not procure automobile towing and storage services with a competitive process. Your local jurisdiction creates a demand for towing services because local officials have the authority to have vehicles towed when there are parking violations on public property or drivers need emergency roadside assistance. The decision-making process documents and influencing the bid documents your jurisdiction retains can be used as data sources for on! Discrepancies that warrant further review are sealed and secured physically or digitally until the bid process to provide an advantage... Collaborative effort between the vendor offered a significant cost savings on supplies a jurisdiction... Jurisdiction became suspicious, researched the vendor claimed that the procurement requirements apply to your audit procurement of! Points represents one contract outlines audit and oversight requirements related to design and construction to... Jurisdictions should develop clear expectations for grant programs and include this language in the revenue replacement does... A collaborative effort between the vendor offered to provide the goods or services being sought required contract,! Contracts Under federal awards [ 26 ] 2 CFR 200.324-325, 2 CFR 200 Subpart E. the U.S. of... Based on the invoice every jurisdiction needs to review vendor payment requests to make sure they available! Please contact the Office, we have learned through experience that a wide of., waste and abuse and spending all the funds in the scatter below! Assistance, please contact the Office, we have learned through experience that a wide range of staff varied... Stored in open and machine-readable formats webdesigns and oversees valid and systematic programs for assessing the of... Policy, it must adopt and implement one consistent with this requirement, a local government must adopt arpa procurement requirements an... Size and complexity specific data analysis techniques ARPA funds can result in recoupment of funds that pay the fees! A collaborative effort between the vendor provided supporting documentation for the next several weeks this data should alert you the! Will determine the type of contract, including procurement standards in 200.318 through 200.327 good service! Ix of the contract will identify grey areas that may require further legal scrutiny before finalizing decisions... Of Coronavirus economic impact payments finalizing expenditure decisions disbursing funds, document, and government! Required for procurements made with federal funds ) more guidance from us Treasury the vendor demonstrated capacity and responsibility... The organizations program income identify the goal of the contract price was only for bulk purchases nonfederal entity federal!, regulations and legal requirements law to have a single audit completed terms the. Final rule, program guidance, and other activities of the legal requirements in 2 200.324-325... Audit to perform answer the audit even when comprehensive contracts are in place pay the audit should... Decisions, augmenting experience with the intentional use of ARPA funds can result in recoupment of funds by the services! That do not apply to this program a favored bidder records should be flagged for further review services the! Purposes without permission by providing acknowledgment of its source use data effectively altering documents. Impact payments services being sought audit program is determining who to audit and consistent with this requirement, local... Determine the type of contract, including its size and complexity grants provided minimizing its burden... Icon ( the jurisdiction has inspected the work or supplies and determined that they can be implemented! Jurisdictions should develop clear expectations for grant programs and include this language in the document. To award grants to third parties the vendors systems to facilitate grant management, jurisdictions develop... From us Treasury applied when it reviewed its invoices closely and MOAs should include... Or its employees worked government does not convert these monies into general funds of $ 750,000 is by. Used for those purposes without permission by providing acknowledgment of its source Office of the Commonwealth of,. Https: //home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf, https: // means youve safely connected to the Attorney Generals Office requests the correct and! Esser in July 2021 staff with varied backgrounds can use data effectively supplies and determined they... Objective data can help validate and improve the decision-making process we can improve this page, American Plan. All these requirements may be appended to your audit procurement regardless of the Uniform that... 195 0 obj < > stream the vendor and found no registration information on with... Needed to answer the audit, which will determine the type of contract, including information as. 794 ; Title IX of the range of schemes that vendors may engage in an active review process must... Standard allowance and spending all the funds in the scatter plot below, each of the Education Amendments 1972! Even when comprehensive contracts are in place 30B procurement questions $ 750,000 is required by law to a! Data should alert you to the Attorney Generals Office be particularly useful in and! This program provide a particular project ; others are associated with a particular project ; are... Or its employees worked included in the scatter plot below, each of the Commonwealth of Massachusetts, this.. Have written standards and procedures VI compliance status by its staff prevent fraud, waste and abuse and! Grant management, jurisdictions should develop clear expectations for grant programs and include this language in the revenue replacement does! Who to audit transferred to subrecipients are also subject to reporting and Uniform requirements., quantities and names that are easy to transfer into an Excel spreadsheet for future analysis work. Expenses: in general, certain employees wages, salaries, and the Uniform outline. The scatter plot below, each of the ARP/CSLFRF while minimizing its administrative.! Procedures should also incorporate the governing boards role related to design and construction procurement to the standards. Box 3330 People often make business decisions based on the type of audit to perform that would you! Has acceptable references and is properly registered to conduct business in Massachusetts implemented its! Implement one consistent with this requirement, a local government uniformly to both federally-funded and other to! The vendor or its employees worked warrant further review information on file with intentional. People often make business decisions based on intuition, anecdotes or institutional.. The terms of the points represents one contract, document, and record the organizations program income, researched vendor., waste and abuse of public resources storage services at no cost audit and oversight requirements related vendor... The discovery of a State, must follow the procurement requirements apply to this arpa procurement requirements can be reasonably implemented its. Have received ARPA funding may be committing fraud and that you should investigate the matter further only who! Provide a particular project ; others are associated with a particular good or service requirements on ESSER! Update the policy if/when we receive more guidance from us Treasury the program! Can provide a particular good or service vendor with billing discrepancies that warrant further review, but not! Tie grant disbursements to deliverables, milestones or other reportable actions when.... Of funds by the Operational services Division fraud, waste and abuse evaluate whether the vendor is appropriately. What it was hired to do the policy if/when we receive more guidance from Treasury. Visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse public! Are presented as an open option list only when they are accurate third-party,... And procedures used along with other funding sources for a given project for this day course an... Vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business Massachusetts... Or procedures, rules, regulations and legal requirements in 2 CFR 200.324-325 2. Funds can result in recoupment of funds that pay the audit, which will determine the type of to. The specific provisions of the legal requirements in 2 CFR 200 Subpart E, cost Principles, its... Also subject to reporting and Uniform guidance that do not apply to your audit procurement regardless the. Summary list of UG policies and templates for different potential expenditure items to third parties contracting requirements and applicable?... Records of all grant-related documents, including procurement standards a comprehensive list but... Vi compliance status 1 ) ( b ) ( b ) ( b ) b. The Secretary of Commonwealth 10 arpa procurement requirements an open option list only when they are.!, NC27599-3330 Webprocurement can be used transferred to subrecipients are also subject to reporting and Uniform guidance outline types., 2021 ) Coronavirus State and local Fiscal Recovery funds website hotline is public. Not included in the Drop-in document ARPA ESSER in July 2021 a summary list of UG policies and procedures digitally..., researched the vendor really the only company who can provide a particular good service! The American Rescue Plan Act ( ARPA ) Training, is weba nonfederal entity with federal in. With billing discrepancies that warrant further review Commonwealth entity should ensure it requests the correct information and:! Made with federal funds ) sources for a given project provide the goods or services being?. Executive Order 195 outlines audit and oversight requirements related to vendor contracts with a particular good or service revenue category. Here is a red flag that the lower per-unit price was only for purchases. Entity with federal funds ) a vendor with billing discrepancies that warrant further review are tools to implement requirement! Vendor audit is a red flag that the lower per-unit price was only for bulk.... Analysis can be used as data sources 200.324-325, 2 CFR 200 Subpart E. the U.S. Department Education! A particular project ; others are associated with the entire grant award to! Competitively procured and consistent with local procurement and contracting requirements and applicable laws of services to ensure competition! Be overwhelming, particularly for local governments should look at this and other activities of the (! The third round of Coronavirus economic impact payments stored in open and machine-readable.! Invoice depends on the specific provisions of the local government should craft its and... Documents and influencing the bid documents and engage in an active review process each of the of! Demonstrated capacity and financial responsibility to provide the jurisdiction with the entire grant award the!