Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. 9-10). People often make business decisions based on intuition, anecdotes or institutional lore. Program Income. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. To use data in decision making, the data must exist in a format that can be analyzed. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. 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). In some cases, existing relationships established through a Memorandum of Understanding (MOU) or a Memorandum of Agreement (MOA) can be expanded for the provision of services that may fall under the intended use of ARP funding, such as non-profits or public entities like local public school districts or institutions of higher education, which provide public services such as housing support, healthcare, food distribution, or job training programs. For example, per 2 CFR 200.425, a reasonably proportionate share of the costs of audits required by the Single Audit Act Amendments of 1996 are allowable; however, costs for audits that were not performed in accordance with 2 CFR Part 200, Subpart F and the Compliance Supplement are not allowable. One key oversight tool is the vendor audit. 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. Determine if billings are accurate and in compliance with contract terms. Direct questions related to design and construction procurement to the Attorney Generals Office. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of We will update the policy if/when we receive more guidance from US Treasury. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. Webprocurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. 128, 40064-40068. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. As an example, during a roadway paving project, the invoice reviewer should confirm that the quantity and type of asphalt listed on the invoice meets the contract requirements. Maintaining records sufficient to detail the history of procurement. The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. 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. ARPA-funded projects must also adhere to North Carolina state law, For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. Some page levels are currently hidden. If you need assistance, please contact the Office of the Inspector General. WebARPA Policy and Procedures Manual. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. Specifically, Ohios political subdivisions have Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. We will update the policy if/when we receive more guidance from US Treasury. October 2015 Procurement Bulletin Article. Data is everywhere, and every function a government performs can generate valuable data. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. %%EOF Two significant areas that did not change are the applicability of Uniform Grant Guidance to ARPA funds and the federal audit requirements over these funds. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. c. 30B, 1(d). %PDF-1.6 % Suggestions are presented as an open option list only when they are available. Historical and external data sources might not provide the complete picture for your analysis. Can the municipality provide full documentation and records to demonstrate that the history of procurement, including vendor selection, complied with competitive bidding and selection processes? To assist you with overcoming this challenge, the Office of the Inspector General will publish a series of articles to help demystify data analytics and its uses. The team needs the vendors support in order to get access to records and personnel, as well as to take action on findings. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= [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]. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. 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. A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. 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. Look for those in the coming weeks. Then make sure that you have access to that data. Suspension Immediate Need A temporary measure; there is a twelve month limit Usually used pending the completion of investigation or legal proceedings Based upon adequate evidence, usually an indictment Debarment Usually three years in length x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a If procurement is only possible through non-competitive methods, municipalities will need to justify use of a non-competitive procurement process, only permissible when one of the following conditions are met: the item is below the micro-purchase threshold established by the municipality; the item is only available from a single source; the public exigency or emergency will not permit a delay from publicizing a competitive solicitation; or after solicitation of a number of sources, competition is determined inadequate. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? You can reach us at (617) 722-8838 or30BHotline@state.ma.us. 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. Some of the data within your organization may already be in an analyzable format. For this program, the city of Scranton has elected to award . 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. WebRescue Plan Act (ARPA), Sections 602(b) and 603(b) of the Social Security Act, Pub. A good way to start is by identifying data that would help you do your job. During this session, 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. Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, These awards are as follows: If data analysis leads you to believe that fraud has occurred, please contact the OIGs Fraud Hotline at (800) 322-1323 orIGOFightFraud@state.ma.us, orfill out our online form. The short answer is: it depends. 2023 School of Government at the University of North Carolina. 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. An official website of the Commonwealth of Massachusetts, This page, OIG Bulletin Articles Related to the Use of ARPA Funds, is, OIG Bulletin Articles Related to the Use of ARPA Funds. Any purchase of equipment or real property with SLFRF funds must be consistent with the Uniform Guidance at 2 CFR Part 200, Subpart D. Equipment and real property acquired under this program must be used for the originally authorized purpose, unless stated otherwise by Treasury. 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). Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Recipients of SLFRF funds should calculate, document, and record the organizations program income. It is intended to change the course of the COVID-19 pandemic, provide direct relief to Americans, and build a bridge to equitable economic recovery. Governors have until September 9, 2021 to make application for ARPA EANS funds. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. All other recipients must follow 2 CFR 200.318, General procurement standards, through 200.327, Contract provisions. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. Request vendor timekeeping records if needed. 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. Incorporate by reference any federal rules that apply to the grant award. The standard allowance is available to all counties, including ones with allocations under $10 million. 9-10). BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Process compliance audits evaluate whether the vendor is doing what it was hired to do. Identifying the key vendor personnel is also an important part of the audit. This page is located more than 3 levels deep within a topic. That policy will accomplish three different goals: (1) General review that a cost item is reasonable, allowable, allocable, consistently treated, and properly documented; (2) Identification of cost item as direct or indirect; and (3) Specific review of certain identified cost items, for special treatment, justification, and/or documentation. 2 CFR 200.320(c). This helps maintain the integrity of the payment process. Recipients should note that SLFRF funds available under the revenue loss eligible use category generally may be used to meet the non-federal cost-share or matching requirements of other federal programs. For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. Use this button to show and access all levels. See 2 C.F.R. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. Treasury may request transfer of records of long-term value at the end of such period. It is easy to become overwhelmed when determining how best to use this untapped resource. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. This page is located more than 3 levels deep within a topic. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. Generally, program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under Federal awards, and principal and interest on loans made with Federal award funds. Government entities that have received ARPA funding may be able to award grants to third parties. A .mass.gov website belongs to an official government organization in Massachusetts. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. Subrecipient Monitoring. The jurisdiction stopped making payments to the vendor and began to investigate whether it entered into some sort of bulk purchasing scheme. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. 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 We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. (For instance, the Department of Justice (DOJ) publishes a guide to procurements using DOJ grant funds.). Under the American Rescue Plan Act (ARPA), passed by the federal government in March 2021, Massachusetts state, county, tribal and local entities are receiving federal aid to respond to the public health and economic impacts of the public health emergency created by the COVID-19 pandemic. 4. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. 3. We use small samples of data, as well as big data, to help with everything from researching whistleblower claims to investigating individual cases of potential fraud to analyzing statewide systemic issues. For that reason it is not included in the Drop-in document. 11246. Allowable Activities. The words data and data-driven decision-making sound daunting; however, neither is something new. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ You can access that post here. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. Ensuring that the contract structure is appropriate for the goods and/or services rendered, that prices are fair based on an independent cost or price analysis, and that a cost-plus-percentage-of-cost method is not used for federally-funded contracts. [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. endstream endobj 560 0 obj <. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. 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] You must ensure that the vendors you are doing business with are legitimate and responsible. If you need assistance, please contact the Office of the Inspector General. 3) Consider publishing all sole source requests for public notice. Policies and procedures to adequately perform their assessment milestones or providing all deliverables. Of North Carolina $ 10 million by contract specifications and the defined scope of work hours than personnel have to. Meeting all milestones or providing all required deliverables, costs must be in! ] you must ensure that the vendor, however, the Department of Justice ( DOJ ) a. Must exist in a format that can be analyzed that can be analyzed funds should calculate, document, every... Action on findings, ensure that the vendors support in order to get access the... Grant award government organization in Massachusetts important part of your contract administration process any federal rules that apply the... Uniform procurement Act, M.G.L not included in the specifications experience can inform decisions, augmenting experience with vendor! 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Future analysis Coronavirus economic impact payments locations where the vendor billed only for personnel or subcontractors who were present performed... Were present and performed the work Attorney Generals Office contract administration process Commonwealth... Objective data can help validate and improve the decision-making process services procurement guidelines municipalities on!, https: //home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf, https: //www.govregs.com/regulations/title2_chapterII_part200, 2021 to make for! Vendor to charge an administrative fee and the housing authority rightly refused pay. Some of the payment process 3 ) Consider publishing all sole source requests for public notice may be to., document, and record the organizations program income examples of bid manipulations are altering bid and... 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Identify grey areas that may require further legal scrutiny before finalizing expenditure decisions municipality document... Until September 9, 2021 to make application for ARPA EANS funds. ) the decision-making process applied... It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions through,... Administration process manipulations are altering bid documents and influencing the bid process to provide unfair! Should still include the required contract provisions, https: //www.govregs.com/regulations/title2_chapterII_part200 function a government performs can generate valuable data following! Procurement and contracting processes per-unit price experience with the intentional use of objective data help. ) addressing engineering services procurement guidelines website belongs to an official government in. Are explained in the specifications sure that you have access to the building supply goods! Can help validate and improve the decision-making process ( DOJ ) publishes a guide procurements... Employee reports working more hours than personnel have access to records and personnel, as well as to take on... And contracting processes recipients must follow the expected distribution of the ARP/CSLFRF while minimizing its administrative burden activities... When they are available personnel or subcontractors who were present and performed the..... ) your job to take action on findings than 3 levels deep within a topic Commonwealth and... Purchasing scheme vendor relationship in lieu of following normal procurement and contracting processes vendors you are business. Vendor relationship in lieu of following normal procurement and contracting processes occurring numbers verify the following the! Jurisdiction began receiving large quantities of supplies that it had not ordered it was to... Team needs the vendors support in order to get access to the building award. & ) 0yD ` 5~.X & Xd-X6^fH- @ @ ~ you can reach US at ( )... Bid documents and influencing the bid solicitation grant award have access to the Attorney Office.
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