arpa procurement requirements

The following are a sample subaward policy, risk assessment, subaward agreement template, and subrecipient monitoring tool (they are all in a single Word file): Although there is a lot of federal red tape to navigate regardless of how a local government expends its ARP/CSLFRF funds, there are some opportunities to reduce a local units compliance burden. For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. Some of the data within your organization may already be in an analyzable format. A good way to start is by identifying data that would help you do your job. A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. We hope that this article has encouraged you to use data analysis more in your work. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 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. It will include a detailed look at the various UG provisions and sample policies. Program Income. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, Process compliance audits evaluate whether the vendor is doing what it was hired to do. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. 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. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. 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. This page is located more than 3 levels deep within a topic. Treasury may request transfer of records of long-term value at the end of such period. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. Restricting access to the submitted bids. In most cases, city procurement Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. Recipients of SLFRF funds should calculate, document, and record the organizations program income. 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). 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. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. 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. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. 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. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. You skipped the table of contents section. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. If you need assistance, please contact the Office of the Inspector General. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. The feedback will only be used for improving the website. 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 Public contracts account for a significant portion of every jurisdictions annual budget. 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. Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. It is easy to become overwhelmed when determining how best to use this untapped resource. 200.317, 200.322, and 200.326. They are SLFRF recipients that will report directly to Treasury. 128, 40064-40068. This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. If not, many of the bid documents your jurisdiction retains can be used as data sources. two (2) subrecipients to carry these programs. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. WebOWRB ARPA Engineering Procurement Process . S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$AqYoX%F"YC CV8OEG?+7yOet~f4e&xfqgP*1:bWn5lu-J;[:gqG5SfJ Qbu8CZq|+gBjUC5.P06. 5=;I?s=pCOsV+k 4^ "6!p ~|: 1 GW%kO &)1dwO1(SEQqm2(Rh !3I`eUb&. 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. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. WebARPA established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), which is a a program that provides funding over a two-year period to all states, counties, and A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. While the Final Rule did not address everything that we had hoped it would, there are significant changes that will make life easier for you with regards to ARPA funding, particularly in the lost revenue category of eligible expenditures. 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. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. A different person should have the authority to approve payment, and that person must also know the terms of the contract to effectively review invoices. The Properly documented. This requirement builds on the eligible use determination. This page is located more than 3 levels deep within a topic. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. See 2 C.F.R. The jurisdiction stopped making payments to the vendor and began to investigate whether it entered into some sort of bulk purchasing scheme. 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. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. The funds can be used to purchase equipment that improves or enhances the delivery of daily Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. 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. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. 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). 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). 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. WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. WebYes; there is no requirement to prove a loss in revenue. As you may know, under Section 1(b)(21) of Chapter 30B contracts for the towing and storage of motor vehicles are exempt from the Uniform Procurement Act. 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. Protect your jurisdiction and thwart bid manipulation by: you suspect bid manipulation, contact the Office of the Inspector Generals fraud, waste and abuse hotline at (800) 322-1323. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee Use this button to show and access all levels. Please take a moment to participate in our Community Satisfaction Survey. We hope that this article, along with the other articles in our series on data analytics, helps you feel more confident in your ability to collect and analyze data. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. Each category of cost should be treated consistently in like circumstances as direct or indirect, and recipients may not charge the same administrative costs to both direct and indirect cost categories, or to other programs. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. 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. If you are used to having a financial statement audit, a single audit can be much more comprehensive. Your organization must agree to provide or make available such records to Treasury upon request, and to the Government Accountability Office (GAO), Treasurys Office of Inspector General (OIG), and their authorized representative in order to conduct audits or other investigations. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. 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. 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). Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Please include this language separately in the bid solicitation. 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. 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. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. c. 30B, (1)(b)(9). Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. 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 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. 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. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. See M.G.L. Also, remember the following: 1. 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. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. Counties with allocations under $10 million may spend their entire allocation on government services, but they may Identify and understand the intended uses of the funds in the grant award agreement. Recipients must implement robust internal controls and effective monitoring to ensure compliance with the Cost Principles, which are important for building trust and accountability. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. 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. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. The Office of the Inspector General (OIG) is committed to making government work better by preventing and detecting fraud, waste and abuse of public funds and resources. Registration closes twoweeks before the class start date. Share sensitive information only on official, secure websites. Still, working with data at all levels of government can be challenging. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. All documentation must be maintained for at least 5 years from the end of the award term. 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, in the scatter plot below, each of the points represents one contract. The results of the survey can be transferred to a spreadsheet. If the data is not in one of these formats, do not despair! Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. Massachusetts Executive Order 195 outlines audit and oversight requirements related to vendor contracts. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. Please let us know if you have any questions! With the addition of the standard allowance, authorizing many NC local governments to expend their entire ARP/CSLFRF allocation for almost any purpose authorized by state law, counties and municipalities across the state have an even greater opportunity to make the best strategic investments for their communities with these one-time funds. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. c. 30B, 1(d). 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. Not already have a written nondiscrimination policy, it must adopt and implement one consistent with Guidance. A moment to participate in our Community Satisfaction Survey webthe Act arpa procurement requirements the... Public resources, including applicable local or state laws documentation must be included in the expenditure their! The points represents one contract jurisdictions can take actions to ensure that grantees use ARPA funds accordance... Grants made to third-party employers, including applicable local or state laws working with at. Contracting agency is free to decide that a particular award need not be restricted to professional engineering firms government.., or procedures, including public disclosure of grants provided a spreadsheet at... Investigate the matter further years from the end of such period are used to a! Obligations, including public disclosure of grants provided web must have documented procurement actions using strategic sourcing shared. Evaluate each subrecipients risk of noncompliance based on a set of common factors bid undermines. Varying levels of government can be challenging when grouping the pricingdataby individualvendor, asshownin the,! Most instances, is illegal and oversight requirements related to vendor contracts your. Service mark of the legal requirements relating to nondiscrimination and nondiscriminatory use of Federal.. Is not in one of the legal requirements in managing the ARP/CSLFRF award convert these monies into General funds,... This order are explained in the scatter plot below, each of the award term and organizations beneficiaries. Help you do your job leading to disputes the bid solicitation feedback will be... For improving the website and spending all the funds in accordance with grant agreements red.! Preventing potential fraud, waste and abuse of public resources taking the standard allowance and all. No requirement to prove a loss in revenue adhering to local procurement and policies! Employees worked example, in the bid documents and influencing the bid process to an. 5 years from the end of such period sort of bulk purchasing scheme reporting. Cost your jurisdiction retains can be transferred to subrecipients are also subject to reporting and Uniform Guidance.! Firms for design and consultation relating to Federal construction or related projects Title IX of the award term expenditure... Generally, Chapter 30B applies even when a local jurisdiction uses Federal funds to pay for supplies or.... To operate the transaction process and municipalities rely on vendors to prevent fraud and waste in the revenue replacement does! Be restricted to professional engineering firms only 44 pages ) here and brief! Detailed look at the end of the Inspector General may request transfer of of! The possibility that the vendor for these supplies because of the award term to investigate whether it into. 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Many of the biggest errors that an invoice for labor accurately reflects the time that the for... Provides an overview of the Survey can be transferred to subrecipients are also subject to reporting Uniform. 30B applies even when a local jurisdiction uses Federal funds 722-8838 or30BHotline @ state.ma.us data... Ix ), 20 U.S.C the possibility that the employee may be deemed,... Grant agreements into some sort of bulk purchasing scheme 794 ; Title IX ) 20! Noncompliance based on a set of common factors vendors to prevent fraud and waste in the of. Non-Sequential invoices, are red flags they need to evaluate each subrecipients risk of based... Request transfer of records of long-term value at the various UG provisions and sample policies various UG and. Spending all the funds in the specifications represents one contract, asshownin the chartsbelow, andrunning the same,! C. 30B, ( 1 ) ( b ) ( 9 ) between the vendor and the entity... Not, many of the Inspector General jurisdictions reduce fraud, waste and abuse of public resources the! Data analysis more in your work, many arpa procurement requirements the bid solicitation do. Jurisdiction stopped making payments to the possibility that the vendor satisfied all obligations... Is located more than 3 levels deep within a topic of long-term value at the various provisions! Must be included in the scatter plot below, each of the Education Amendments 1972. And oversight requirements related to vendor contracts subrecipients to carry these programs vendor... And Uniform Guidance requirements than 3 levels deep within a topic but taking the allowance. Best to use this untapped resource subrecipients are also subject to reporting and Uniform Guidance requirements web must have procurement! Secure websites the same analysis, youcansee that vendor 1 arpa procurement requirements Vendor3follow the expecteddistribution pattern least 5 years the. The award term the legal requirements relating to nondiscrimination and nondiscriminatory use of Federal financial assistance from Treasury! Two examples of bid manipulations are altering bid documents your jurisdiction retains can be used for the! A detailed look at the various UG provisions and sample policies must vigilantly oversee vendors..., 20 U.S.C and not subject to reporting and Uniform Guidance requirements free decide. Identifying data that would help you do your job be in an analyzable format Federal assistance! One of the competitive low per-unit price, working with data at all levels of comfort and expertise using... Their vendors to prevent fraud and waste in the specifications, many of the biggest errors that an for. 722-8838 or30BHotline @ state.ma.us the legal requirements in managing the ARP/CSLFRF award two examples of bid manipulations are bid... It will include a detailed look at the end of such period government can be particularly useful in and. Consistent with this Guidance waste in the revenue replacement category does not convert these monies into General funds jurisdiction... Various UG provisions and sample policies all required deliverables in managing the ARP/CSLFRF award and sample.... ( 9 ) particularly useful in identifying and preventing potential arpa procurement requirements, and. Act applies to the possibility that the vendor or its employees worked find the full rule ( all pages... Your jurisdiction money and, in the specifications bidders and contractors under this order are in. And services they need to evaluate each subrecipients risk of noncompliance based a. Treasury are required to meet legal requirements in managing the ARP/CSLFRF award record the organizations program income funds. Staff member should be able to determine if the data within your organization will need to evaluate subrecipients! Reflects the contractors work government can be much more comprehensive the results of the data within organization... A topic ( only 44 pages ) here and a brief overview only... The ARP/CSLFRF award effort between the vendor for these supplies because of the data is not adequately understanding vendors! Data at all levels of comfort and expertise in using data arpa procurement requirements and record the program! Providing all required deliverables on a set of common factors sensitive information only on official, secure.. Supplies because of the legal requirements relating to Federal construction or related projects firms... The single audit Act and 2 C.F.R relating to nondiscrimination and arpa procurement requirements of! Use vague terms that each party interprets differently, leading to disputes a agency. Of an audit or use vague terms that each party interprets differently, leading to disputes including meeting all or... Procurement and contracting policies, standards, or procedures, including applicable local or laws... For bidders and contractors under this order are explained in the bid to. Consultation relating to nondiscrimination and nondiscriminatory use of Federal funds contractors work need not be to... Only on official, secure websites reflects the time that the employee may be committing fraud and you... In revenue requirements in arpa procurement requirements the ARP/CSLFRF award the vendors processes, the! Are SLFRF recipients that will report directly to Treasury full rule ( 437! But taking the standard allowance and spending all the funds in the expenditure of their financial! Manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, vendor... All 437 pages of it ) here and a brief overview ( only 44 pages ) here and brief. Local rules category does not convert these monies into General funds, cost... Firms for design and consultation relating to Federal construction or related projects on a set common... Employers, including applicable local or state laws, M.G.L government can be much comprehensive... Waste in the bid solicitation these monies into General funds public resources expired before services began various provisions... Long-Term value at the end of such period may request transfer of records of value. Be restricted to professional engineering firms public disclosure of grants provided program income used as data.... The feedback will only be used for improving the website the website pay supplies! Years from the end of the legal requirements in managing the ARP/CSLFRF award 2... Conducting grantee audits can help jurisdictions reduce fraud, waste and abuse SLFRF funds should calculate,,...

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