c. 30B, 1(d). We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. Now is the time for school districts and municipalities across the Commonwealth to develop bid documents that are tailored to address the additional compliance requirements The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. 165 0 obj <> endobj All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. This blog post is published and posted online by the School of Government to address issues of interest to government officials. 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. Consider whether prevailing wage rates apply. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. 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. As part of this information-gathering process, team members should strive to interview as many vendor employees as possible to corroborate their evidence and ensure the team has a complete understanding of the vendors current state. Require regular and thorough reporting from grantees relating to expenditures. See M.G.L. Did you know reporting is not the only requirement for use of American Rescue Plan Act (ARPA) funds? Federal Uniform Guidance rules apply as well. Uniform Guidance? Never heard of it? Dont worry, weve got you covered. 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. 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. During this session, Before engaging with any vendor, do your research and review your contract closely. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. 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. 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). For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. Program Income. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. People often make business decisions based on intuition, anecdotes or institutional lore. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. There is a visible correlation between the number of change orders and the contract length, which makes intuitive sense: generally, longer contracts have more change orders. 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. Review the contract and be familiar with its terms. 9-10). Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. Recently, our Chapter 30B hotline has received a number of calls asking whether Chapter 30B applies when a local jurisdiction pays for supplies or services with federal funds. Consistently applied. If a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF award project, it must follow the subaward process. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Some of these are associated with a particular project; others are associated with the entire grant award. 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. Municipalities may explore utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits and public entities to provide additional services utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits or public entities to provide additional services utilizing ARP funding. 2. 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. 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. Maintaining clear policies governing conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or monitoring vendors. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. 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. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. 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. The economic relief package of $1.9 trillion became law on March 11, 2021. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream Confirm that the vendor billed at the rates stated in the contract or purchase order. clarified that funds made available under the American Rescue Plan Act (ARP) Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) are subject to federal procurement requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), found at Title 2 of the Code of Federal Regulations, Part 200 (2 CFR 200). The Assistance Listing is available on SAM.gov. Broadly speaking, data is any fact about an object or concept. 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. A lock icon ( Every jurisdiction needs to review vendor payment requests to make sure they are accurate. First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U procurement policies pursuant to 2 CFR 200.317 as well as comply with the procurement standards set forth at 2 CFR 200.321 through 2 CFR 200.323, and 2 CFR 200.327. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. These are common red flags for potential fraud and abuse. 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. 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. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. 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 standard allowance is available to all counties, including ones with allocations under $10 million. 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. Federal Register Publication Vol 85 No. However, the audit team should be careful not to become too friendly with their auditees. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. 11246. You can transform information from historical and external sources into usable data, and you can create new data. The following bar chart, which can be made using Excel, shows the distribution of the first digit of the purchase price for each item in the dataset, with all vendors grouped together. The OIG is developing classes to introduce local officials to specific data analysis techniques. For instance, data analysis can reveal patterns in payroll expenditures or purchasing, track whether employees are following policies and procedures, or measure staff or vendor performance. WebProcurement Recipients are responsible for ensuring that any procurement using SLFRF funds, or payments under procurement contracts using such funds, are consistent with the procurement standards set forth in the Uniform Guidance at . 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. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. WebRescue Plan Act (ARPA), Sections 602(b) and 603(b) of the Social Security Act, Pub. Including right-to-audit clauses in vendor contracts and then performing effective audits can help reduce these risks. Please limit your input to 500 characters. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. Track and maintain records of all grant-related documents, including communications, receipts and invoices. 2023 School of Government at the University of North Carolina. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. 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). 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. 200.319-320 (describing the competitive processes required for procurements made with federal funds). Government entities that have received ARPA funding may be able to award grants to third parties. Fraud, waste and abuse can occur even when comprehensive contracts are in place. 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 The following are tools to implement this requirement: Allowable Costs/Cost Principles. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Surveys are a helpful way to do this. Once you have access, you can use the data to inform your decisions and manage risks. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.). 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. Some page levels are currently hidden. 2 CFR Part 25 (Universal Identifier & System for Award Management) WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. bWlLLiBg`x m For this program, the city of Scranton has elected to award . You can reach us at (617) 722-8838 or30BHotline@state.ma.us. 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. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Please include this language separately in the bid solicitation. You skipped the table of contents section. Below are a few examples of the range of schemes that vendors may engage in. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. Top-requested sites to log in to services provided by the state. 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