The Office of the Inspector General often reviews vendor invoices and other documents as part of its duty to prevent and detect fraud, waste and abuse. To use data in decision making, the data must exist in a format that can be analyzed. A .mass.gov website belongs to an official government organization in Massachusetts. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. Civil Rights Compliance. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. endstream endobj 560 0 obj <. This makes bid manipulation more difficult. Direct questions related to design and construction procurement to the Attorney Generals Office. 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. This scope is different than what is included in the current contract and may be considered noncompetitive. Use this button to show and access all levels. 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. WebDepending on the site host organizations procurement requirements, a formal solicitation process may be needed to purchase and install charging infrastructure. To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an Allowable Costs and Cost Principles Policy. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. Determine if billings are accurate and in compliance with contract terms. What is the difference between Suspension and Debarment? [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. Or maybe you used a more sophisticated tool to make that decision for example, the weather app on your phone but in both cases you used data to decide to wear a raincoat. We will use this information to improve this page. ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. One key oversight tool is the vendor audit. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? By regularly monitoring key performance indicators and tying grant payments to measurable standards, jurisdictions can determine which projects are working well and which require additional attention. The audit scope and appropriate approach depend on the type of audit performed. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. Therefore, support from potential stakeholders senior management, the Board of Directors, department decision-makers is important for a successful audit engagement. Exceptions to requirements for small purchase or formal method competitive rules. Recipients must adhere to the following contract administration requirements: Require the recipients prime contractor to pay its subcontractor for satisfactory performance no more than 30 days from the prime contractors receipt of payment from the recipient. 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.. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. Thank you for your website feedback! For that reason it is not included in the Drop-in document. 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. Please limit your input to 500 characters. 2 CFR 200.320(c). Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. Allowable Activities. Please limit your input to 500 characters. 12. This collection does not apply to Tribal governments. Many of our past reports highlight fraudulent or inaccurate vendor billing. Where feasible, municipalities should consider taking steps to ensure competition is accessible to minority- and women-owned businesses in addition to labor surplus area firms. Each of the considerations above, as well as operation and maintenance In most cases, city procurement As an example, the Infrastructure Investment and Jobs Act provides that SLFRF funds may be used to meet the non-federal match requirements of authorized Bureau of Reclamation projects and certain broadband deployment projects. Some page levels are currently hidden. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. 117- 2 (March 11, 2021). It will include a detailed look at the various UG provisions and sample policies. See M.G.L. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. WebThe City of Detroit Office of Contracting and Procurement (OCP) requests proposals from qualified Respondents to provide procurement supportive services including reviewing &creating scopes of work, creating bid solicitations, contract development, contract negotiations and preparation of critical See more Buyers Requirements Right-to-audit clauses should be specific, yet not overly restrictive, to allow the procuring entity the ability to interview key vendor personnel and review applicable documentation and records. ARPA REQUIREMENTS TO BE INCLUDED IN Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. 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. In this article, we delve into two specific techniques for creating and using data visualizations, which can further aid a jurisdiction in detecting waste or fraud. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. Based on theAssistance Listing: Coronavirus State and Local Fiscal Recovery Fundsand Part 2 of theUS Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance(v3.0 February 2022) (Compliance Guide), the following UG provisions apply to the ARP/CSLFRF grant award: Most of these UG provisions impose process and internal control requirements, but some impose limitations on when, how, and for what purposes federal grant funds may be spent. 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. Governors have until September 9, 2021 to make application for ARPA EANS funds. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. 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 Capital Funds Project website. Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. In the meantime, please feel free to contact us if you have any questions or ideas about data. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Confirm that the vendor billed at the rates stated in the contract or purchase order. The results of the survey can be transferred to a spreadsheet. Some of these are associated with a particular project; others are associated with the entire grant award. These awards are as follows: 0 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. The vendor provided supporting documentation for the items or services on the invoice. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. The funds can be used to purchase equipment that improves or enhances the delivery of daily Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. [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 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. Alternatively, if the recipient does not have a NICRA, the recipient may elect to use the de minimis rate of 10 percent of the modified total direct costs pursuant to 2 CFR 200.414(f). Historical data regarding the use of a supply or service can help procurement teams project future procurement needs and build a more effective and accurate budget. 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 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 Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). Please let us know how we can improve this page. 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. The state agency or municipality should first identify the goal of the audit, which will determine the type of audit to perform. 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. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. Restricting access to the submitted bids. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. [2] Per 2 CFR 200.318(a), non-Federal entities, such as municipalities, must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. These are common red flags for potential fraud and abuse. 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. If you are not checking invoices carefully against your contract terms and conditions, your jurisdiction may be paying more that it should; or, in the case of a revenue-generating contract, your jurisdiction may be receiving less than it should. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. 11246. 9-10). Top-requested sites to log in to services provided by the state. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. ARPA REQUIREMENTS TO BE INCLUDED IN 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. 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. Is it something you can collect in the future? WebWhen it comes to using ARPA funds, there are layers of rules towns have to follow (the U.S. Treasury says so right here on page 8): - Local procurement rules - New York State Require regular and thorough reporting from grantees relating to expenditures. 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. ) or https:// means youve safely connected to the official website. This information is invaluable to managers. 5. Program Income. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. Is the contract active and does it include the goods or services being sought? Review for compliance with federal procurement law requirements. These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. 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). Finally, in addition to my colleagues Rebecca Badgett, who drafted some of the above UG policies, and Connor Crews, who is working on procurement and conflict of interest policies, we want to thank our two amazing research assistants, Tiffany Oliva and Abby Gostling, who drafted several of our templates and other tools. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. endstream endobj startxref Recipients should consult the final rule for further details if they seek to utilize SLFRF funds as a match for these projects. 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, a municipality may have an engineering and construction firm contracted to build a new community center and wants to use the same firm to perform citywide water and sewer infrastructure projects as permitted by the CLFRF. 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. Knapp-Sanders Building For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. See 2 C.F.R. WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. Then make sure that you have access to that data. 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. Jurisdictions therefore must dedicate staff to evaluate documents and completed work reports from contractors to make sure that they have followed the contract before issuing payment. Subrecipient Monitoring. infrastructure, potential enhancements of state funding resources, While a right-to-audit clause gives the team the contractual authority to conduct the audit, getting buy-in from management will help make the audit more efficient and effective. Identifying the key vendor personnel is also an important part of the audit. 200.317, 200.322, and 200.326. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. Below are a few examples of the range of schemes that vendors may engage in. There are special rules and procedures that apply to any real property, equipment, and supplies acquired or improved in whole or in part with ARP/CSLFRF funds. 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. October 2015 Procurement Bulletin Article. 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. Secure websites use HTTPS certificates. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. If you are used to having a financial statement audit, a single audit can be much more comprehensive. 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