These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? Top-requested sites to log in to services provided by the state. 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. Fraud, waste and abuse can occur even when comprehensive contracts are in place. 559 0 obj <> endobj All documentation must be maintained for at least 5 years from the end of the award term. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. 195 0 obj <>stream Registration closes twoweeks before the class start date. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. Assigning multiple witnesses to attend and attest to the proper bid opening. When was the last time your client revised their procurement contracts? A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. 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 Some of these are associated with a particular project; others are associated with the entire grant award. 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. Recipients of SLFRF funds should calculate, document, and record the organizations program income. Identify and understand the intended uses of the funds in the grant award agreement. When was the last time your client revised their procurement contracts? Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of 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. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate on the basis of race, color, national origin (including limited English proficiency), disability, age, or sex (including sexual orientation and gender identity), in accordance with the following authorities: Title VI of the Civil Rights Act of 1964 (Title VI) Public Law 88-352, 42 U.S.C. We welcome non-English speakers to contact us. 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 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 Once the data has been transformed into auser-friendlyformat, it can be used in a variety of ways to assist with future procurements and other business decisions. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. 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. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. 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? A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. For this program, the city of Scranton has elected to award . If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. A lock icon or https:// means youve safely connected to the official website. Maintaining records sufficient to detail the history of procurement. Financial compliance audits examine whether the vendor is billing appropriately. There are many reasons to audit contracts with vendors and suppliers. Properly documented. 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. Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. In this case, the subaward to a nonprofit is based on the services that the recipient intends to provide (assistance to households experiencing homelessness), and the nonprofit is serving as the subrecipient, providing services on behalf of the recipient. 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. 2 CFR Part 25 (Universal Identifier & System for Award Management) The Office of the Inspector General has compiled the following Bulletin articles related to using ARPA funds, including articles about paying for supplies and services with federal funds, invoice review, data analytics and vendor audits. A good way to start is by identifying data that would help you do your job. 6. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. This outlier may warrant further investigation. (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. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. 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. 2. 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. Then you can compile this information into a data-friendly format, like a spreadsheet. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. For that reason it is not included in the Drop-in document. 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. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. Copyright 2009 to Present School of Government at the University of North Carolina. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. However, Chapter 30B does not apply to federally funded procurements if following Chapter 30B would conflict with federal laws or regulations. 200.317, 200.322, and 200.326. After the official bid opening requiring a review of the bid submittals and verification of the bid results by a party not involved in the bid process. This blog post is published and posted online by the School of Government to address issues of interest to government officials. 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. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. Process compliance audits evaluate whether the vendor is doing what it was hired to do. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? All rights reserved. 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. The Office of Management and Budget recently published guidance on how auditors should conduct Single Audits for ARPA Recovery Fund investments and the Emergency Rental Assistance Program County auditors should consult OMBs Compliance Supplement when constructing Single Audits for county investments of federal funds. For this program, the city of Scranton has elected to award . To browse a complete catalog of School of Government publications, please visit the Schools website at www.sog.unc.edu or contact the Bookstore, School of Government, CB# 3330 Knapp-Sanders Building, UNC Chapel Hill, Chapel Hill, NC 27599-3330; e-mail sales@sog.unc.edu; telephone 919.966.4119; or fax 919.962.2707. 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. Please limit your input to 500 characters. necessary to lawfully utilize federal ARPA funds for procurement or construction? hWoHWcORPKt.u8 -fA zA^%hq0)`Q9^2 B $BJ*'xdg.|vOhRRFa)`q:e8^0^0^0^0^ 6fn?iTDuHG?=t1Ax twx3Oy!/%G}KoW%0!,k69\=nl A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. If your contract does not permit the vendor to charge a specific fee, then your jurisdiction has a basis for contesting the application of any additional fee. Consistent with 2 CFR 200.311 and 2 CFR 200.313, any equipment or real property acquired using SLFRF funds shall vest in the non- Federal entity, consistent with any guidance that Treasury may issue. 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 Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. 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. Direct questions related to design and construction procurement to the Attorney Generals Office. Federally funded procurements if following Chapter 30B does not apply to federally procurements! The effectiveness of talent acquisition activities that meet the organization 's needs talent acquisition activities that meet the organization needs... 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