Consider whether prevailing wage rates apply. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. 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). 2000d-1 et seq., and the Departments implementing regulations, 31 CFR part 22; Section 504 of the Rehabilitation Act of 1973 (Section 504), Public Law 93-112, as amended by Public Law 93-516, 29 U.S.C. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. The OIG is developing classes to introduce local officials to specific data analysis techniques. 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. 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. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. Webprocurement can be used. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. (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. Mayor Smiley wants to hear from you! 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 This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. Federal procurement laws and regulations typically require that you use a fair, open and competitive process, even though price thresholds, advertising requirements and contract award language may differ from the requirements of Chapter 30B. 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. 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 otherwise specified in program-specific guidance. SLFRF funds beyond those that are available under the revenue loss eligible use category may not be used to meet the non-federal match or cost-share requirements of other federal programs, other than as specifically provided for by statute. 195 0 obj <>stream For example, in the scatter plot below, each of the points represents one contract. If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. two (2) subrecipients to carry these programs. As required under 2 CFR 200, a local governments procurement program must address the following: Full and Open The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. You skipped the table of contents section. Taking incremental steps and continually finding areas for improvement will create a robust data program and help you make informed, data-driven decisions. 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&. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Determine if billings are accurate and in compliance with contract terms. External sources are another area from which data can be gathered and used in an analysis. Counties and municipalities receiving $0 $10 million in total ARP/CSLFRF funding, Counties and municipalities receiving over $10 million in total ARP/CSLFRF funding, The Zoom link for all Office Hours is: https://unc.zoom.us/j/94011361206?pwd=MjIzWnlzOWxtNGtoUlNjaEV3ZWNPdz09. These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. We use data every day without realizing it. 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. [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]. Some of the data within your organization may already be in an analyzable format. In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act, Treasury will collect and review information from non-Tribal recipients to ascertain their compliance with the applicable requirements before and after providing financial assistance. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. Also, remember the following: 1. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. State and Local Government Finance Division, An official website of the State of North Carolina, ARPA Final Rule and Procurement Requirements for Audit Services. April 11, 2022: Basics of Implementing the Standard Allowance. 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. It is a red flag that the business may not be legitimate or well established. Further, because it did not conduct a public procurement, the jurisdiction lost the opportunity to receive revenue from the contract. 601 0 obj <>stream The course will have three parts, including brief overview videos, a 1-day live (Zoom) workshop, and extended daily Zoom Help Desk Office Hours the last two weeks of April (to help with implementation issues and completion of the Project & Expenditure report due by April 30). This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. To use data in decision making, the data must exist in a format that can be analyzed. For instance, recipients should note that SLFRF funds may not be used as the non-federal share for purposes of a states Medicaid and CHIP programs because the OMB has approved a waiver from this provision as requested by the Centers for Medicare & Medicaid Services pursuant to 2 CFR 200.102 of the Uniform Guidance and related regulations. 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. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. Process compliance audits evaluate whether the vendor is doing what it was hired to do. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. Recipients should consult the final rule for further details if they seek to utilize SLFRF funds as a match for these projects. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. Determine whether the contract allows the vendor to bill for the items listed on the invoice. ARPA-funded projects must also adhere to North Carolina In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. ARPA REQUIREMENTS TO BE INCLUDED IN These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. Specifically, Ohios political subdivisions have Chapel Hill, NC27599-3330 When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 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. 5. Secure websites use HTTPS certificates. WebARPA Policy and Procedures Manual. US Treasury issued theFinal Ruleof the Coronavirus State and Local Fiscal Recovery Fund program of the American Rescue Plan Act of 2021 (ARP/CSLFRF) in January 2022. The following is the schedule for the next several weeks. If you are used to having a financial statement audit, a single audit can be much more comprehensive. The funds can be used to purchase equipment that improves or enhances the delivery of daily 2023 School of Government at the University of North Carolina. Many of our past reports highlight fraudulent or inaccurate vendor billing. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. 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. 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 January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US In most cases, city procurement Federal Register Publication Vol 85 No. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. Regulatory compliance audits determine whether the vendor is following all of the laws and regulations relevant to the goods and services they provide (e.g., environmental regulations). Maintaining clear policies governing conflicts of interest for They are still federal grant funds, subject to all the award terms (be sure to read this document thoroughly) and most of the provisions of the federal Uniform Guidance (UG), which is the set of regulations that apply to the administration of federal awards. When procuring goods or services, the state agency or municipal department typically executes a contract with the vendor to outline the scope of the parties agreement. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. 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. 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. Consistently applied. 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. 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 Please limit your input to 500 characters. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. Please do not include personal or contact information. The regulations related to allowable costs and cost principles are complex. Capital Funds Project website. 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. This training discusses the differences between subrecipients and contractors under the federal rules, fiscal recovery fund spending that is presumed eligible due to the nature of the beneficiaries or the type of project, and rules relating to using fiscal recovery funds on capital expenditures. 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). 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. 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). 3. 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