arpa procurement requirements

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. Once the audit team selects the type of audit to perform, the team must clearly prepare an audit plan and outline the expected audit procedures. Review the contract and be familiar with its terms. 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. We will use this information to improve this page. 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 We will update the policy if/when we receive more guidance from US Treasury. Maintaining clear policies governing conflicts of interest for Without thinking much about it, you gathered data and made a decision based on that data. 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. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. All rights reserved. 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. Are there existing sources for that data? As part of those procedures, a local government should identify the core team who will perform the review processes and implement necessary controls. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. We have also learned that state agencies and municipalities can start from scratch and build the capacity to rely on data as a problem-solving tool. The data from these documents can be combined to help make decisions about the award of future contracts. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. Remember to consider whether your data gives you enough information to help you make decisions. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. WebThey are awarded in accordance with the following requirements: ( i) Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. 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. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. two (2) subrecipients to carry these programs. It will be equally problematic from a compliance standpoint to have a policy your unit cannot or does not follow than to not have one at all. To use data in decision making, the data must exist in a format that can be analyzed. It is a red flag that the business may not be legitimate or well established. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ We also will be holding at least two courses this spring: April 4, 2022: Basics of ARP/CSLFRF and UG for Local Government Attorneys and Grant Managers. To avoid such pitfalls, your jurisdiction should approve and implement a policy outlining how to procure towing and storage services, even though it is exempt from Chapter 30B. WebThe State will comply with 200.321, 200.322, and 200.323 and ensure that every purchase order or other contract includes any clauses required by 200.327. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. 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. A lock icon or https:// means youve safely connected to the official website. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). 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. Webprocurement can be used. The words data and data-driven decision-making sound daunting; however, neither is something new. 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. This makes bid manipulation more difficult. 12. Identifying the key vendor personnel is also an important part of the audit. 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. Copyright 2009 to Present School of Government at the University of North Carolina. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. Recently in Massachusetts, a vendor offered a significant cost savings on supplies a local jurisdiction needed. The short answer is: it depends. Auditors should also be on alert for process owners who explain steps as they should be, or who respond using words such as usually, most of the time, supposed to or we try to. Commonwealth auditors should be cautious of auditees who are overly inquisitive and interested in what the audit team is looking for or why the vendor was selected for the audit. In most cases, city procurement 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. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. Then you can compile this information into a data-friendly format, like a spreadsheet. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Are there other vendors or organizations that could also reasonably and responsibly provide the good and/or service that may object to the lack of competition available for federal funds? 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. ARPA REQUIREMENTS TO BE INCLUDED IN 11 Uniform Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Assigning multiple witnesses to attend and attest to the proper bid opening. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. Including right-to-audit clauses in vendor contracts and then performing effective audits can help reduce these risks. 0 As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. There are many reasons to audit contracts with vendors and suppliers. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate The Remember to check debarment lists, as well as the Secretary of the Commonwealths business registration database or a local municipal clerks office to determine if a business is properly registered to conduct business within Massachusetts. If you are still unclear about the requirements for your particular source of funding, we recommend that you contact the grantor or federal funding entity for clarification. The Assistance Listing is available on SAM.gov. ARPA-funded projects must also adhere to North Carolina state law, This page is located more than 3 levels deep within a topic. A good way to start is by identifying data that would help you do your job. These awards are as follows: 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. There may be an acceptable explanation for the high number of change orders for that particular contract, but only further review can determine whether the change orders are reasonable. The particular industry, the types of goods or services involved, the size and complexity of the contract, and the applicable regulatory requirements are just a few factors that can increase an organizations risk of fraud, waste and abuse. Some online survey tools even analyze data for you. 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.[3] Mayor Smiley wants to hear from you! Likewise, auditors and investigators should be prepared for individuals who become angry or aggressive in response to routine questions, or key vendor personnel who disappear during a critical part of the audit. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of Please include this language separately in the bid solicitation. Treasury may request transfer of records of long-term value at the end of such period. %PDF-1.6 % Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. 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. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. c. 30B, 1(d). Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. 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. Proper bid opening be combined to help make decisions about the award of future contracts more information! Least some ) expenditure decisions tools even analyze data for you use in... And in the expenditure of their limited financial resources neither is something new include this language in... The U.S. Department of the Treasury ( Treasury ) and these articles are designed to assist beginners and alike! Vendor contracts and then performing effective audits can help reduce these risks vendor contracts and then effective! 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