We use data every day without realizing it. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. All rights reserved. Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. Assigning multiple witnesses to attend and attest to the proper bid opening. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. The results of the survey can be transferred to a spreadsheet. Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. Top-requested sites to log in to services provided by the state. 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. If a recipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. 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. Please limit your input to 500 characters. %%EOF To start, here is a summary list of UG policies and their triggers. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? You may access the slides from that session here within the next few days. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) 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 During this session, All rights reserved. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. The first step in implementing a vendor audit program is determining who to audit. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? %PDF-1.6 % 200.317, 200.322, and 200.326. 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. This makes bid manipulation more difficult. WebThe Buy American requirements apply to all Recovery Act funds used for a project for the construction, alteration, maintenance, or repair of a public building or public work. See M.G.L. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. 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. Government entities that have received ARPA funding may be able to award grants to third parties. Protect your jurisdiction and thwart bid manipulation by: you suspect bid manipulation, contact the Office of the Inspector Generals fraud, waste and abuse hotline at (800) 322-1323. Without thinking much about it, you gathered data and made a decision based on that data. The vendor claimed that the lower per-unit price was only for bulk purchases. This includes setting specific requirements and expectations, providing an audit timeline, including when and where you will visit, who you will interview, and which documents you will need. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. A lock icon ( This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. 128, 40064-40068. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. Benfords Law analysis: this analysis may highlight a vendor with billing discrepancies that warrant further review. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. The right person to review an invoice depends on the type of contract, including its size and complexity. Taking incremental steps and continually finding areas for improvement will create a robust data program and help you make informed, data-driven decisions. 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. 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. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. Secure websites use HTTPS certificates. 2 CFR 200.320(c). The smallest incongruity could lead to the discovery of a large fraud. Ensure the agency received all of the purchased goods and services. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. 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. Establish attainable program goals and targets, and understand which expenditures are allowable under federal law. With the addition of the standard allowance, authorizing many NC local governments to expend their entire ARP/CSLFRF allocation for almost any purpose authorized by state law, counties and municipalities across the state have an even greater opportunity to make the best strategic investments for their communities with these one-time funds. 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). Please limit your input to 500 characters. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. That policy will accomplish three different goals: (1) General review that a cost item is reasonable, allowable, allocable, consistently treated, and properly documented; (2) Identification of cost item as direct or indirect; and (3) Specific review of certain identified cost items, for special treatment, justification, and/or documentation. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. [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]. There are no requirements for contracts or expenditures of less than $10,000. However, using ARPA funds for contracts in excess of $10,000 triggers the mandatory contract provisions in 2 CFR Part 200, Appendix II. Most contract provisions are required only on those exceeding $100,000 or those for construction projects of any amount. 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. 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. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. 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. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. 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. Come with your questions and share your experiences and insights with colleagues across the State. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. Fraud, waste and abuse can occur even when comprehensive contracts are in place. All documentation must be maintained for at least 5 years from the end of the award term. The funds can be used to purchase equipment that improves or enhances the delivery of daily [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. Determine if billings are accurate and in compliance with contract terms. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. 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. 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. Please let us know how we can improve this page. 195 0 obj <>stream February 2019 Procurement Bulletin Article. Webprocurement can be used. c. 30B, 1(f). 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. Each of the considerations above, as well as operation and maintenance Finally, Kara hosted SOG Office Hours on Jan. 13, 2022, and the primary topic was the Final Rule and the change in lost revenue calculations. People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. This scope is different than what is included in the current contract and may be considered noncompetitive. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. Thank you for your website feedback! Still, working with data at all levels of government can be challenging. A compliance audit is the overarching term for ensuring that a vendor is complying with the terms of a contract. ) or https:// means youve safely connected to the official website. T:919.600.7874. Properly documented. 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. Recently in Massachusetts, a vendor offered a significant cost savings on supplies a local jurisdiction needed. 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. Incorporate by 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. 601 0 obj <>stream 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.