Maintaining records sufficient to detail the history of procurement. The funds can be used to purchase equipment that improves or enhances the delivery of daily procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. It is easy to become overwhelmed when determining how best to use this untapped resource. We welcome non-English speakers to contact us. 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. WebStates are required to follow their own procurement procedures as well as the Federal requirements for procurement of recovered materials and inclusion of required contract provisions per 2 C.F.R. Also, remember the following: 1. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. 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.. 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. 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. Recipients should note that SLFRF funds available under the revenue loss eligible use category generally may be used to meet the non-federal cost-share or matching requirements of other federal programs. endstream endobj startxref Every jurisdiction needs to review vendor payment requests to make sure they are accurate. The results of the survey can be transferred to a spreadsheet. The team should consider gaining direct access to the vendors systems to facilitate its review. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. Webthe provision of police, fire, and other public safety services (e.g., purchasing a fire truck or police vehicles, purchasing other equipment, covering salaries of public safety personnel). 11 Uniform As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E regarding Cost Principles, allowable costs are based on the premise that a recipient is responsible for the effective administration of Federal awards, application of sound management practices, and administration of Federal funds in a manner consistent with the program objectives and terms and conditions of the award. The August 2020 installment of our data series discussed how to collect data and provided examples of how municipal employees can use that data to identify waste and possible fraud. Direct costs are those that are identified specifically as costs of implementing the SLFRF program objectives, such as contract support, materials, and supplies for a project. Then make sure that you have access to that data. 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. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. Written procedures that do not meet UG standards must be revised to include these 12. October 2015 Procurement Bulletin Article. Capital Funds Project website. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. Please let us know if you have any questions! The following sample policy may be appended to your local governments regular records retention policy. Specifically, Ohios political subdivisions have To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. Ensure the agency received all of the purchased goods and services. This can lead to drawing incorrect conclusions about the data and documentation available. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. The funds can be used to purchase equipment that improves or enhances the delivery of daily The right person to review an invoice depends on the type of contract, including its size and complexity. 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. ARPA REQUIREMENTS TO BE INCLUDED IN Historical and external data sources might not provide the complete picture for your analysis. Is it something you can collect in the future? Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. 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. 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. Any purchase of equipment or real property with SLFRF funds must be consistent with the Uniform Guidance at 2 CFR Part 200, Subpart D. Equipment and real property acquired under this program must be used for the originally authorized purpose, unless stated otherwise by Treasury. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. 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. There are several techniques you could use to identify vendors to audit. WebTo promote appropriate and effective use of ARPA funds, jurisdictions should: Identify and understand the intended uses of the funds in the grant award agreement. Civil Rights Compliance. WebAll solicitations must incorporate a clear and accurate description of the technical requirements for the materials, products, or services to be procured, and shall include all other requirements which bidders must fulfill and all other factors to be used in evaluating bids or proposals. Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. American Rescue Plan Act of 2021: Sample Uniform Guidance Policies and Implementation Tools, -Boards of Mental Health, Developmental Disabilities, & Substance Abuse, -Affordable Housing & Minimum Housing Codes, -Professional Responsibility for Government Attorneys, Purchasing, Construction, Property Transactions, -Purchasing / Purchase Contracts / Purchase Orders, Assistance Listing: Coronavirus State and Local Fiscal Recovery Funds, US Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, Subpart C, Pre-Federal Award Requirements and Contents of Federal Awards, Subpart D, Post Federal; Award Requirements, Project and Expenditure Report Tracking Template, Blog post explaining allowable cost and cost principles, Sample Allowable Cost and Cost Principles Policy, Sample Employee Effort Certification Form for 100% Covered Employees, Sample Employee Effort Certification Form for Less Than 100% Covered Employees, as outlined in paragraph 4.c. [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. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. The OIG is developing classes to introduce local officials to specific data analysis techniques. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US To promote accountability, ARPA includes requirements for the administration, monitoring and reporting of funds. In your role as a procurement official, you may already track bids and price quotations in Excel. Nevertheless, the vendor generated substantial revenue from the contract because drivers had to pay the vendor for towing and storage charges. Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. A .mass.gov website belongs to an official government organization in Massachusetts. This information is invaluable to managers. If a local government received less than $10 million in CSLFRF funds, it may take the What is the difference between Suspension and Debarment? It is intended to change the course of the COVID-19 pandemic, provide direct relief to Americans, and build a bridge to equitable economic recovery. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Are there existing sources for that data? two (2) subrecipients to carry these programs. Ensure compliance with policies, procedures, rules, regulations and legal requirements. 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. As you may know, under Section 1(b)(21) of Chapter 30B contracts for the towing and storage of motor vehicles are exempt from the Uniform Procurement Act. 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. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. Please do not include personal or contact information. As many of you already know, the US Treasury last week issued the Final Rule on the funds granted to state and local governments by the American Rescue Plan Act. 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