arpa procurement requirements

Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. Incorporate by reference any federal rules that apply to the grant award. All rights reserved. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. See M.G.L. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. You skipped the table of contents section. All rights reserved. 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 They are SLFRF recipients that will report directly to Treasury. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. For example, in the scatter plot below, each of the points represents one contract. 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. 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. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. Historical data regarding the use of a supply or service can help procurement teams project future procurement needs and build a more effective and accurate budget. 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. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= It will include a detailed look at the various UG provisions and sample policies. 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. In order to maintain the vendors trust and cooperation, the team should only ask for information necessary to achieve the goal of the audit and documents that have a true business justification. 559 0 obj <> endobj Mathematicians studied collections of numbers and found that the first digit will be a 1 about 30% of the time and a 2 about 17% of the time, with subsequent numbers following a similar decreasing pattern, as shown in the data visualization on the next page. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. As part of its contract administration process, the housing authority discovered the improper charges when it reviewed its invoices closely. Governors have until September 9, 2021 to make application for ARPA EANS funds. If you are used to having a financial statement audit, a single audit can be much more comprehensive. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. To utilize a pre-existing contract, municipalities can consider the following requirements to assess whether the contract meets federal procurement requirements: 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. 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. 9-10). The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. 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. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. A different person should have the authority to approve payment, and that person must also know the terms of the contract to effectively review invoices. ) or https:// means youve safely connected to the official website. 117- 2 (March 11, 2021). 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. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. However, the audit team should be careful not to become too friendly with their auditees. 2 CFR 200.320(c). 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 Direct questions related to design and construction procurement to the Attorney Generals Office. ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. 128, 40064-40068. These risk assessments may include factors such as prior experience in managing Federal funds, previous audits, personnel, and policies or procedures for award execution and oversight. The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. Web( a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. For that reason it is not included in the Drop-in document. The public expects that the local jurisdiction protected their interests, including ensuring that the vendor is qualified and that the towing charges are reasonable; and vendors expect open and fair competitive processes when a local jurisdiction contracts for a service that it needs. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee Share sensitive information only on official, secure websites. 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. Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. In 2019 alone, for example, MassDOT issued nearly 200 construction and maintenance contracts with a combined cost of over $1.2 billion. Include a right-to-audit clause in grant agreements. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. 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. There is a visible correlation between the number of change orders and the contract length, which makes intuitive sense: generally, longer contracts have more change orders. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Other important aspects to consider are the audit period, access to records and personnel, format of records, time needed, failure-to-produce penalties and notification requirements (planned versus surprise reviews). Chapel Hill, NC27599-3330 February 2019 Procurement Bulletin Article. A lock icon or https:// means youve safely connected to the official website. The right person to review an invoice depends on the type of contract, including its size and complexity. infrastructure, potential enhancements of state funding resources, 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. [4] 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 and 2 CFR 200.318(a). Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. 3) Consider publishing all sole source requests for public notice. Restricting access to the submitted bids. A lock icon ( WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, Registration closes twoweeks before the class start date. 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. 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. Then make sure that you have access to that data. The U.S. Department of the Treasury (Treasury) clarified that funds made available under the American Rescue Plan Act (ARP) Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) are subject to federal procurement requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), found at Title 2 of the Code of Federal Regulations, Part 200 (2 CFR 200). 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). Some page levels are currently hidden. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. Use this button to show and access all levels. A .mass.gov website belongs to an official government organization in Massachusetts. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). For this program, the city of Scranton has elected to award . 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. The goal of a vendor fraud audit is to determine whether the vendor intentionally acted to defraud the contracting organization. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. 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. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. It is easy to become overwhelmed when determining how best to use this untapped resource. Because ARP/CSLFRF in the revenue replacement category may be spent on any government service authorized under state law (assuming allowable cost items), a local government may use ARP/CSLFRF to supplant employees salaries and benefits during the award term, thus freeing up general fund or enterprise fund monies to be spent on more complex capital projects or programs. Alternatively, if the recipient does not have a NICRA, the recipient may elect to use the de minimis rate of 10 percent of the modified total direct costs pursuant to 2 CFR 200.414(f). Please remove any contact information or personal data from your feedback. 165 0 obj <> endobj You can transform information from historical and external sources into usable data, and you can create new data. The following is a sample policy to address the specifics of property management: Note that there are some grey areas related to whether and how a local government must seek US Treasurys approval for disposal of real property, equipment, or supplies over $5,000, and whether or not a local government will have to repay US Treasury its federal share. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. 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. 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. 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). The words data and data-driven decision-making sound daunting; however, neither is something new. The OIG is developing classes to introduce local officials to specific data analysis techniques. Justifying and documenting the selection of vendors, including: (1) that a vendor is responsive to the requirements outlined in the procurement, (2) responsible, (3) not debarred from doing business with the federal government, and (4) offering a reasonable, competitive cost, based on cost or price analysis completed by the municipality. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. You must ensure that the vendors you are doing business with are legitimate and responsible. 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