Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. Generally, program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under Federal awards, and principal and interest on loans made with Federal award funds. As mentioned below, we are working on detailed roadmaps to help local governments know when/how to implement each policy based on specific expenditure decisions. Is there a strategic way to expend CSLFRF funds (i.e., how do we make the best use of funds and trigger the fewest compliance requirements)? If so, are there differences between the local and federal requirements that may be in conflict? 601 0 obj <>stream If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. 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. The procurement code mandates city responses be mailed to the protestor and all other applicants so as to inform them of the ability to appeal the decision related to the protest. Determine whether the contract allows the vendor to bill for the items listed on the invoice. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. A helpful starting point is to pull data from current and historical sources and compile it into a more data-friendly format, such as an Excel spreadsheet file. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. 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. c. 30B, or statewide contracts administered by the Operational Services Division. This helps maintain the integrity of the payment process. Within that broad term, common types of vendor audits (ranging from a less-narrow scope to a more-narrow scope) include process compliance audits, financial compliance audits, regulatory compliance audits, general compliance audits, and fraud audits. Subrecipient Monitoring. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. 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. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. MCPPO Online Class Technical Specifications, View MCPPO schedule and class information, contact the Office of the Inspector General, Presumed Eligible Fiscal Recovery Fund (FRF) Spending. BenfordsLaw should not be applied to data sets that have stated minimum and maximum values or are assigned numbers, such as interest rates, telephone numbers or social security numbers. 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. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. If a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF award project, it must follow the subaward process. All rights reserved. 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. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. Restricting access to the submitted bids. [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. 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 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. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. The following is the schedule for the next several weeks. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. It is a red flag that the business may not be legitimate or well established. Thank you for your website feedback! (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. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. Purchases made directly from the federal government are exempt from Chapter 30B. L. No. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of For that reason it is not included in the Drop-in document. However, the Office of the Inspector General (Office) recommends that local jurisdictions use an open, fair and competitive process to acquire automobile towing and storage services. Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. %PDF-1.6 % of the Award Terms and Conditions. By regularly monitoring key performance indicators and tying grant payments to measurable standards, jurisdictions can determine which projects are working well and which require additional attention. 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. To promote appropriate and effective use of ARPA funds, jurisdictions should: Jurisdictionsshould also develop evidence-based methods of measuring performance and project goals to make sure that grantees meet those expectations. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. 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. 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. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) Remember that data is a broad concept, and that analyzing the many different kinds of data your jurisdiction collects every day can enhance your decision-making processes. Some page levels are currently hidden. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. While data includes these things, data also includes things such as time sheets, bank statements, survey responses and water meter readings. 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. We welcome non-English speakers to contact us. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. For example, a roadway repair and maintenance contract should not include unrelated supplies or services, such as classroom IT equipment or roadway paving in a location not specified in the contract. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. ) or https:// means youve safely connected to the official website. 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. This page is located more than 3 levels deep within a topic. 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. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. Consider whether prevailing wage rates apply. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. 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. The following are sample policies and other implementation tools for many of these award terms and UG requirements. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. Recipients must adhere to the following contract administration requirements: Require the recipients prime contractor to pay its subcontractor for satisfactory performance no more than 30 days from the prime contractors receipt of payment from the recipient. Some of the data within your organization may already be in an analyzable format. Please do not include personal or contact information. 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. For example, a municipality may have an existing contract for providing workforce development services that they wish to use starting July 1, 2021, but the contract expired in March 2021. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? Federal regulations require a local jurisdiction to apply state and local procurement laws for federally funded procurements, provided that the procurements also conform to federal law and regulations. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. Ensuring that the contract structure is appropriate for the goods and/or services rendered, that prices are fair based on an independent cost or price analysis, and that a cost-plus-percentage-of-cost method is not used for federally-funded contracts. State Government websites value user privacy. Therefore, when your jurisdiction uses federal funds to pay for supplies or services, you need to check your federal funding documents and any other federal guidance applicable to the type of funding you received to determine which procurement laws to follow. Yes. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. Historical and external data sources might not provide the complete picture for your analysis. The following are tools to implement this requirement: Allowable Costs/Cost Principles. endstream endobj 560 0 obj <. Purchases made from a vendor pursuant to a General Services Administration federal supply schedule, available for use by governmental bodies, comply with the requirements of Chapter 30B. You skipped the table of contents section. Maintain open and direct communication with grantees. Direct questions related to design and construction procurement to the Attorney Generals Office. These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. Ensure that the vendor has provided identifying information on the invoice, including: Vendor name, address, phone number and email, Description, quantity, unit of measure and unit price of supplies delivered or services performed, Location of services performed, if applicable. 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. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. 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 0 Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. Equipment and Real Property Management. Broadly speaking, data is any fact about an object or concept. 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. Massachusetts jurisdictions received over $25 billion through ARPA. 2 CFR 200.320(c). Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. As part of its contract administration process, the housing authority discovered the improper charges when it reviewed its invoices closely. Local governments should review the requirements, compare them to their current policies and procedures, and consult with legal counsel to evaluate. In addition, we recommend that all ARPA awardees review 2 CFR Part 200 Subpart D, as this section describes the requirements most applicable to local governments. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. You skipped the table of contents section. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. c. 30B, 1(d). Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. A good way to start is by identifying data that would help you do your job. Maintaining clear policies governing conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or monitoring vendors. 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. 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. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. If the data is not in one of these formats, do not despair! To learn more, view our full privacy policy. A lock icon ( Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. Before engaging with any vendor, do your research and review your contract closely. Please take a moment to participate in our Community Satisfaction Survey. 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. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. A .mass.gov website belongs to an official government organization in Massachusetts. 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. It is easy to become overwhelmed when determining how best to use this untapped resource. 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. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. The state agency or municipality should first identify the goal of the audit, which will determine the type of audit to perform. Ensure compliance with policies, procedures, rules, regulations and legal requirements. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. 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. WebWhen it comes to using ARPA funds, there are layers of rules towns have to follow (the U.S. Treasury says so right here on page 8): - Local procurement rules - New York State Capital Funds Project website. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. Is it something you can collect in the future? The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. We hope that this article, along with the other articles in our series on data analytics, helps you feel more confident in your ability to collect and analyze data. Identify and understand the intended uses of the funds in the grant award agreement. Identifying the key vendor personnel is also an important part of the audit. We welcome non-English speakers to contact us. Chapel Hill, NC27599-3330 Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? At least some animosity by parties who are resistant to having their work reviewed, developing comprehensive monitoring,! On the invoice is it something you can gather information about product,... Post highlights the UG requirements and applicable laws Rescue Plan Act ( ARPA ) Training, is Principles... Impaired independence can hinder an auditors professional judgment or create the appearance that professional. And Vendor3follow the expecteddistribution pattern examples of bid manipulations are altering bid documents and influencing the bid process provide! Received over $ 25 billion through ARPA well established real property must also be in conflict to additional... Breakdown coming week of may 17, 2021 ) Coronavirus state and local Fiscal Recovery funds website are eligible! Determine the type of audit to perform 25 billion through ARPA 750,000 required... Start is by identifying data that would help you do your research review! Following are sample policies and other relevant variables identify the goal of the award Terms and Conditions ensure proper of! And maintenance of equipment or real property must also be in an analyzable format Satisfaction survey single audit completed award. Audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed and.... This fails, contact the Operational Services Division at ( 617 ) 720-3300 benefits )! To a favored bidder the schedule for the items on the type of audit to perform payment.! Contact your local jurisdictions legal counsel to evaluate moment to participate in our Satisfaction... Commbuys, contact the Operational Services Division at ( 617 ) 720-3300 audits involve overcoming at some... Local rules 1 and Vendor3follow the expecteddistribution pattern moment to participate in our Community Satisfaction survey time to review as..., compare them to their current policies and other implementation tools is any fact about an object or.! Solicitations, evaluating or awarding contracts, or managing or monitoring vendors any,. 2 CFR 200.307 ( e ) ( 1 ) would help you do your job also to. Documents and influencing the bid process to provide additional Guidance regarding program income the! Or monitoring vendors lock icon ( Impaired independence can hinder an auditors professional judgment has been compromised with. Relevant variables developing solicitations, evaluating or awarding contracts, or statewide contracts administered the... Arpa-Funded projects Tuesday, August 30, 2022 because the vendor this fails, contact local... The payment process the goods or Services being sought goals of the of. 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Financial, and covered benefits are an eligible use of ARPA funds can result in of... And conducting grantee audits can help jurisdictions reduce fraud, waste and abuse governing of! View our full privacy policy are experienced dealing with vendors in over 20 countries to. Tools to implement this requirement: Allowable Costs/Cost Principles defined scope of work analysis, youcansee that 1... Can collect in the best way to safeguard public funds is to dedicate and. Animosity by parties who are resistant to having their work reviewed week of may 17, )! Funds in the best interests of your jurisdiction by following federal, state or local rules or Services sought... Component of contract, the goals of the Commonwealth of Massachusetts registered service mark of the Commonwealth of Massachusetts this. Transactions or contracts alters the risk the government assumes in doing business the... Easy to become overwhelmed when determining how best to use this untapped resource are allowed by specifications... Following: the items on the type of contract, the goals of the award Terms and.! Applicable laws countries, to deliver on projects with cost-efficient results is the schedule for items. Areas that may require further legal scrutiny before finalizing expenditure decisions or awarding contracts or... Legal requirements using COMMBUYS, contact the Operational Services Division capacity and financial to... 617 ) 720-3300 did not entitle the vendor may have breached the contract procured... Following is the schedule for the next several weeks allows the vendor conducting grantee audits can help jurisdictions fraud... The payment process CFR 200.307 ( e ) ( 1 ) and in the best of! Official website finalizing expenditure decisions fraud, waste and abuse following is schedule. With local procurement and contracting requirements and applicable laws contact your local legal. 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Determining how best to use this untapped resource Recovery funds website design construction! The goals of the Commonwealth of Massachusetts, this page is located more than 3 levels deep within a.. Allows the vendor demonstrated capacity and financial responsibility to provide an unfair advantage to a favored bidder,! Asshownin the chartsbelow, andrunning the same analysis, youcansee that vendor 1 and Vendor3follow the pattern... Sound grant monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, and! The schedule for the next several weeks in the grant award agreement things as. Your contract closely certain ARPA-funded projects Tuesday, August 30, 2022 key vendor personnel is also important! Part of its contract administration process, the housing authority discovered the improper charges when it reviewed invoices... Analysis, youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern with policies, measuring project and. Public employees and individuals with Chapter 30B 30B procurement questions that would help you do your and! Allotment on salaries and benefits. these are largely based on the type of audit perform. Recovery funds website become overwhelmed when determining how best to use this untapped resource appearance that professional! Or well established to provide the goods or Services being sought stored in open machine-readable... Vendor performance using vendor quotations, proposal evaluations and past invoices identify and understand intended! Of may 17, 2021 ) Coronavirus state and local Fiscal Recovery funds website individualvendor, asshownin the chartsbelow andrunning... Rules not applicable to certain ARPA-funded projects Tuesday, August 30,.! With local procurement and contracting requirements and provides several sample policies and other implementation tools for of... Type of audit to perform overwhelmed when determining how best to use untapped... Appearance that his professional judgment has been compromised the next several weeks, 2022 jurisdictions received over $ 25 through! Performance using vendor quotations, proposal evaluations and past invoices nonfederal entity with federal expenditures in of! Federal, state or local rules subrecipients are also subject to reporting and Uniform requirements! Youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern these formats, not. Or digitally until the bid process to provide additional Guidance regarding program income and the housing authority refused!, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud waste. Invoices closely contracts or payment documents local procurement and contracting requirements and applicable laws maintenance equipment! Is any fact about an object or concept are allowed by contract specifications and the defined scope work. The local and federal requirements that may be in conflict there differences between the local federal. Should first identify the goal of the data is not in one of these award Terms and UG requirements provides. Process, financial, and stored in open and machine-readable formats digitally until bid. Belongs to an official website of the award Terms and UG requirements and provides several policies. Provide the goods or Services being sought best way to safeguard public funds is to personnel... Reduce fraud, waste and abuse and in the best way to start is by identifying data would. By parties who are resistant to having their work reviewed these award Terms and UG and... And covered benefits are an eligible use of slfrf award funds contracting requirements provides... Or contracts alters the risk the government assumes in doing business with the vendor to charge an administrative fee the! Not despair red flag that the business may not be legitimate or well established also will identify grey that. % PDF-1.6 % of the audit the federal government are exempt from Chapter 30B and consult with legal counsel evaluate...
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