Consider whether prevailing wage rates apply. If not, many of the bid documents your jurisdiction retains can be used as data sources. [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. Implement internal controls to prevent fraud, waste and abuse. 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. 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. If a recipient seeks to use SLFRF funds to satisfy match or cost-share requirements for a federal grant program, the recipient should first confirm with the relevant awarding agency that no waiver has been granted for that program, that no other circumstances enumerated under 2 CFR 200.306(b) would limit the use of SLFRF funds to meet the match or cost-share requirement, and that there is no other statutory or regulatory impediment to using the SLFRF funds for the match or cost-share requirement. Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. 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. A lock icon ( Many of our past reports highlight fraudulent or inaccurate vendor billing. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. Consistently applied. The feedback will only be used for improving the website. All documentation must be maintained for at least 5 years from the end of the award term. A local government should craft its policies and procedures so that they can be reasonably implemented by its staff. Once you have access, you can use the data to inform your decisions and manage risks. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. Please let us know how we can improve this page. 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. 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. 5. 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. If you need assistance, please contact the Office of the Inspector General. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. Maintaining records sufficient to detail the history of procurement. Look for those in the coming weeks. To promote accountability, ARPA includes requirements for the administration, monitoring and reporting of funds. This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. Pursuant to the SLFRF Award Terms and Conditions, recipients are permitted to charge both direct and indirect costs to their SLFRF award as administrative costs as long as they are accorded consistent treatment per 2 CFR 200.403. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. 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. 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, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) 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. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. Including right-to-audit clauses in vendor contracts and then performing effective audits can help reduce these risks. 2 CFR 200.317 - 2 CFR 200.327. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. The 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. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. You can transform information from historical and external sources into usable data, and you can create new data. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. 12. The prevention and detection of fraud, waste and abuse of public funds always an important issue for government entities is even more critical now that jurisdictions are receiving billions of additional dollars in ARPA funding. Are you missing any data that would help you monitor utilization? 3) Consider publishing all sole source requests for public notice. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. 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. 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. The record retention requirements for ARP/CSLFRF-related records are more stringent than those imposed under State law. 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. Based on theAssistance Listing: Coronavirus State and Local Fiscal Recovery Fundsand Part 2 of theUS Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance(v3.0 February 2022) (Compliance Guide), the following UG provisions apply to the ARP/CSLFRF grant award: Most of these UG provisions impose process and internal control requirements, but some impose limitations on when, how, and for what purposes federal grant funds may be spent. Review the contract and be familiar with its terms. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. Subrecipient Monitoring. Without thinking much about it, you gathered data and made a decision based on that data. WebPrerequisite: None Class Level: Basic Instructional Method: Online - MCPPO Online Class Technical Specifications Advanced Prep: None Class dates and times: April 18, 2023, The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. 128, 40064-40068. If a vendor is not registered beware. Treasury may request transfer of records of long-term value at the end of such period. Remember to consider whether your data gives you enough information to help you make decisions. Insufficient reportingrequirements or processes, or lack of attention to grant administration, can lead to a wide range of negative results, including project mismanagement, inappropriate use of funds and failure to comply with legal requirements. The team should consider gaining direct access to the vendors systems to facilitate its review. 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. We will use this information to improve this page. For that reason it is not included in the Drop-in document. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. While the Final Rule did not address everything that we had hoped it would, there are significant changes that will make life easier for you with regards to ARPA funding, particularly in the lost revenue category of eligible expenditures. 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. Federal Register Publication Vol 85 No. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. The ARPA program requires recipients to comply with the procurement provisions of Title 2, Part 200 of the Code of Federal 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 Direct questions related to design and construction procurement to the Attorney Generals Office. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. 11 Uniform The regulations related to allowable costs and cost principles are complex. Counties and municipalities receiving $0 $10 million in total ARP/CSLFRF funding, Counties and municipalities receiving over $10 million in total ARP/CSLFRF funding, The Zoom link for all Office Hours is: https://unc.zoom.us/j/94011361206?pwd=MjIzWnlzOWxtNGtoUlNjaEV3ZWNPdz09. %%EOF Use of this blog post for commercial purposes is prohibited. A .mass.gov website belongs to an official government organization in Massachusetts. Weve never been audited, so there are no benchmarks to assess our performance., Our regular business hours are third shift., We cannot remove documents from our office., Cross-charging multiple clients or departments for their staffs work, Improper employee classification e.g., junior staff hours billed at a supervisors hourly rate, Overlapping time vendor creates two or more timesheets for the employee for the same day, Schedule manipulation vendor routinely postpones or schedules jobs with higher overtime rates toward the end of the week, Over-purchasing materials for personal use, Product substitution - substituting lower-quality products for those agreed upon in the contract, Failure to apply discounts, refunds and rebates, Billing materials to one project but using for another project, Intentionally applying rates from one contract to another, Billing time and equipment rates in lump-sum, unit or fixed-price contracts. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. You skipped the table of contents section. 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. Also, remember the following: 1. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U Per 2 CFR Part 200.303, your organization must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. 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. 6. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. Please do not include personal or contact information. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. Please limit your input to 500 characters. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. The state agency or municipality should first identify the goal of the audit, which will determine the type of audit to perform. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. Recently, our Chapter 30B hotline has received a number of calls asking whether Chapter 30B applies when a local jurisdiction pays for supplies or services with federal funds. These awards are as follows: Knapp-Sanders Building Bid manipulation can also include allowing a vendor to submit bid documents after the public deadline or disclosing offers made by one vendor to another before the bids are opened publicly. During this session, Please limit your input to 500 characters. 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. Additional controls that your organization should implement include written policies that explicitly identify appropriate allocation methods, accounting standards and principles, compliance monitoring checks for program income calculations, and records. Nevertheless, the vendor generated substantial revenue from the contract because drivers had to pay the vendor for towing and storage charges. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. In your role as a procurement official, you may already track bids and price quotations in Excel. Still, working with data at all levels of government can be challenging. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. 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. Recipients of SLFRF funds should calculate, document, and record the organizations program income. Maintaining clear policies governing conflicts of interest for After the official bid opening requiring a review of the bid submittals and verification of the bid results by a party not involved in the bid process. Incorporate by Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. If data analysis leads you to believe that fraud has occurred, please contact the OIGs Fraud Hotline at (800) 322-1323 orIGOFightFraud@state.ma.us, orfill out our online form. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. 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. The executive order requires that every goods or services contract or agreement must incorporate an auditing provision permitting the government to audit the vendors books, records and other compilations of data relative to the performance of any provision or requirement of the contract or agreement. Thank you for your website feedback! We will update the policy if/when we receive more guidance from US Treasury. The funds can be used to purchase equipment that improves or enhances the delivery of daily April 11, 2022: Basics of Implementing the Standard Allowance. 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. Some of these are associated with a particular project; others are associated with the entire grant award. When procuring goods or services, the state agency or municipal department typically executes a contract with the vendor to outline the scope of the parties agreement. All rights reserved. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. During this session, A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. This Job Opportunity Announcement may be used to fill other Management & Program Analyst (Talent Management Specialist) GS-0343-11/12 FPL: 12 positions within the Economic 601 0 obj <>stream Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. Each category of cost should be treated consistently in like circumstances as direct or indirect, and recipients may not charge the same administrative costs to both direct and indirect cost categories, or to other programs. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. Specifically, Ohios political subdivisions have We will update the policy if/when we receive more guidance from US Treasury. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of Therefore, support from potential stakeholders senior management, the Board of Directors, department decision-makers is important for a successful audit engagement. Use this button to show and access all levels. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. 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. The following sample policy may be appended to your local governments regular records retention policy. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Incorporate by reference any federal rules that apply to the grant award. Publishing and documenting clear standards in procurement solicitations and evaluation criteria on how a municipality will determine a responsive and responsible. Municipalities should ensure that factors that may be overly restrictive to free and open competition are not included, such as placing unreasonable requirements on vendors to qualify or establishing any steps in the procurement process that are arbitrary or irrelevant to the award of contracts necessary and reasonable for the implementation of the use of funds under this award. The vendor claimed that the lower per-unit price was only for bulk purchases. of the Award Terms and Conditions, Accessibility: Report a Digital Access Issue, Allowable Costs and Cost Principles Policy, Financial Management and Internal Controls, Program Income Policy (if local government uses ARP/CSLFRF funds to establish a loan program or otherwise earns income related to an ARP/CSLFRF expenditure), Procurement Policy (if a local government contracts for goods or services paid for with ARP/CSLFRF funds, or must engage in a Single Audit (even if the audit is paid for with other funds)), Property Management Policy (if a local government uses ARP/CLSFRF to acquire or improve any real property, equipment, or supplies), Subaward Policy (if a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF-eligible project), Thursday, March 24, at 8:30am (focus on affordable housing). Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. There are many reasons to audit contracts with vendors and suppliers. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. 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 Exceptions to requirements for small purchase or formal method competitive rules. As part of its contract administration process, the housing authority discovered the improper charges when it reviewed its invoices closely. Are there special requirements for capital Exceptions to requirements for small purchase or formal method competitive rules. In your procurement file you can transform information from historical and external sources into data! 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