To help prioritize which vendors to audit, consider the factors below. 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). The following are a sample subaward policy, risk assessment, subaward agreement template, and subrecipient monitoring tool (they are all in a single Word file): Although there is a lot of federal red tape to navigate regardless of how a local government expends its ARP/CSLFRF funds, there are some opportunities to reduce a local units compliance burden. 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. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. This collection does not apply to Tribal governments. Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act (ARPA).The Final Rule makes several key changes to the Interim Final Rule, including expanding the eligible uses of Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. 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 For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. 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. We welcome non-English speakers to contact us. WebOWRB ARPA Engineering Procurement Process . WebSourcing & Procurement. 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. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. 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. These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. The reviewer should also request receipts or consult with appropriate staff to confirm that the dollar amounts on the invoice are valid before recommending invoice payment. 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. WebARPA Policy and Procedures Manual. %PDF-1.6 % We hope that this article has encouraged you to use data analysis more in your work. Benfords Law analysis: this analysis may highlight a vendor with billing discrepancies that warrant further review. BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. See M.G.L. Please let us know if you have any questions! Please limit your input to 500 characters. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 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. 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. Review the contract and be familiar with its terms. 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. During this session, Incorporate by reference any federal rules that apply to the grant award. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. External sources are another area from which data can be gathered and used in an analysis. 200.319-320 (describing the competitive processes required for procurements made with federal funds). Process compliance audits evaluate whether the vendor is doing what it was hired to do. By now, Ohio municipalities, counties, and townships are well aware that the federal government passed significant coronavirus relief funding in the American Rescue Plan Act (ARPA). 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). Consistently applied. Regulatory compliance audits determine whether the vendor is following all of the laws and regulations relevant to the goods and services they provide (e.g., environmental regulations). A cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. The vendor provided supporting documentation for the items or services on the invoice. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US For instance, data analysis can reveal patterns in payroll expenditures or purchasing, track whether employees are following policies and procedures, or measure staff or vendor performance. endstream endobj 560 0 obj <. For that reason it is not included in the Drop-in document. Suggestions are presented as an open option list only when they are available. This outlier may warrant further investigation. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. This blog post is published and posted online by the School of Government to address issues of interest to government officials. 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. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. Please include this language separately in the bid solicitation. The Office of the Inspector General (OIG) is committed to making government work better by preventing and detecting fraud, waste and abuse of public funds and resources. All documentation must be maintained for at least 5 years from the end of the award term. Implement internal controls to prevent fraud, waste and abuse. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. This course is targeted to finance and management staff of smaller and mid-sized units that will be taking the standard allowance and spending most, if not all, of their ARP/CSLFRF as revenue replacement. 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). 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. People often make business decisions based on intuition, anecdotes or institutional lore. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. State Government websites value user privacy. Each recipient should review program requirements, including Treasurys final rule and the recipients Award Terms and Conditions, to determine and record eligible uses of SLFRF funds. Determine if billings are accurate and in compliance with contract terms. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. The smallest incongruity could lead to the discovery of a large fraud. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. 11246. 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. %%EOF infrastructure, potential enhancements of state funding resources, Some online survey tools even analyze data for you. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. Conducting a survey can be as simple as sending out an email or using a free online survey tool. 128, 40064-40068. Share sensitive information only on official, secure websites. 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 vendor claimed that the lower per-unit price was only for bulk purchases. October 2017 Procurement Bulletin Article, Recently, our Office learned that a vendor included administrative fees in invoices issued to a housing authority under a revenue-generating contract. 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. 200.317, 200.322, and 200.326. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. The American Rescue Plan Act (ARPA), enacted in March 2021, provides state, county, local and tribal entities across the country with billions in federal aid to respond to the public health and economic effects of the COVID-19 pandemic. The ARPA program requires recipients to comply with the procurement provisions of Title 2, Part 200 of the Code of Federal For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. In the meantime, please feel free to contact us if you have any questions or ideas about data. The American Rescue Plan Act (ARPA) has brought millions in public dollars to cities, towns and other public entities to respond to the COVID-19 pandemic and its economic consequences. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. 179 0 obj <>/Filter/FlateDecode/ID[<598620AB2247954EBE922AD03988F6D9>]/Index[165 31]/Info 164 0 R/Length 86/Prev 341858/Root 166 0 R/Size 196/Type/XRef/W[1 3 1]>>stream For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. This page is located more than 3 levels deep within a topic. 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. 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. During this session, The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. Exceptions to requirements for small purchase or formal method competitive rules. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. In most cases, city procurement 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. 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. 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 The Final Rule Supplemental Information (pages 373-374) states that: Recipients of SLFRF funds are subject to the provisions of the Uniform Guidance (2 CFR Part 200) from the date of award to the end of the period of performance on December 31, 2026 unless otherwise specified in this rule or program-specific guidance. 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 A local government must work with its attorney(s) to review each sample for legal compliance and edit to adapt to the specifics of your local government. 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. When was the last time your client revised their procurement contracts? Massachusetts jurisdictions received over $25 billion through ARPA. 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. 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