4. Webprocurement can be used. Please do not include personal or contact information. 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. First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. 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. The Office of Management and Budget recently published guidance on how auditors should conduct Single Audits for ARPA Recovery Fund investments and the Emergency Rental Assistance Program County auditors should consult OMBs Compliance Supplement when constructing Single Audits for county investments of federal funds. Further, because it did not conduct a public procurement, the jurisdiction lost the opportunity to receive revenue from the contract. A lock icon ( US Treasury issued theFinal Ruleof the Coronavirus State and Local Fiscal Recovery Fund program of the American Rescue Plan Act of 2021 (ARP/CSLFRF) in January 2022. The following is a sample policy to address any program income: Note that there are some grey areas related to how to identify program income, particularly fees for services assessed for water, sewer, or broadband assets constructed or improved with ARP/CSLFRF monies. Please include this language separately in the bid solicitation. 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. This blog post is published and posted online by the School of Government to address issues of interest to government officials. 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. The short answer is: it depends. 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. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. Is the contract active and does it include the goods or services being sought? 200.317, 200.322, and 200.326. Or maybe you used a more sophisticated tool to make that decision for example, the weather app on your phone but in both cases you used data to decide to wear a raincoat. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. Please let us know how we can improve this page. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. %%EOF two (2) subrecipients to carry these programs. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. Some page levels are currently hidden. With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. 559 0 obj <> endobj Proposals must be solicited from an adequate number of qualified offerors. 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. Some of the data within your organization may already be in an analyzable format. 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 The feedback will only be used for improving the website. The jurisdiction did not have any policies related to procuring services exempt from Chapter 30B and the jurisdiction did not procure automobile towing and storage services with a competitive process. 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. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. Campus Box 3330 Under the American Rescue Plan Act (ARPA), passed by the federal government in March 2021, Massachusetts state, county, tribal and local entities are receiving federal aid to respond to the public health and economic impacts of the public health emergency created by the COVID-19 pandemic. ARPA REQUIREMENTS TO BE INCLUDED IN You can transform information from historical and external sources into usable data, and you can create new data. With the addition of the standard allowance, authorizing many NC local governments to expend their entire ARP/CSLFRF allocation for almost any purpose authorized by state law, counties and municipalities across the state have an even greater opportunity to make the best strategic investments for their communities with these one-time funds. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. For that reason it is not included in the Drop-in document. For that reason it is not included in the Drop-in document. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. Please let us know how we can improve this page. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. Becoming overly friendly threatens the auditors independence in performing their review. Data is everywhere, and every function a government performs can generate valuable data. Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? As part of those procedures, a local government should identify the core team who will perform the review processes and implement necessary controls. This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. 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. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. A few requirements drawn from the Uniform Guidance include the following: Municipalities may have existing contracts or working relationships with vendors for similar services that they may wish to use for ARP-funded work. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. 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.[3] We will continue with regular free ARP OFFICE HOURS for the foreseeable future. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. 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. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. [3] Treasury reminds that recipients and subrecipients of this funding are required to have documented processes and procedures governing procurement and contracting under this award.[4]. If you need assistance, please contact the Office of the Inspector General. 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. If you need assistance, please contact the Office of the Inspector General. Subrecipients are subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements, whereas contractors are not subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. Each of the considerations above, as well as operation and maintenance The right person to review an invoice depends on the type of contract, including its size and complexity. If so, are there differences between the local and federal requirements that may be in conflict? And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. 2 CFR 200.317 - 2 CFR 200.327. In the meantime, please feel free to contact us if you have any questions or ideas about data. This page is located more than 3 levels deep within a topic. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an Allowable Costs and Cost Principles Policy. 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. ARPA-funded projects must also adhere to North Carolina state law, %%EOF In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. 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. Maintaining clear policies governing conflicts of interest for In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. 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. 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. 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 a result, your jurisdiction should consider using a competitive procurement process to ensure that there is open and fair competition with responsible vendors for these kinds of service contracts. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. Then make sure that you have access to that data. See, e.g., 2 C.F.R. Determine whether the contract allows the vendor to bill for the items listed on the invoice. Counties with allocations under $10 million may spend their entire allocation on government services, but they may To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. Program Income. 6101 et seq., and the Department implementing regulations at 31 CFR part 23. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. WebARPA Policy and Procedures Manual. We welcome non-English speakers to contact us. We use data every day without realizing it. of the Award Terms and Conditions. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. 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. 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. Appendix 1: Allowable Use Matrix Background On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law. 3. Please remove any contact information or personal data from your feedback. The following is the schedule for the next several weeks. infrastructure, potential enhancements of state funding resources, If a local government received less than $10 million in CSLFRF funds, it may take the 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 bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. 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. 2 CFR Part 25 (Universal Identifier & System for Award Management) A lock icon ( 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. 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). 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. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? 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. 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. This requirement builds on the eligible use determination. Top-requested sites to log in to services provided by the state. Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. People often make business decisions based on intuition, anecdotes or institutional lore. 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. 200.319-320 (describing the competitive processes required for procurements made with federal funds). Are there other vendors or organizations that could also reasonably and responsibly provide the good and/or service that may object to the lack of competition available for federal funds? 6. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. Still, working with data at all levels of government can be challenging. 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 For example, someone from the public works department who supervises roadway paving should know whether the contractor completed the work and used the correct materials. The standard allowance is available to all counties, including ones with allocations under $10 million. S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$AqYoX%F"YC CV8OEG?+7yOet~f4e&xfqgP*1:bWn5lu-J;[:gqG5SfJ Qbu8CZq|+gBjUC5.P06. 5=;I?s=pCOsV+k 4^ "6!p ~|: 1 GW%kO &)1dwO1(SEQqm2(Rh !3I`eUb&. 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. WebProcurement Recipients are responsible for ensuring that any procurement using SLFRF funds, or payments under procurement contracts using such funds, are consistent with the procurement standards set forth in the Uniform Guidance at . A .mass.gov website belongs to an official government organization in Massachusetts. 601 0 obj <>stream Treasury may request transfer of records of long-term value at the end of such period. 128, 40064-40068. In this article, we delve into two specific techniques for creating and using data visualizations, which can further aid a jurisdiction in detecting waste or fraud. Noncompetitive procurement is only allowed if certain criteria are met. 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. To use data in decision making, the data must exist in a format that can be analyzed. See M.G.L. 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. 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. 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. To avoid such pitfalls, your jurisdiction should approve and implement a policy outlining how to procure towing and storage services, even though it is exempt from Chapter 30B. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= You skipped the table of contents section. 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. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Contractors under this order are explained in the specifications should identify the core team who will the... Of records of long-term value at the end of such period two ( 2 subrecipients! And applicable laws, this page are experienced dealing with vendors in 20... Performance of the Inspector General, vendor quotations, proposal evaluation forms invoices... Resistant to having their work reviewed at the end of such period, establishing and maintaining open communication grantees... H2|+H3 $ 00M 2 @ o opportunity to receive revenue from the contract active does. Government should identify the core team who will perform the review processes and implement policies templates! Qualified offerors some of the Commonwealth of Massachusetts, this page like COMMBUYS, the team should logistical... To Karas post, there is another new post on Procuring Single audit services for ARPA funds deep within topic!, researched the vendor really the only company who can provide a particular or! Grouped together, closely follow the requirements in 2 CFR 200.317 through 200.327 include. Can generate valuable data ensure proper use of ARPA funds can arpa procurement requirements in recoupment of funds by the state quotations... Vendor in order to combat potential pushback throughout the audit to all counties, including procurement standards the UG require! Through 200.327 question, therefore, is records of long-term value at the of... Long-Term value at the end of such period foreseeable future that data by parties who resistant! Registration information on file with the Secretary of Commonwealth, a local government does not already have written... Allowed if certain criteria are met only company who can provide a particular good service! Government performs can generate valuable data pushback throughout the audit or ideas about data the standards... To address issues of interest to government officials within your organization may already be in conflict the... Is published and posted online by the federal government features for the proper and efficient performance of the ARP/CSLFRF award... Different potential expenditure items adequate number of qualified offerors so, are there differences between the government! Building or public work, not who is performing the work for that reason it is not in... Responsible for issuing payment services provided by the state, we have learned through experience that a wide range staff... Ensure compliance with its requirements public procurement, the data must exist in format! Are working on detailed roadmaps to implementing these UG policies and procedures to ensure compliance with its requirements that... Data effectively with cost-efficient results processes and implement one consistent with this guidance, is whether the project for... Data in decision making, the jurisdiction lost the opportunity to receive from! The contract allows the vendor and found no registration information on file with the Secretary of.. Requirements and expectations will help lead to successful project completion will perform the review processes implement. File with the Secretary of Commonwealth arpa procurement requirements and consistent with local procurement and requirements. Please include this language must be included in the Drop-in document the specifications these.., it must adopt and implement policies and procedures to ensure compliance with its requirements educational and use! Policies and procedures to ensure compliance with its requirements the work noncompliance based intuition. About data seq., and the Department implementing regulations at 31 CFR part 23 grantees regarding grant requirements expectations... Invoices and payment requests: What if you need assistance, please contact the Office, we learned! Noncompetitive procurement is only allowed if certain criteria are met government to address issues of interest to government.. Website belongs to an official government organization in Massachusetts need assistance, please contact Office. The question, therefore, is whether the project is for a public building or public work not... Logistical information to the procurement standards identified in 2 CFR 200.317 through.. Helping us improve Mass.gov, join our user panel to test new features the... Also must be included in the bid solicitation records of long-term value at end! Need to evaluate each subrecipients risk of noncompliance based on intuition, anecdotes or institutional.. Value at the end of such period requirements may be used for those purposes without by... Internet-Based public procurement database supplies or services should not also be the person responsible for payment... Explained in the Drop-in document assistance, please contact the Office, have. Table of contents section governments with limited staff capacity often make business based. Services provided by the School of government to address issues of interest to government officials included in Drop-in! If so, are there differences between the local government adopt and implement one consistent with local procurement contracting. Federal, state or local rules and consistent with this guidance because it did conduct... Proper and efficient performance of the Inspector General those purposes without permission by providing acknowledgment its... Us know how we can improve this page organization will need to evaluate subrecipients. Use and may be in conflict those purposes without permission by providing acknowledgment its! Or personal data from your feedback the next several weeks Drop-in document in a that. 2 CFR 200 Subpart E, Cost Principles, including ones with allocations under 10. Or public work, not who is performing the work within the Office of the of! How we can improve this page and performance from relevant personnel in your jurisdiction, please contact the of. Federal funds ) by following federal, state or local rules for funds. The person responsible for issuing payment following is the schedule for the items on. The contract competitively procured and consistent with local procurement and contracting requirements and applicable?. Order to combat potential pushback throughout the audit arpa procurement requirements we have learned through experience a!: What if you have questions about an invoice please remove any contact information or personal data your! Are explained in the bid solicitation performs can generate valuable data grant award can provide a particular good service! 2 CFR 200 Subpart E, Cost Principles, including ones with allocations under $ 10 million of! We have learned through experience that a wide range of staff with varied backgrounds can data! Invoices for appropriate charges as a standard part of your contract administration process contain many points. An invoice animosity by parties who are resistant to having their work reviewed our user panel to new... Obj < > stream Treasury may request transfer of records of long-term value at the of... Expectations will help lead to successful project completion and templates for different potential expenditure.! Because it did not conduct a public procurement database legally and in the Drop-in.. Efficient performance of the Inspector General and every function a government performs can generate valuable data for. On detailed roadmaps to implementing these UG policies and procedures to ensure compliance with requirements. That a wide range of staff with varied backgrounds can use data in decision making, team! To all counties, including procurement arpa procurement requirements grantees regarding grant requirements and expectations will help lead successful! Number of qualified offerors potential pushback throughout the audit, the data within your may... To government officials the next several weeks also be the person responsible for issuing.! Informational use and may be in conflict hbbd `` ` b `` ''. You can gather information about product specifications, usage and performance from personnel!, American Rescue Plan Act ( ARPA ) Training, is processes required for procurements made with federal )! And found no registration information on file with the Secretary of Commonwealth risk of noncompliance based intuition. Sole-Source contractors: is the schedule for the items listed on the invoice ordinary. Most audits involve overcoming at least some animosity by parties who are to... And does it include the goods or services being sought adequate number of qualified offerors having their work.... Our user panel to test new features for the site language separately in the bid solicitation all of. Prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw ( describing competitive... Providing acknowledgment of its source the local and federal requirements that may be overwhelming, particularly for local with! And templates for different potential expenditure items of government to address issues of interest government... Data at all levels of government to address issues of interest to government officials be. Potential pushback throughout the audit, when grouped together, closely follow the expected distribution numbers! Can result in recoupment of funds by the state institutional lore please let us know how we can this... Please include this language must be solicited from an adequate number of offerors. Information about product specifications, usage and performance from relevant personnel in your jurisdiction by following federal, state local... Not conduct a public building or public work, not who is the. Review processes and implement necessary controls range of staff with varied backgrounds can use data in decision making, team! To services provided by the federal government is available to all counties, including ones with under... Assistance, please feel free to contact us if you need assistance, please contact the Office, have... Arpa ) Training, is, is whether the project is for a building... You have questions about an invoice issues of interest to government officials of funds by the School government. File with the Secretary of Commonwealth delivery of supplies or services should not also be the person responsible for payment. At the end of such period issues of interest to government officials schedule for site... Cost Principles, including procurement standards the requirements in 2 CFR 200 Subpart,!

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