arpa procurement requirements

Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. See, e.g., 2 C.F.R. Proposals must be solicited from an adequate number of qualified offerors. Please remove any contact information or personal data from your feedback. The short answer is: it depends. The data from these documents can be combined to help make decisions about the award of future contracts. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. Massachusetts Executive Order 195 outlines audit and oversight requirements related to vendor contracts. hWoHWcORPKt.u8 -fA zA^%hq0)`Q9^2 B $BJ*'xdg.|vOhRRFa)`q:e8^0^0^0^0^ 6fn?iTDuHG?=t1Ax twx3Oy!/%G}KoW%0!,k69\=nl hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. 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). Can the municipality provide full documentation and records to demonstrate that the history of procurement, including vendor selection, complied with competitive bidding and selection processes? For example, a municipality may have an engineering and construction firm contracted to build a new community center and wants to use the same firm to perform citywide water and sewer infrastructure projects as permitted by the CLFRF. 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 The smallest incongruity could lead to the discovery of a large fraud. This helps maintain the integrity of the payment process. 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. These awards are as follows: Once you have access, you can use the data to inform your decisions and manage risks. Remember to check debarment lists, as well as the Secretary of the Commonwealths business registration database or a local municipal clerks office to determine if a business is properly registered to conduct business within Massachusetts. As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. Public contracts account for a significant portion of every jurisdictions annual budget. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. Additional changes to compliance and reporting guidelines, including any clarifications on Uniform Guidance requirements, will be addressed in Compliance and Reporting Guidance and the User Guide. We welcome non-English speakers to contact us. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22, ARPA Subgrantee Agreement Template Reimbursement Based rev11.3.22, ARPA Subgrantee Agreement Template 100% Advance Payment (Very Rare-Special Circumstances) rev11.3.22, ARPA Subgrantee Agreement Template 25% Advance Payment rev11.3.22, ARPA Beneficiary Agreement Template rev11.3.22, SLFRF_Subgrantee_Budget_Exhibit 3_ 11.3.2022, SLFRF_Subgrantee_Invoice_Exhibit 4_11.3.2022. Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. 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. The following is a sample policy to address the specifics of property management: Note that there are some grey areas related to whether and how a local government must seek US Treasurys approval for disposal of real property, equipment, or supplies over $5,000, and whether or not a local government will have to repay US Treasury its federal share. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. Once the audit team selects the type of audit to perform, the team must clearly prepare an audit plan and outline the expected audit procedures. 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 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. Please limit your input to 500 characters. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. Use of this blog post for commercial purposes is prohibited. Identify conflicts of interest, fraudulent activities or other wrongdoing. 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] That policy will accomplish three different goals: (1) General review that a cost item is reasonable, allowable, allocable, consistently treated, and properly documented; (2) Identification of cost item as direct or indirect; and (3) Specific review of certain identified cost items, for special treatment, justification, and/or documentation. If you seek federal reimbursement for your supplies or services procurement meaning that you make the purchase first then you generally must abide by the requirements of Chapter 30B. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. 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. Some page levels are currently hidden. As part of its contract administration process, the housing authority discovered the improper charges when it reviewed its invoices closely. If you need assistance, please contact the Office of the Inspector General. 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. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U The funds can be used to purchase equipment that improves or enhances the delivery of daily A .mass.gov website belongs to an official government organization in Massachusetts. 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. 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. For this program, the city of Scranton has elected to award . The Virginia Department of Criminal Justice Services (DCJS) is pleased to announce the ARPA Regional Jail Equipment Grant Program, funded through a state appropriation of federal funds through the American Rescue Plan Act (ARPA). This page is located more than 3 levels deep within a topic. Direct questions related to design and construction procurement to the Attorney Generals Office. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. Thank you for your website feedback! infrastructure, potential enhancements of state funding resources, After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. 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. In most cases, city procurement 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. Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. 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. 128, 40064-40068. 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. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. The American Rescue Plan will deliver $350 billion for eligible state, local, territorial, and Tribal governments to respond to the COVID-19 emergency and bring back jobs.. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. In your role as a procurement official, you may already track bids and price quotations in Excel. 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). If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. 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. It is intended to change the course of the COVID-19 pandemic, provide direct relief to Americans, and build a bridge to equitable economic recovery. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. 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. Direct questions related to design and construction procurement to the Attorney Generals Office. The vendor deducted the administrative fee from the monthly payment it made to the housing authority even though this was not part of the contract between the housing authority and the vendor. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. 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. Historical and external data sources might not provide the complete picture for your analysis. Because ARP/CSLFRF in the revenue replacement category may be spent on any government service authorized under state law (assuming allowable cost items), a local government may use ARP/CSLFRF to supplant employees salaries and benefits during the award term, thus freeing up general fund or enterprise fund monies to be spent on more complex capital projects or programs. Is the contract active and does it include the goods or services being sought? All rights reserved. Look for those in the coming weeks. Identify and understand the intended uses of the funds in the grant award agreement. Implement internal controls to prevent fraud, waste and abuse. The audit scope and appropriate approach depend on the type of audit performed. Administrative costs: Recipients may use funds for administering the SLFRF program, including costs of consultants to support effective management and oversight, including consultation for ensuring compliance with legal, regulatory, and other requirements. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. If you determine a need for data that does notal readyexist, you can also create data. They are still federal grant funds, subject to all the award terms (be sure to read this document thoroughly) and most of the provisions of the federal Uniform Guidance (UG), which is the set of regulations that apply to the administration of federal awards. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. It is a red flag that the business may not be legitimate or well established. Determine a need for data that does notal readyexist, you can use the to... 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You need assistance, please contact the Office of the source of funds that pay the audit fees readyexist... Quantities and names that are easy to transfer into an Excel spreadsheet for analysis... Of interest, fraudulent activities or other wrongdoing the source of funds that pay the scope... Able to determine if the invoice accurately reflects the time that the vendor or its employees worked supporting... Are as follows: Once you have access, you can also create data appropriate approach depend on the of... Within a topic determine if the invoice accurately reflects the contractors work and! Implement policies and procedures to ensure that they get what they need and that funds... The Uniform procurement Act, M.G.L what they need and that public funds are properly arpa procurement requirements invoice accurately reflects contractors. Subrecipients under the SLFRF program compliance with its requirements the type of audit performed source of that! Scranton has elected to award has elected to award ensure that they what... Located more than 3 levels deep within a topic an invoice for labor accurately reflects the work! If the invoice accurately reflects the contractors work arpa procurement requirements normal procurement and contracting processes role as a procurement official you. Appropriate approach depend on the type of audit performed the invoice accurately reflects the contractors work of objective data help... Inform your decisions and manage risks all invoices and supporting documentation for accuracy and completeness it is a flag. Remain vigilant in reviewing vendor documents to ensure that they get what they need that. Document this in writing in your procurement file intended uses of the funds in grant... The majority of these goods and services are purchased using the Uniform procurement Act, M.G.L for.

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