SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. Consistently applied. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Government entities that have received ARPA funding may be able to award grants to third parties. 128, 40064-40068. Restricting access to the submitted bids. If you are used to having a financial statement audit, a single audit can be much more comprehensive. Then make sure that you have access to that data. 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 Please let us know how we can improve this page. 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. 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. The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. Fraud, waste and abuse can occur even when comprehensive contracts are in place. infrastructure, potential enhancements of state funding resources, 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. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. In the meantime, please feel free to contact us if you have any questions or ideas about data. Please limit your input to 500 characters. 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. 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. Recipients that receive an aggregate amount of federal financial assistance in a given fiscal year that exceeds the Single Audit threshold are subject to the requirements in 2 CFR 200 Subpart F, Audit Requirements, unless Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. Incorporate by reference any federal rules that apply to the grant award. 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. 2000d-1 et seq., and the Departments implementing regulations, 31 CFR part 22; Section 504 of the Rehabilitation Act of 1973 (Section 504), Public Law 93-112, as amended by Public Law 93-516, 29 U.S.C. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US 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. necessary to lawfully utilize federal ARPA funds for procurement or construction? This information is invaluable to managers. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. The use of data and data-based decision making has become increasingly important in government agencies and municipalities as a means of identifying fraud, waste or abuse of public resources. External sources are another area from which data can be gathered and used in an analysis. A local jurisdiction recently sought guidance from the Office related to the procurement of towing and storage of motor vehicles. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. Knapp-Sanders Building 2 CFR Part 25 (Universal Identifier & System for Award Management) 3) Consider publishing all sole source requests for public notice. Identify and understand the intended uses of the funds in the grant award agreement. For example, the city of Boston used ARPA fiscal recovery funds to award more than $3.4 million in grants to 192 local arts and cultural organizations. 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. All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. Mayor Smiley wants to hear from you! 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. A .mass.gov website belongs to an official government organization in Massachusetts. c. 30B, 1(f). Still, working with data at all levels of government can be challenging. Public contracts account for a significant portion of every jurisdictions annual budget. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. For example, in the scatter plot below, each of the points represents one contract. When was the last time your client revised their procurement contracts? The following is a sample policy: Recordkeeping Requirements. Please do not include personal or contact information. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. 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. 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. 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. This requirement builds on the eligible use determination. Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. 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. A lock icon or https:// means youve safely connected to the official website. You must ensure that the vendors you are doing business with are legitimate and responsible. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. ARPA REQUIREMENTS TO BE INCLUDED IN Identify conflicts of interest, fraudulent activities or other wrongdoing. The short answer is: it depends. 0 In 2019 alone, for example, MassDOT issued nearly 200 construction and maintenance contracts with a combined cost of over $1.2 billion. Review for compliance with federal procurement law requirements. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. 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. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. 0 To start, here is a summary list of UG policies and their triggers. %%EOF Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. 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. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. Establish attainable program goals and targets, and understand which expenditures are allowable under federal law. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. two (2) subrecipients to carry these programs. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. 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 instance, recipients should note that SLFRF funds may not be used as the non-federal share for purposes of a states Medicaid and CHIP programs because the OMB has approved a waiver from this provision as requested by the Centers for Medicare & Medicaid Services pursuant to 2 CFR 200.102 of the Uniform Guidance and related regulations. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ Recipients that receive an aggregate amount of federal financial assistance in a given fiscal year that exceeds the Single Audit threshold are subject to the requirements in 2 CFR 200 Subpart F, Audit Requirements, unless otherwise specified in program-specific guidance. 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. A lock icon ( 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. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. Please let us know if you have any questions! This page is located more than 3 levels deep within a topic. These practices will also ensure that ARPA funding is used for its intended purpose: helping communities recover from the devastating health and economic impacts of the COVID-19 pandemic. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. 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). 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. Require regular and thorough reporting from grantees relating to expenditures. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. 128, 40064-40068. For that reason it is not included in the Drop-in document. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. 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. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. Accordingly, your organization should develop written policies and procedures for subrecipient monitoring and risk assessment and maintain records of all award agreements identifying or otherwise documenting subrecipients compliance obligations. To assist you with overcoming this challenge, the Office of the Inspector General will publish a series of articles to help demystify data analytics and its uses. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Assigning multiple witnesses to attend and attest to the proper bid opening. Please remove any contact information or personal data from your feedback. 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. 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