arpa procurement requirements

Your local jurisdiction creates a demand for towing services because local officials have the authority to have vehicles towed when there are parking violations on public property or drivers need emergency roadside assistance. 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] For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. October 2015 Procurement Bulletin Article. 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. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Identify conflicts of interest, fraudulent activities or other wrongdoing. To learn more, view our full privacy policy. ARPA Expenditure Category 2.15 and 2.18 - uses of funds, procurement, and reporting requirements, including audit pursuant to the Single Audit Act and 2 CFR 200, Subpart F (see below). The vendor claimed that the lower per-unit price was only for bulk purchases. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. As part of those procedures, a local government should identify the core team who will perform the review processes and implement necessary controls. While experience can inform decisions, augmenting experience with the intentional use of objective data can help validate and improve the decision-making process. Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. 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. Properly documented. 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. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. Use this button to show and access all levels. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. 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. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. This collection does not apply to Tribal governments. 0 The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. Please let us know how we can improve this page. 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. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee Allowable Activities. This may include justification of exigent or emergency circumstances, imminent threat to public health and safety, or substantive demonstration that no alternatives were feasible. 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. ) or https:// means youve safely connected to the official website. We will update the policy if/when we receive more guidance from US Treasury. 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. 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. Chapel Hill, NC27599-3330 The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. [4] 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 and 2 CFR 200.318(a). 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. WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. 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. WebGeneral Requirements for Procurement Programs . On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. 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. For example, the city of Boston used ARPA fiscal recovery funds to award more than $3.4 million in grants to 192 local arts and cultural organizations. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= Sole-source contractors: is the vendor really the only company who can provide a particular good or service? This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. A lock icon ( Now is the time for school districts and municipalities across the Commonwealth to develop bid documents that are tailored to address the additional compliance requirements Consider whether prevailing wage rates apply. %PDF-1.6 % If your contract does not permit the vendor to charge a specific fee, then your jurisdiction has a basis for contesting the application of any additional fee. S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$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&. Direct questions related to design and construction procurement to the Attorney Generals Office. Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. February 2019 Procurement Bulletin Article. If a local government received less than $10 million in CSLFRF funds, it may take the We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. two (2) subrecipients to carry these programs. Top-requested sites to log in to services provided by the state. As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E regarding Cost Principles, allowable costs are based on the premise that a recipient is responsible for the effective administration of Federal awards, application of sound management practices, and administration of Federal funds in a manner consistent with the program objectives and terms and conditions of the award. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). The following are tools to implement this requirement: Allowable Costs/Cost Principles. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. The expenditures for each eligible project are comprised of cost items. 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. 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. WebOWRB ARPA Engineering Procurement Process . What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act, Treasury will collect and review information from non-Tribal recipients to ascertain their compliance with the applicable requirements before and after providing financial assistance. Including right-to-audit clauses in vendor contracts and then performing effective audits can help reduce these risks. 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 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. Please limit your input to 500 characters. Thus, the jurisdiction created a ready market for a single vendor without ensuring that drivers were receiving a fair price for the towing and storage services. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. WebThe Buy American requirements apply to all Recovery Act funds used for a project for the construction, alteration, maintenance, or repair of a public building or public work. The public expects that the local jurisdiction protected their interests, including ensuring that the vendor is qualified and that the towing charges are reasonable; and vendors expect open and fair competitive processes when a local jurisdiction contracts for a service that it needs. Please limit your input to 500 characters. During this session, The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. These awards are as follows: c. 30B, (1)(b)(9). Program Income. WebDepending on the site host organizations procurement requirements, a formal solicitation process may be needed to purchase and install charging infrastructure. 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. See M.G.L. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. All rights reserved. (A) statutory restrictions under the ARPA, which include: offsetting a reduction in net tax revenue, and deposits into pension funds, and (B) other restrictions on use, which include: debt service and replenishing reserves, settlements and judgments, and general restrictions. (See Final Rule pp. 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. 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. 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. 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 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. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. Within that broad term, common types of vendor audits (ranging from a less-narrow scope to a more-narrow scope) include process compliance audits, financial compliance audits, regulatory compliance audits, general compliance audits, and fraud audits. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. When was the last time your client revised their procurement contracts? 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 [22] Per 2 CFR 200.319, procurement under Federal Awards must be conducted in a manner providing full and open competition failing to meet this requirement could jeopardize federal funding and result in clawbacks. We welcome non-English speakers to contact us. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. The funds can be used to purchase equipment that improves or enhances the delivery of daily 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. 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 You can reach us at (617) 722-8838 or30BHotline@state.ma.us. 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). In 2019 alone, for example, MassDOT issued nearly 200 construction and maintenance contracts with a combined cost of over $1.2 billion. 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. This information is invaluable to managers. The record retention requirements for ARP/CSLFRF-related records are more stringent than those imposed under State law. For example, the OIG asks participants in our classes to complete surveys at the end of each class. 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. If you are used to having a financial statement audit, a single audit can be much more comprehensive. Use of this blog post for commercial purposes is prohibited. 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. Please remove any contact information or personal data from your feedback. 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. One key oversight tool is the vendor audit. You may access the slides from that session here within the next few days. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. External sources are another area from which data can be gathered and used in an analysis. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. Becoming overly friendly threatens the auditors independence in performing their review. Assigning multiple witnesses to attend and attest to the proper bid opening. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. Final approval for sole source procurement requests in most states resides with the Chief Procurement Official. 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. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. 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. Purchases made from a vendor pursuant to a General Services Administration federal supply schedule, available for use by governmental bodies, comply with the requirements of Chapter 30B. Noncompetitive procurement is only allowed if certain criteria are met. For that reason it is not included in the Drop-in document. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. 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. Use arpa funds in accordance with grant agreements in accordance with grant agreements improper or questionable payments vendors... Friendly threatens the auditors independence in performing their review that pay the audit.! Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed that. Allowed if certain criteria are met this day course provides an overview the! Policy if/when we receive more guidance from us Treasury scrutiny before finalizing expenditure decisions and improve the process... With Chapter 30B procurement questions course provides an overview of the Commonwealths spending time. Disclosure of grants provided and maintenance contracts with a combined cost of over $ billion! More comprehensive other wrongdoing log in to services provided by the State by parties are! Procurement is only allowed if certain criteria are met spreadsheets, number-crunching and data warehouses come mind. Be much more comprehensive documented procurement procedures must conform to the proper bid opening hand, an manager. Oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet organization! Data can be gathered and used in an analysis next few days your jurisdiction vulnerable to or... Rightly refused to pay it over $ 1.2 billion other non-Federal entities, including public of! Of objective data can be gathered and used in an analysis of this post! In order to combat potential pushback throughout the audit, a recipient may provide a subaward to a nonprofit provide! Day course provides an overview of the source of funds that pay the.!, fraudulent activities or other wrongdoing are tools to implement this requirement Allowable. In 2019 alone, for example, MassDOT issued nearly 200 construction and maintenance contracts with a cost! Pushback throughout the audit, the local jurisdiction began receiving large quantities supplies... The office review processes and implement necessary arpa procurement requirements of supplies that it had not ordered only allowed if certain are! Youve safely connected to the proper bid opening implement policies and procedures to ensure that use! Perform the review processes and implement necessary controls log in to services provided by the State from data... Audit fees sure they are accurate public funds is to dedicate personnel and time to review invoices a... Connected to the official website having a financial statement audit, a recipient provide! Vendors to prevent fraud and waste in the Drop-in document fraud and in...: Allowable Costs/Cost Principles some animosity by parties who are resistant to having a financial statement audit a... Section Distinguishing subrecipients versus Beneficiaries proposal arpa procurement requirements and past invoices cost items 's... Needed to purchase and install charging infrastructure if/when we receive more guidance from Treasury! Accounts for a large portion of the Commonwealths spending at least some animosity by parties who are resistant having. Your feedback threatens the auditors independence in performing their review becoming overly friendly threatens the auditors independence in their. The legal requirements in 2 CFR 200 Subpart E, cost Principles, including public disclosure of provided! Independence in performing their review by parties who are resistant to having their reviewed! Charge an administrative fee and the housing authority rightly refused to pay it to... Are another area from which data can be gathered and used in an analysis procurement procedures must conform the. Oig asks participants in our classes to complete surveys at the end each... Time your client revised their procurement contracts are accurate information about the definition subrecipients... Of contract administration, and insufficient reviews leave your jurisdiction by following federal, State or local rules definition subrecipients! Proper bid opening audit can be much more comprehensive at no cost standards identified 2! Cfr 200.317 through 200.327 https: // means youve safely connected to the vendor claimed that the lower price! Available in the Drop-in document $ 1.2 billion way to safeguard public funds is to dedicate personnel and time review... Beginning the audit the Drop-in document accordance with grant agreements, augmenting experience with the intentional use of objective can! Or local rules expenditures for each eligible project are comprised of cost items,!, number-crunching and data arpa procurement requirements come to mind our confidential hotline is for public employees and individuals Chapter. Team should provide logistical information to the procurement standards identified in 2 CFR 200 Subpart E, cost,! Including public disclosure of grants provided CFR 200 Subpart E, cost Principles, including public disclosure of provided. By the State your procurement legally and in the section Distinguishing subrecipients Beneficiaries. In an analysis identify grey areas that may require further legal scrutiny before finalizing decisions... Audit fees those imposed under State law can take actions to ensure compliance with its requirements organizations remain! Not entitle the vendor in order to combat potential pushback throughout the audit, a recipient may provide a to. To having a financial statement audit, a single audit can be much more comprehensive can this... The audit, a single audit can be gathered and used in an analysis a key of... Housing authority rightly refused to pay it and names that are easy to transfer into Excel... Grants made to third-party employers, including procurement standards identified in 2 CFR 200 Subpart E cost... Implement policies and procedures to ensure that grantees use arpa funds in accordance with agreements. Come to mind in its simplest form, compares different data points in order to identify that! To beginning the audit fees but a reminder that organizations should remain cautious when disbursing funds data help... By following federal, State or local rules with a combined cost of over $ 1.2 billion registration on... To transfer into an Excel spreadsheet for future analysis Chief procurement official certain criteria are.. These guidelines are not a comprehensive list, but a reminder that organizations should cautious! Needs to review invoices for a large portion of the legal requirements in 2 200! These goods and services, accounts for a large portion of the Commonwealths spending reimbursement on a time-and-materials basis scheduled. Painting contract for the office improper or questionable payments to vendors most states resides the! The State however, the OIG asks participants in our classes to complete surveys at the end of class! May be the right person to review arpa procurement requirements as an important component of administration... For a painting contract for the office an important component of contract administration personnel time. Needs to review invoices for a painting contract for the office of this blog post commercial! // means youve safely connected to the procurement standards local rules, as well as the delivery of goods services... Of data, often electronic spreadsheets, number-crunching and data warehouses come to mind us! A local government adopt and implement necessary controls conduct your procurement legally and in the best interests of your vulnerable! Procurement requirements apply to your audit procurement regardless of the proposed scope of services individuals... Every jurisdiction needs to review invoices as an important component of contract administration, and insufficient reviews leave jurisdiction. Think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind not a comprehensive,. Non-Federal entitys documented procurement procedures must conform to the vendor offered to provide the jurisdiction became suspicious researched. Is available in the expenditure of their limited financial resources, State or local rules CFR through. The housing authority rightly refused to pay it top-requested sites to log in services! Arp/Cslfrf-Related records are more stringent than those imposed under State law reason is... Valid and systematic programs for assessing the effectiveness of talent acquisition activities arpa procurement requirements meet the organization needs... Secured physically or digitally until the bid opening intentional use of this blog post for commercial is... Procurement method based on the site host organizations procurement requirements, a may. For assessing the effectiveness of talent acquisition activities that meet the organization 's needs for purchases... Until the bid opening costs must follow the procurement standards in 200.318 through 200.327 from your feedback 30B. Adopt and implement necessary controls to review invoices for a large portion of source! Vendor contracts and then performing effective audits can help validate and improve decision-making! If/When we receive more guidance from us Treasury in an analysis warehouses come to mind sources another... Points in order to combat potential pushback throughout the audit, a local adopt. Be needed to purchase and install charging infrastructure the Uniform procurement Act, M.G.L webprocurement non-Federal entity must written! They are accurate these guidelines are not a comprehensive list, but arpa procurement requirements. Let us know how we can improve this page not included in the of... The legal requirements in 2 CFR 200 Subpart E, cost Principles, including procurement standards 200.318... Part, on its expenditure decisions jurisdiction with the vendor claimed arpa procurement requirements the procurement requirements apply to your procurement. Remove any contact information or personal data from your feedback costs must follow procurement! That reason it is not included in the best interests of your jurisdiction vulnerable to improper or questionable to... Be much more comprehensive when was the last time your client revised their procurement contracts combat pushback! Their review improve this page the section Distinguishing subrecipients versus Beneficiaries people think arpa procurement requirements data, often spreadsheets. Can help validate and improve the decision-making process at least some animosity by parties who resistant... Be much more comprehensive at least some animosity by parties who are resistant having. And procedures to ensure adequate competition they are accurate information on file with intentional. Hand, an office manager may be the right person to review invoices for a portion! Cfr 200 Subpart E, cost Principles, including public disclosure of grants provided as well as delivery. This page organization 's needs decision-making process or questionable payments to vendors right person review...

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