BenfordsLaw is best applied to large data sets (at least several hundred records) of naturallyoccuringnumbers with some connection, such as population data, income tax data or scientific data. 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. ARPA REQUIREMENTS TO BE INCLUDED IN Tie grant disbursements to deliverables, milestones or other reportable actions when possible. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. Capital Funds Project website. Finally, in addition to my colleagues Rebecca Badgett, who drafted some of the above UG policies, and Connor Crews, who is working on procurement and conflict of interest policies, we want to thank our two amazing research assistants, Tiffany Oliva and Abby Gostling, who drafted several of our templates and other tools. The standard allowance is available to all counties, including ones with allocations under $10 million. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. 128, 40064-40068. The prevention and detection of fraud, waste and abuse of public funds always an important issue for government entities is even more critical now that jurisdictions are receiving billions of additional dollars in ARPA funding. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. Require regular and thorough reporting from grantees relating to expenditures. For this program, the city of Scranton has elected to award . 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. We will use this information to improve this page. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. The Office of the Inspector General (OIG) is committed to making government work better by preventing and detecting fraud, waste and abuse of public funds and resources. 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 Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. 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. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of Exceptions to requirements for small purchase or formal method competitive rules. Chapel Hill, NC27599-3330 Please include this language separately in the bid solicitation. Process compliance audits evaluate whether the vendor is doing what it was hired to do. This can lead to drawing incorrect conclusions about the data and documentation available. 2 CFR 200.320(c). The following are sample policies and other implementation tools for many of these award terms and UG requirements. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. of the Award Terms and Conditions. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. Also, remember the following: 1. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. Purchases made directly from the federal government are exempt from Chapter 30B. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. 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. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Are you missing any data that would help you monitor utilization? These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. 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. The short answer is: it depends. And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. People often make business decisions based on intuition, anecdotes or institutional lore. Direct questions related to design and construction procurement to the Attorney Generals Office. There are many reasons to audit contracts with vendors and suppliers. [2] 2 CFR 200.317-327, available at https://www.govregs.com/regulations/title2_chapterII_part200. A local jurisdiction recently sought guidance from the Office related to the procurement of towing and storage of motor vehicles. contact the Office of the Inspector General. ) or https:// means youve safely connected to the official website. Further, a prequalification or screening process for vendors interested in providing certain services, such as towing and storage, helps ensure that the public is receiving services from a qualified vendor at a reasonable price. Treasurys implementing regulations, 31 CFR part 22, and the Department of Justice (DOJ) regulations, Coordination of Non-discrimination in Federally Assisted Programs, 28 CFR part 42, provide for the collection of data and information from recipients (see 28 CFR 42.406). The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. The first step in implementing a vendor audit program is determining who to audit. ) or https:// means youve safely connected to the official website. The words data and data-driven decision-making sound daunting; however, neither is something new. We use data every day without realizing it. 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. A compliance audit is the overarching term for ensuring that a vendor is complying with the terms of a contract. Massachusetts jurisdictions received over $25 billion through ARPA. As mentioned below, we are working on detailed roadmaps to help local governments know when/how to implement each policy based on specific expenditure decisions. The OIG is developing classes to introduce local officials to specific data analysis techniques. To promote appropriate and effective use of ARPA funds, jurisdictions should: Jurisdictionsshould also develop evidence-based methods of measuring performance and project goals to make sure that grantees meet those expectations. 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. Municipalities should also be prepared to justify and document the selection of the MOU or MOA as the most appropriate, reasonable, and cost-effective method to provide services utilizing ARP funds. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. Please do not include personal or contact information. Below are a few examples of the range of schemes that vendors may engage in. 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. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a 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). Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. Webprocurement can be used. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. 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. WebSourcing & Procurement. Once you have access, you can use the data to inform your decisions and manage risks. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. To start, here is a summary list of UG policies and their triggers. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. 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. 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. endstream endobj startxref ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee 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. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022 a to. 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