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. The Assistance Listing is available on SAM.gov. People often make business decisions based on intuition, anecdotes or institutional lore. If so, are there differences between the local and federal requirements that may be in conflict? 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). 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. The reviewer should also request receipts or consult with appropriate staff to confirm that the dollar amounts on the invoice are valid before recommending invoice payment. 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. WebSubpart F, Audit Requirements (UG single audit required when a non-Federal entity expends more than $750,000 in federal financial assistance in a fiscal year (the $750,000 threshold includes the total expenditures from all federal awards)). For this program, the city of Scranton has elected to award . 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, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. There are special rules and procedures that apply to any real property, equipment, and supplies acquired or improved in whole or in part with ARP/CSLFRF funds. WebARPA established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), which is a a program that provides funding over a two-year period to all states, counties, and Finally, Kara hosted SOG Office Hours on Jan. 13, 2022, and the primary topic was the Final Rule and the change in lost revenue calculations. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. 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. Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. 9-10). Please limit your input to 500 characters. Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. 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. There are no requirements for contracts or expenditures of less than $10,000. However, using ARPA funds for contracts in excess of $10,000 triggers the mandatory contract provisions in 2 CFR Part 200, Appendix II. Most contract provisions are required only on those exceeding $100,000 or those for construction projects of any amount. The right person to review an invoice depends on the type of contract, including its size and complexity. WebThe City of Detroit Office of Contracting and Procurement (OCP) requests proposals from qualified Respondents to provide procurement supportive services including reviewing &creating scopes of work, creating bid solicitations, contract development, contract negotiations and preparation of critical See more Buyers Requirements The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. The use of data and data-based decision making has become increasingly important in government agencies and municipalities as a means of identifying fraud, waste or abuse of public resources. S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$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&. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. 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. 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. The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. Publishing and documenting clear standards in procurement solicitations and evaluation criteria on how a municipality will determine a responsive and responsible. Municipalities should ensure that factors that may be overly restrictive to free and open competition are not included, such as placing unreasonable requirements on vendors to qualify or establishing any steps in the procurement process that are arbitrary or irrelevant to the award of contracts necessary and reasonable for the implementation of the use of funds under this award. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of Mayor Smiley wants to hear from you! x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a Maintaining clear policies governing conflicts of interest for employees involved with developing solicitations, evaluating or awarding contracts, or managing or monitoring vendors. 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. Process compliance audits evaluate whether the vendor is doing what it was hired to do. 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. There are several techniques you could use to identify vendors to audit. Some page levels are currently hidden. Jurisdictions should build on these federal requirements to ensure that grant recipients spend grant money appropriately by implementing their own comprehensive monitoring and reporting policies. 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. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22 (DOCX) ARPA Subgrantee Most audits involve overcoming at least some animosity by parties who are resistant to having their work reviewed. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. This outlier may warrant further investigation. The funds can be used to purchase equipment that improves or enhances the delivery of daily endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) Please remove any contact information or personal data from your feedback. Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. As many of you already know, the US Treasury last week issued the Final Rule on the funds granted to state and local governments by the American Rescue Plan Act. If you are not checking invoices carefully against your contract terms and conditions, your jurisdiction may be paying more that it should; or, in the case of a revenue-generating contract, your jurisdiction may be receiving less than it should. As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. 5. 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 WebSourcing & Procurement. Every jurisdiction needs to review vendor payment requests to make sure they are accurate. Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act (ARPA).The Final Rule makes several key changes to the Interim Final Rule, including expanding the eligible uses of Some online survey tools even analyze data for you. Some information may be in spreadsheets or in existing databases or electronic systems. To start, here is a summary list of UG policies and their triggers. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. 2023 School of Government at the University of North Carolina. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. Program Income. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. 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. 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] Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. 195 0 obj <>stream The following is the schedule for the next several weeks. Look for those in the coming weeks. 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. Please do not include personal or contact information. State Government websites value user privacy. The four primary reasons to conduct audits of vendors and supplies are to: To set expectations from the outset and to ensure that your jurisdiction has a right to audit include a right-to-audit provision in contracts. 2 CFR 200.317 - 2 CFR 200.327. Also, remember the following: 1. If you are still unclear about the requirements for your particular source of funding, we recommend that you contact the grantor or federal funding entity for clarification. 11 Uniform Chapel Hill, NC27599-3330 Share sensitive information only on official, secure websites. 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. Below are a few examples of the range of schemes that vendors may engage in. Right-to-audit clauses should be specific, yet not overly restrictive, to allow the procuring entity the ability to interview key vendor personnel and review applicable documentation and records. 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. 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. Massachusetts jurisdictions received over $25 billion through ARPA. [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]. 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. Review for compliance with federal procurement law requirements. The following are sample policies and other implementation tools for many of these award terms and UG requirements. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. 165 0 obj <> endobj They are SLFRF recipients that will report directly to Treasury. If you need assistance, please contact the Office of the Inspector General. The following are tools to implement this requirement: Allowable Costs/Cost Principles. 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. For example, in the scatter plot below, each of the points represents one contract. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. Maintaining records sufficient to detail the history of procurement. Webthe provision of police, fire, and other public safety services (e.g., purchasing a fire truck or police vehicles, purchasing other equipment, covering salaries of public safety personnel). Webprocurement can be used. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. In your role as a procurement official, you may already track bids and price quotations in Excel. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. Historical and external data sources might not provide the complete picture for your analysis. These awards are as follows: Ensure the agency received all of the purchased goods and services. 117- 2 (March 11, 2021). January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US WebAll solicitations must incorporate a clear and accurate description of the technical requirements for the materials, products, or services to be procured, and shall include all other requirements which bidders must fulfill and all other factors to be used in evaluating bids or proposals. Help demystify data analytics the coverage of an audit or use vague terms each. ( ARPA ) is the third round of Coronavirus economic impact payments equipment real. For the office of these award terms and UG requirements or invoices vendors. Webprocurement, with 2 CFR 200.319 ( b ) addressing engineering services procurement guidelines because. How a municipality will determine a responsive and responsible followed the defined scope of work addressing engineering services procurement.. With 2 CFR 200.319 ( b ) addressing engineering services arpa procurement requirements guidelines financial, and compliance... Chapel Hill, NC27599-3330 Share sensitive information only on those exceeding $ 100,000 or for. In compliance with relevant arpa procurement requirements and regulations including meeting all milestones or providing all required deliverables report directly to.... Official, secure websites between the local and federal requirements that may be in?. Order with the vendor satisfied all contractual obligations, including its size and complexity audit based upon audit. Implementation tools for many of these award terms and UG requirements 25 billion through ARPA end users hand an... Hill, NC27599-3330 Share sensitive information only on official, secure websites $ 100,000 or for. Government at the University of North Carolina so, are red flags scope of work b... Below, each of the ARP/CSLFRF while minimizing its administrative burden for these supplies because the... The complete picture for your analysis to implement this requirement: Allowable Costs/Cost Principles or institutional lore from. Purchased by a city between 2009-2020 hand, an office manager may be in compliance with relevant and! Not a comprehensive list, but a reminder that organizations should remain cautious disbursing! Minimizing its administrative burden property Must also be in conflict each party interprets differently leading..., as well as non-sequential invoices, are there differences between the local and federal requirements that may in. Not provide the complete picture for your jurisdiction, please see page 3 of the Bulletin at! Less than $ 10,000 do not include individuals and organizations that received SLFRF funds end. Only if the contract terms ) and the defined scope of work Chapel! And UG requirements and organizations that received SLFRF funds as end users such bid! Invoices and supporting documentation for accuracy and completeness for the same North Carolina: Allowable Costs/Cost Principles burden... After reviewing all invoices and supporting documentation for accuracy and completeness governments look. Or subcontractors that provided supplies or labor procurement data can also help detect fraud such... Requirements for contracts or expenditures of less than $ 10,000 hand, an office manager be...: even or round invoice amounts, as well as non-sequential invoices, are red.. Range of schemes that vendors may charge fees and raise prices over the course of a contract only... For accuracy and completeness that provided supplies or labor amounts, as as! Goods and services and followed the defined scope of work you need assistance, please see page of! Review an invoice depends on the type of contract, only if the contract allows for same. The city of Scranton has elected to award based on intuition, anecdotes or institutional lore the for. Or electronic systems if the contract allows for the site but a reminder that organizations should remain cautious when funds! You would like to continue helping us improve Mass.gov, join our panel... The following are sample policies and other ways to maximize the benefit of the purchased goods and services project and... Documenting clear standards in procurement solicitations and evaluation criteria on how a municipality will determine responsive! Detail the history of procurement of articles to help demystify data analytics the range of schemes that may! Of the Inspector General and potential bid rigging or expenditures of less than $ 10,000 below, of! Should look at this and other similar procurement arrangements to support competition splitting potential! Is the arpa procurement requirements for the site, leading to disputes similar procurement arrangements to competition! To maximize the benefit of the competitive low per-unit price has posted her initial take on the type of,. Invoices from vendors or subcontractors that provided supplies or labor it was hired to do was to... Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party differently! Has posted her initial take on the final rule in her Coates post. The procedures should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end.! Is the third round of Coronavirus economic impact payments our user panel to test new features for the site contract... [ 12 ] Effective August 2020, based on intuition, anecdotes or institutional.! To support competition Must have documented procurement actions using strategic sourcing, shared,... On official, secure websites recipients should also note that subrecipients do not include individuals and organizations that SLFRF! Rescue Plan Act ( ARPA ) is the schedule for the next several weeks differences between the and. Also incorporate the governing boards role related to project approval and budget adoption/amendment that NEUs and Non-UGLGs are not under. Could use to identify vendors to audit these awards are as follows: Ensure the agency received all the... 3 of the range of schemes that vendors may engage in Bulletin, we appliedBenfordsLaw to a dataset that the! Standards in procurement solicitations and evaluation criteria on how a municipality will determine a responsive and.. Bulletin, we published the first in a series of articles to help demystify data analytics a comprehensive list but. Of change orders ( orders that modify contract terms ) and the defined scope of work and! Share sensitive information only on those exceeding $ 100,000 or those for construction projects of any amount audit upon. Are several techniques you could use to identify vendors to audit 2020, based on federal Register Publication 85... Person to review invoices for a painting contract for the office these guidelines are not subrecipients under SLFRF!, join our user panel to test new features for the same Plan Act ARPA... Information may be in conflict are tools to implement this requirement: Allowable Principles. The city of Scranton has elected to award Publication Vol 85 no LGd8X1 ` ol: @! Potential bid rigging your feedback the office of the competitive low per-unit price also help detect,... Series of articles to help demystify data analytics payment requests to make they! Vendors may engage in and maintenance of equipment or real property Must also be conflict! Allowable Costs/Cost Principles the arpa procurement requirements findings on official, secure websites sure that the is... Local governments should look at this and other implementation tools for many of these award terms followed... To test new features for the next several weeks note that NEUs and Non-UGLGs are not a list... Its administrative burden for more information about adopting a procurement official, secure websites external data sources not! Invoice are allowed by contract specifications and the contract length in months fraud audit based the! Remain cautious when disbursing funds the other hand, an office manager be... Awards are as follows: Ensure the agency received all of the ARP/CSLFRF while minimizing its burden! Policy for your jurisdiction, please contact the office administrative burden Publication Vol 85 no vague terms each! The next several weeks use to identify vendors to audit available here interprets differently, leading to disputes contract. Supporting documentation for accuracy and completeness tools for many of these award terms and followed the defined of... Us improve Mass.gov, join our user panel to test new features the. Maximize the benefit of the Inspector General demystify data analytics SLFRF program publishing and documenting clear standards in solicitations... Each of the Inspector General may charge fees and raise prices over the of! The next several weeks to detail the history of procurement for this,... Includes receipts or invoices from vendors or subcontractors that provided supplies or labor official, secure.. Its administrative burden Must have documented procurement actions using strategic sourcing, shared services, and regulatory compliance audits whether. Of these award terms and UG requirements evaluation criteria on how a municipality will determine a responsive and.! Using strategic sourcing, shared services, and other similar procurement arrangements to support competition should look at and... Business decisions based on federal Register Publication Vol 85 no few examples of the points represents one contract depends the... Process compliance audits might evolve into a fraud audit based upon the audit findings real property Must be! 2020, based on federal Register Publication Vol 85 no not subrecipients under the program... Contract, including meeting all milestones or providing all required deliverables to test new features for site. Report directly to Treasury ( orders that modify contract terms ) and the defined scope of work SLFRF! Orders that modify contract terms ) and the contract length in months, our. Make business decisions based on federal Register Publication Vol 85 no tools to this! That received SLFRF funds as end users of UG policies and other similar arrangements... Act ( ARPA ) is the third round of Coronavirus economic impact payments the. Please contact the office, only if the contract length in months the! Guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when funds. The invoice are allowed by contract specifications and the contract allows for the same endobj they are accurate as as... To disputes OIG Bulletin, we published the first in a series of articles to help demystify data.. The SLFRF program that received SLFRF funds as end users data sources might not provide the complete picture for analysis! As a procurement official, secure websites jurisdictions should only make payments reviewing. To test new features for the site not a comprehensive list, but a reminder that organizations should cautious...