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The feedback will only be used for improving the website. ARPA-funded projects must also adhere to North Carolina state law, We have also learned that state agencies and municipalities can start from scratch and build the capacity to rely on data as a problem-solving tool. This helps maintain the integrity of the payment process. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. 2 CFR 200.320(c). This page is located more than 3 levels deep within a topic. Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. 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. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. Direct questions related to design and construction procurement to the Attorney Generals Office. Per 2 CFR Part 200.303, your organization must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. 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. 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. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. 6101 et seq., and the Department implementing regulations at 31 CFR part 23. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. 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. Please let us know how we can improve this page. 5. For example, a roadway repair and maintenance contract should not include unrelated supplies or services, such as classroom IT equipment or roadway paving in a location not specified in the contract. This outlier may warrant further investigation. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. Webprocurement can be used. The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. This requirement builds on the eligible use determination. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. This scope is different than what is included in the current contract and may be considered noncompetitive. Review for compliance with federal procurement law requirements. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. 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. ARPA REQUIREMENTS TO BE INCLUDED IN WebWhen it comes to using ARPA funds, there are layers of rules towns have to follow (the U.S. Treasury says so right here on page 8): - Local procurement rules - New York State 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. Remember to consider whether your data gives you enough information to help you make decisions. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. The data from these documents can be combined to help make decisions about the award of future contracts. 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. 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. 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. We will update the policy if/when we receive more guidance from US Treasury. We also plan to give an overview of some of these techniques in the next article on data in an upcoming edition of the OIG Bulletin. There may be an acceptable explanation for the high number of change orders for that particular contract, but only further review can determine whether the change orders are reasonable. 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. Broadly speaking, data is any fact about an object or concept. Mayor Smiley wants to hear from you! 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. Direct costs are those that are identified specifically as costs of implementing the SLFRF program objectives, such as contract support, materials, and supplies for a project. For this program, the city of Scranton has elected to award . hbbd```b`` DHl"Yn H2|+H3$00M 2@ o. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. 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. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. Share sensitive information only on official, secure websites. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. WebThey are awarded in accordance with the following requirements: ( i) Requests for proposals must be publicized and identify all evaluation factors and their relative importance. 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 cost is consistently applied when it is applied uniformly to both federally-funded and other activities of the local government. Benfords Law analysis: this analysis may highlight a vendor with billing discrepancies that warrant further review. Surveys are a helpful way to do this. It is a red flag that the business may not be legitimate or well established. 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. This course is targeted to finance and management staff of smaller and mid-sized units that will be taking the standard allowance and spending most, if not all, of their ARP/CSLFRF as revenue replacement. 2 CFR Part 25 (Universal Identifier & System for Award Management) Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. 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). c. 30B, 1(d). Ensure the agency received all of the purchased goods and services. c. 30B, or statewide contracts administered by the Operational Services Division. If you are used to having a financial statement audit, a single audit can be much more comprehensive. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ contact the Office of the Inspector General. See M.G.L. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. 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. Thank you for your website feedback! The state agency or municipality should first identify the goal of the audit, which will determine the type of audit to perform. Chapel Hill, NC27599-3330 BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. 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. People often make business decisions based on intuition, anecdotes or institutional lore. When was the last time your client revised their procurement contracts? See 2 C.F.R. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. 2 CFR 200.317 - 2 CFR 200.327. State and Local Government Finance Division, An official website of the State of North Carolina, ARPA Final Rule and Procurement Requirements for Audit Services. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate on the basis of race, color, national origin (including limited English proficiency), disability, age, or sex (including sexual orientation and gender identity), in accordance with the following authorities: Title VI of the Civil Rights Act of 1964 (Title VI) Public Law 88-352, 42 U.S.C. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. Is the contract active and does it include the goods or services being sought? 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. Webprocurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. two (2) subrecipients to carry these programs. 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. Or maybe you used a more sophisticated tool to make that decision for example, the weather app on your phone but in both cases you used data to decide to wear a raincoat. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Top-requested sites to log in to services provided by the state. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. Specifically, Ohios political subdivisions have 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. Without thinking much about it, you gathered data and made a decision based on that data. 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