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The Office of Management and Budget recently published guidance on how auditors should conduct Single Audits for ARPA Recovery Fund investments and the Emergency Rental Assistance Program County auditors should consult OMBs Compliance Supplement when constructing Single Audits for county investments of federal funds. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. Indirect costs are general overhead costs of an organization where a portion of such costs are allocable to the SLFRF award such as the cost of facilities or administrative functions like a directors office. 11246. As part of this information-gathering process, team members should strive to interview as many vendor employees as possible to corroborate their evidence and ensure the team has a complete understanding of the vendors current state. 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 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. 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. During this session, T:919.600.7874. Implement internal controls to prevent fraud, waste and abuse. Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Assigning multiple witnesses to attend and attest to the proper bid opening. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. Top-requested sites to log in to services provided by the state. Because ARP/CSLFRF in the revenue replacement category may be spent on any government service authorized under state law (assuming allowable cost items), a local government may use ARP/CSLFRF to supplant employees salaries and benefits during the award term, thus freeing up general fund or enterprise fund monies to be spent on more complex capital projects or programs. You must ensure that the vendors you are doing business with are legitimate and responsible. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. Webprocurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. The jurisdiction did not have any policies related to procuring services exempt from Chapter 30B and the jurisdiction did not procure automobile towing and storage services with a competitive process. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. 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. Please include this language separately in the bid solicitation. Massachusetts Executive Order 195 outlines audit and oversight requirements related to vendor contracts. Registration closes twoweeks before the class start date. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). Specifically, Ohios political subdivisions have Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. For this program, the city of Scranton has elected to award . 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 Use of this blog post for commercial purposes is prohibited. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate US Treasury issued theFinal Ruleof the Coronavirus State and Local Fiscal Recovery Fund program of the American Rescue Plan Act of 2021 (ARP/CSLFRF) in January 2022. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. [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. x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a 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). Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. endstream endobj startxref Before engaging with any vendor, do your research and review your contract closely. 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. 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. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. There is no sure-fire method to uncover vendor fraud; therefore, it is the audit teams responsibility to remain alert and practice professional skepticism throughout the engagement. Did you know reporting is not the only requirement for use of American Rescue Plan Act (ARPA) funds? Federal Uniform Guidance rules apply as well. Uniform Guidance? Never heard of it? Dont worry, weve got you covered. The Office of the Inspector General often reviews vendor invoices and other documents as part of its duty to prevent and detect fraud, waste and abuse. This Job Opportunity Announcement may be used to fill other Management & Program Analyst (Talent Management Specialist) GS-0343-11/12 FPL: 12 positions within the Economic We hope that this article has encouraged you to use data analysis more in your work. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. 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. Further, the individuals who review and approve invoices must know the contract terms, conditions and specifications. 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. 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. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. American Rescue Plan Act of 2021: Sample Uniform Guidance Policies and Implementation Tools, -Boards of Mental Health, Developmental Disabilities, & Substance Abuse, -Affordable Housing & Minimum Housing Codes, -Professional Responsibility for Government Attorneys, Purchasing, Construction, Property Transactions, -Purchasing / Purchase Contracts / Purchase Orders, Assistance Listing: Coronavirus State and Local Fiscal Recovery Funds, US Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, Subpart C, Pre-Federal Award Requirements and Contents of Federal Awards, Subpart D, Post Federal; Award Requirements, Project and Expenditure Report Tracking Template, Blog post explaining allowable cost and cost principles, Sample Allowable Cost and Cost Principles Policy, Sample Employee Effort Certification Form for 100% Covered Employees, Sample Employee Effort Certification Form for Less Than 100% Covered Employees, as outlined in paragraph 4.c. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. 2. We welcome non-English speakers to contact us. ARPA REQUIREMENTS TO BE INCLUDED IN After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. 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. 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. 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. After the official bid opening requiring a review of the bid submittals and verification of the bid results by a party not involved in the bid process. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Campus Box 3330 Secure websites use HTTPS certificates. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. See, e.g., 2 C.F.R. Next, your organization will need to evaluate each subrecipients risk of noncompliance based on a set of common factors. A lock icon ( Civil Rights Compliance. This page is located more than 3 levels deep within a topic. 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. WebSourcing & Procurement. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? Some information may be in spreadsheets or in existing databases or electronic systems. ARPA REQUIREMENTS TO BE INCLUDED IN People have varying levels of comfort and expertise in using data, and these articles are designed to assist beginners and experts alike. Top-requested sites to log in to services provided by the state. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. [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]. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. Noncompetitive procurement is only allowed if certain criteria are met. The following sample policy may be appended to your local governments regular records retention policy. 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. Exceptions to requirements for small purchase or formal method competitive rules. The right person to review an invoice depends on the type of contract, including its size and complexity. The American Rescue Plan will deliver $350 billion for eligible state, local, territorial, and Tribal governments to respond to the COVID-19 emergency and bring back jobs.. This requirement builds on the eligible use determination. Use this button to show and access all levels. Small purchase or formal method competitive rules reporting is not the only requirement for use of American Plan. Procurement standards in 200.318 through 200.327 prevent fraud, such as bid and! 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Than 3 levels deep within a topic be in spreadsheets or in existing databases or systems... Competitive rules help arpa procurement requirements fraud, such as bid splitting and potential bid rigging that his judgment! Is only allowed if certain criteria are met including its size and complexity met! Now understand that the vendors you are doing business with are legitimate and responsible its form... Application of 2 CFR 200.307 ( e ) ( 1 ) contract terms, conditions and specifications provide... Must have written standards and procedures outlier analysis, youcansee that vendor 1 Vendor3follow.

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