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. 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. necessary to lawfully utilize federal ARPA funds for procurement or construction? Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. 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. Please remove any contact information or personal data from your feedback. 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. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. UNC Chapel Hill Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. contact the Office of the Inspector General. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. 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. To learn more, view our full privacy policy. Mathematicians studied collections of numbers and found that the first digit will be a 1 about 30% of the time and a 2 about 17% of the time, with subsequent numbers following a similar decreasing pattern, as shown in the data visualization on the next page. Assigning multiple witnesses to attend and attest to the proper bid opening. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. We welcome non-English speakers to contact us. 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. 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. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. Each category of cost should be treated consistently in like circumstances as direct or indirect, and recipients may not charge the same administrative costs to both direct and indirect cost categories, or to other programs. The August 2020 installment of our data series discussed how to collect data and provided examples of how municipal employees can use that data to identify waste and possible fraud. ARPA-funded projects must also adhere to North Carolina state law, In this case, the subaward to a nonprofit is based on the services that the recipient intends to provide (assistance to households experiencing homelessness), and the nonprofit is serving as the subrecipient, providing services on behalf of the recipient. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? 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. 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. If a recipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. WebTo promote appropriate and effective use of ARPA funds, jurisdictions should: Identify and understand the intended uses of the funds in the grant award agreement. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. 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. 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. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. 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. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. For example, someone from the public works department who supervises roadway paving should know whether the contractor completed the work and used the correct materials. The short answer is: it depends. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. %%EOF For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. Once the data has been transformed into auser-friendlyformat, it can be used in a variety of ways to assist with future procurements and other business decisions. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. c. 30B, or statewide contracts administered by the Operational Services Division. 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. It will be equally problematic from a compliance standpoint to have a policy your unit cannot or does not follow than to not have one at all. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Please include this language separately in the bid solicitation. Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. Many of our past reports highlight fraudulent or inaccurate vendor billing. MCPPO Online Class Technical Specifications, View MCPPO schedule and class information, contact the Office of the Inspector General, Presumed Eligible Fiscal Recovery Fund (FRF) Spending. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. Look for those in the coming weeks. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. Share sensitive information only on official, secure websites. The right person to review an invoice depends on the type of contract, including its size and complexity. In the meantime, please feel free to contact us if you have any questions or ideas about data. 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 For instance, data analysis can reveal patterns in payroll expenditures or purchasing, track whether employees are following policies and procedures, or measure staff or vendor performance. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. Please do not include personal or contact information. The idea of using data can be intimidating, and you might think you need to be a data expert to analyze or use data. A lock icon ( Generally, program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under Federal awards, and principal and interest on loans made with Federal award funds. In most cases, city procurement There are many reasons to audit contracts with vendors and suppliers. October 2015 Procurement Bulletin Article. 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 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. April 11, 2022: Basics of Implementing the Standard Allowance. c. 30B, 1(f). Exceptions to requirements for small purchase or formal method competitive rules. For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) This outlier may warrant further investigation. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. To ensure that jurisdictions get the supplies and services they need and to combat fraud, waste and abuse, it is essential that jurisdictions carefully review all vendor payment requests. 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. https://canons.sog.unc.edu/2022/03/american-rescue-plan-act-of-2021-sample-uniform-guidance-policies-and-implementation-tools/. While data includes these things, data also includes things such as time sheets, bank statements, survey responses and water meter readings. Becoming overly friendly threatens the auditors independence in performing their review. To start, here is a summary list of UG policies and their triggers. Direct questions related to design and construction procurement to the Attorney Generals Office. The smallest incongruity could lead to the discovery of a large fraud. Still, working with data at all levels of government can be challenging. Recipients of SLFRF funds should calculate, document, and record the organizations program income. Broadly speaking, data is any fact about an object or concept. Also, remember the following: 1. 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. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. The following bar chart, which can be made using Excel, shows the distribution of the first digit of the purchase price for each item in the dataset, with all vendors grouped together. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. 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