%PDF-1.6 % Use this button to show and access all levels. 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. WebYes; there is no requirement to prove a loss in revenue. If the data is not in one of these formats, do not despair! [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). This page is located more than 3 levels deep within a topic. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate 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 Written procedures that do not meet UG standards must be revised to include these 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] A local government should craft its policies and procedures so that they can be reasonably implemented by its staff. SLFRF funds beyond those that are available under the revenue loss eligible use category may not be used to meet the non-federal match or cost-share requirements of other federal programs, other than as specifically provided for by statute. Share sensitive information only on official, secure websites. We use data every day without realizing it. Suggestions are presented as an open option list only when they are available. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. In most cases, city procurement 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 Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. A local jurisdiction recently sought guidance from the Office related to the procurement of towing and storage of motor vehicles. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. Please limit your input to 500 characters. In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. Is it something you can collect in the future? Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. It is a red flag that the business may not be legitimate or well established. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. Generally, your organization must maintain records and financial documents for five years after all funds have been expended or returned to Treasury, as outlined in paragraph 4.c. of the Award Terms and Conditions. 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. We will update the policy if/when we receive more guidance from US Treasury. With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. 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. As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. 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 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. The Virginia Department of Criminal Justice Services (DCJS) is pleased to announce the ARPA Regional Jail Equipment Grant Program, funded through a state appropriation of federal funds through the American Rescue Plan Act (ARPA). 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. ) or https:// means youve safely connected to the official website. Top-requested sites to log in to services provided by the state. 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. Review for compliance with federal procurement law requirements. 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. If you need assistance, please contact the Office of the Inspector General. To use data in decision making, the data must exist in a format that can be analyzed. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. To learn more, view our full privacy policy. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. infrastructure, potential enhancements of state funding resources, Blackboardor other virtual platform login details will be emailed to registrants. All rights reserved. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. Many of the UG provisions require that the local government adopt and implement policies and procedures to ensure compliance with its requirements. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. Please let us know if you have any questions! During this session, With the addition of the standard allowance, authorizing many NC local governments to expend their entire ARP/CSLFRF allocation for almost any purpose authorized by state law, counties and municipalities across the state have an even greater opportunity to make the best strategic investments for their communities with these one-time funds. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. 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. Counties with allocations under $10 million may spend their entire allocation on government services, but they may 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. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. Review the contract and be familiar with its terms. We hope that this article, along with the other articles in our series on data analytics, helps you feel more confident in your ability to collect and analyze data. L. No. Benfords Law analysis: this analysis may highlight a vendor with billing discrepancies that warrant further review. Jurisdictions therefore must dedicate staff to evaluate documents and completed work reports from contractors to make sure that they have followed the contract before issuing payment. When procuring goods or services, the state agency or municipal department typically executes a contract with the vendor to outline the scope of the parties agreement. We hope that this article has encouraged you to use data analysis more in your work. Under the American Rescue Plan Act (ARPA), passed by the federal government in March 2021, Massachusetts state, county, tribal and local entities are receiving federal aid to respond to the public health and economic impacts of the public health emergency created by the COVID-19 pandemic. 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. When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act, Treasury will collect and review information from non-Tribal recipients to ascertain their compliance with the applicable requirements before and after providing financial assistance. Please limit your input to 500 characters. 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. Broadly speaking, data is any fact about an object or concept. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. Without thinking much about it, you gathered data and made a decision based on that data. Still, working with data at all levels of government can be challenging. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. 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. After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. Share sensitive information only on official, secure websites. The following is a sample policy: Recordkeeping Requirements. 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. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. Then make sure that you have access to that data. Conducting a survey can be as simple as sending out an email or using a free online survey tool. The following are sample policies and other implementation tools for many of these award terms and UG requirements. However, the audit team should be careful not to become too friendly with their auditees. Treasurys final rule, program guidance, and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. 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. External sources are another area from which data can be gathered and used in an analysis. Please include this language separately in the bid solicitation. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. two (2) subrecipients to carry these programs. If procurement is only possible through non-competitive methods, municipalities will need to justify use of a non-competitive procurement process, only permissible when one of the following conditions are met: the item is below the micro-purchase threshold established by the municipality; the item is only available from a single source; the public exigency or emergency will not permit a delay from publicizing a competitive solicitation; or after solicitation of a number of sources, competition is determined inadequate. Therefore, when your jurisdiction uses federal funds to pay for supplies or services, you need to check your federal funding documents and any other federal guidance applicable to the type of funding you received to determine which procurement laws to follow. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. Use this button to show and access all levels. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. A different person should have the authority to approve payment, and that person must also know the terms of the contract to effectively review invoices. Ensuring that the contract structure is appropriate for the goods and/or services rendered, that prices are fair based on an independent cost or price analysis, and that a cost-plus-percentage-of-cost method is not used for federally-funded contracts. 3. 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 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. 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. Before engaging with any vendor, do your research and review your contract closely. Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. 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