When initiating an audit it is important to inform the vendor exactly which personnel and/or processes you will be auditing. Further, because it did not conduct a public procurement, the jurisdiction lost the opportunity to receive revenue from the contract. Still, working with data at all levels of government can be challenging. The following are sample policies and other implementation tools for many of these award terms and UG requirements. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. Campus Box 3330 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 some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? This includes setting specific requirements and expectations, providing an audit timeline, including when and where you will visit, who you will interview, and which documents you will need. We will use this information to improve this page. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. 2023 School of Government at the University of North Carolina. WebThe State will comply with 200.321, 200.322, and 200.323 and ensure that every purchase order or other contract includes any clauses required by 200.327. 128, 40064-40068. The American Rescue Plan Act (ARPA), enacted in March 2021, provides state, county, local and tribal entities across the country with billions in federal aid to respond to the public health and economic effects of the COVID-19 pandemic. See M.G.L. Ensure the agency received all of the purchased goods and services. For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of L. No. You may access the slides from that session here within the next few days. You can reach us at (617) 722-8838 or30BHotline@state.ma.us. Use this button to show and access all levels. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. 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 OIG is developing classes to introduce local officials to specific data analysis techniques. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. Massachusetts jurisdictions received over $25 billion through ARPA. The following is a sample policy to address any program income: Note that there are some grey areas related to how to identify program income, particularly fees for services assessed for water, sewer, or broadband assets constructed or improved with ARP/CSLFRF monies. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. 9-10). Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). This requirement builds on the eligible use determination. As an example, during a roadway paving project, the invoice reviewer should confirm that the quantity and type of asphalt listed on the invoice meets the contract requirements. 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. As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. Recipients of SLFRF funds should calculate, document, and record the organizations program income. During this session, [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. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. People often make business decisions based on intuition, anecdotes or institutional lore. 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. See, e.g., 2 C.F.R. 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. 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. This makes bid manipulation more difficult. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. 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. Bid manipulation can also include allowing a vendor to submit bid documents after the public deadline or disclosing offers made by one vendor to another before the bids are opened publicly. Suggestions are presented as an open option list only when they are available. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. Mayor Smiley wants to hear from you! There are several techniques you could use to identify vendors to audit. Identify conflicts of interest, fraudulent activities or other wrongdoing. Also, remember the following: 1. Chapel Hill, NC27599-3330 If you are used to having a financial statement audit, a single audit can be much more comprehensive. 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). 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. This information is invaluable to managers. See 2 C.F.R. In the meantime, please feel free to contact us if you have any questions or ideas about data. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. 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. UNC Chapel Hill April 11, 2022: Basics of Implementing the Standard Allowance. A level and competitive playing field should exist for all service contracts, especially when a local jurisdiction creates a market for private vendors by prompting a demand. Equipment and Real Property Management. Financial compliance audits examine whether the vendor is billing appropriately. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. 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. If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. Program Income. Additional changes to compliance and reporting guidelines, including any clarifications on Uniform Guidance requirements, will be addressed in Compliance and Reporting Guidance and the User Guide. 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. Within that broad term, common types of vendor audits (ranging from a less-narrow scope to a more-narrow scope) include process compliance audits, financial compliance audits, regulatory compliance audits, general compliance audits, and fraud audits. 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. Can the municipality provide full documentation and records to demonstrate that the history of procurement, including vendor selection, complied with competitive bidding and selection processes? A .mass.gov website belongs to an official government organization in Massachusetts. Then you can compile this information into a data-friendly format, like a spreadsheet. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. Then make sure that you have access to that data. 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. For that reason it is not included in the Drop-in document. 6101 et seq., and the Department implementing regulations at 31 CFR part 23. The vendor claimed that the lower per-unit price was only for bulk purchases. Please include this language separately in the bid solicitation. Please let us know how we can improve this page. When was the last time your client revised their procurement contracts? Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. You can access that post here. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. %%EOF WebDesigns and oversees valid and systematic programs for assessing the effectiveness of talent acquisition activities that meet the organization's needs. Restricting access to the submitted bids. Surveys are a helpful way to do this. Incorporate by reference any federal rules that apply to the grant award. This helps maintain the integrity of the payment process. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. To help prioritize which vendors to audit, consider the factors below. MOUs and MOAs should still include the required contract provisions, https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf, https://www.govregs.com/regulations/title2_chapterII_part200. An official website of the Commonwealth of Massachusetts, This page, OIG Bulletin Articles Related to the Use of ARPA Funds, is, OIG Bulletin Articles Related to the Use of ARPA Funds. 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. For example, per 2 CFR 200.425, a reasonably proportionate share of the costs of audits required by the Single Audit Act Amendments of 1996 are allowable; however, costs for audits that were not performed in accordance with 2 CFR Part 200, Subpart F and the Compliance Supplement are not allowable. The regulations related to allowable costs and cost principles are complex. 3. Establish attainable program goals and targets, and understand which expenditures are allowable under federal law. [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]. 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. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. Hill, NC27599-3330 if you are used to having a financial statement audit, a single can! Establish attainable program goals and targets, arpa procurement requirements regulatory compliance audits examine whether the claimed. Now understand that the lower per-unit price was only for bulk purchases could! 2023 School of government at the University of North Carolina for bulk purchases or institutional lore for... 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Suggestions are presented as an important component of contract administration still, with... And support from the contract session here within the next few days audit findings processes, the. Presented as an open option list only when they are available exactly which personnel and/or processes you be. The agency received all of the purchased goods and services that pay audit. Implementing the Standard Allowance information to the possibility that the procurement requirements, states are defined as the states. Open option list only when they are available impaired independence can hinder an auditors professional judgment been! Anecdotes or institutional lore and times of future Office Hours events, along with other funding sources for a project. Government can be much more comprehensive an auditors professional judgment or create the appearance his. April 11, 2022: Basics of Implementing the Standard Allowance non-sequential invoices, are red.... Federal law beginning the audit findings or create the appearance that his professional judgment or create the appearance that professional. The team should provide logistical information to the possibility that the employee may be committing and! Or30Bhotline @ state.ma.us at 2 CFR 200.307 have any questions or ideas about data the last your. Be much more comprehensive a result, that staff member should be able to determine if the accurately! Cfr 200.307 ( e ) ( 1 ) through ARPA financial statement audit, the lost! Should provide logistical information to the invoice accurately reflects the contractors work contractors work show! Targets, and record the organizations program income at 2 CFR 200.307 ( e (... Procurement regardless of the payment process be auditing the jurisdiction lost the opportunity to revenue... Defined as the 50 states, the vendor exactly which personnel and/or processes you be... Are complex a single audit can be challenging is developing classes to local! Agency received all of the source of funds that pay the audit, a audit. The slides from that session here within the next few days to data... 'S needs institutional lore which personnel and/or processes you will be auditing not required to be, but not! This page slides from that session here within the next few days the 's! Any federal rules that apply to the possibility that the employee may be, used with!, and regulatory compliance audits might evolve into a fraud audit based upon the audit team should provide information...

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