Maintaining clear policies governing conflicts of interest for Are there existing sources for that data? Municipalities should also be prepared to justify and document the selection of the MOU or MOA as the most appropriate, reasonable, and cost-effective method to provide services utilizing ARP funds. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. If you are used to having a financial statement audit, a single audit can be much more comprehensive. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. ARPA Subgrantee Agreement Template Two Payment (Advance, Reimbursement) rev11.3.22, ARPA Subgrantee Agreement Template Reimbursement Based rev11.3.22, ARPA Subgrantee Agreement Template 100% Advance Payment (Very Rare-Special Circumstances) rev11.3.22, ARPA Subgrantee Agreement Template 25% Advance Payment rev11.3.22, ARPA Beneficiary Agreement Template rev11.3.22, SLFRF_Subgrantee_Budget_Exhibit 3_ 11.3.2022, SLFRF_Subgrantee_Invoice_Exhibit 4_11.3.2022. For that reason it is not included in the Drop-in document. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. 11 Uniform Government entities should only pay invoices after confirming that the vendor has satisfactorily delivered all goods, has performed all required services according to the contract and has submitted an accurate invoice. 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. See, e.g., 2 C.F.R. Use this button to show and access all levels. Where feasible, municipalities should consider taking steps to ensure competition is accessible to minority- and women-owned businesses in addition to labor surplus area firms. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. Further, a prequalification or screening process for vendors interested in providing certain services, such as towing and storage, helps ensure that the public is receiving services from a qualified vendor at a reasonable price. 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. Properly documented. Thus, the jurisdiction created a ready market for a single vendor without ensuring that drivers were receiving a fair price for the towing and storage services. Determine if billings are accurate and in compliance with contract 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. Top-requested sites to log in to services provided by the state. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. To help prioritize which vendors to audit, consider the factors below. 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. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. 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. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= of the Award Terms and Conditions. endstream endobj 560 0 obj <. April 11, 2022: Basics of Implementing the Standard Allowance. Recipients that receive an aggregate amount of federal financial assistance in a given fiscal year that exceeds the Single Audit threshold are subject to the requirements in 2 CFR 200 Subpart F, Audit Requirements, unless otherwise specified in program-specific guidance. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. Mayor Smiley wants to hear from you! 200.319-320 (describing the competitive processes required for procurements made with federal funds). A compliance audit is the overarching term for ensuring that a vendor is complying with the terms of a contract. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. Assigning multiple witnesses to attend and attest to the proper bid opening. Specifically, Ohios political subdivisions have Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. 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 includes receipts or invoices from vendors or subcontractors that provided supplies or labor. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. The vendor claimed that the lower per-unit price was only for bulk purchases. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. 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. 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. 2 CFR 200.317 - 2 CFR 200.327. %PDF-1.6 % 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. Include a right-to-audit clause in grant agreements. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. two (2) subrecipients to carry these programs. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. A .mass.gov website belongs to an official government organization in Massachusetts. 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. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. 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. Pursuant to the SLFRF Award Terms and Conditions, recipients are permitted to charge both direct and indirect costs to their SLFRF award as administrative costs as long as they are accorded consistent treatment per 2 CFR 200.403. Please let us know how we can improve this page. Each of the considerations above, as well as operation and maintenance A lock icon or https:// means youve safely connected to the official website. Right-to-audit clauses should be specific, yet not overly restrictive, to allow the procuring entity the ability to interview key vendor personnel and review applicable documentation and records. Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. Insufficient reportingrequirements or processes, or lack of attention to grant administration, can lead to a wide range of negative results, including project mismanagement, inappropriate use of funds and failure to comply with legal requirements. There are many reasons to audit contracts with vendors and suppliers. The ARPA program requires recipients to comply with the procurement provisions of Title 2, Part 200 of the Code of Federal This policy sets up procedures for making project requests, approving those requests, and documenting that approval and any required justifications and other records. By now, Ohio municipalities, counties, and townships are well aware that the federal government passed significant coronavirus relief funding in the American Rescue Plan Act (ARPA). This page is located more than 3 levels deep within a topic. 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. This blog post is published and posted online by the School of Government to address issues of interest to government officials. 584 0 obj <>/Filter/FlateDecode/ID[<835934A992BE5B40B85FB79B51E29EDE>]/Index[559 43]/Info 558 0 R/Length 119/Prev 296096/Root 560 0 R/Size 602/Type/XRef/W[1 3 1]>>stream [1] These requirements outline the general standards and regulations for the procurement of goods and services for recipients and subrecipients of federally awarded funds. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.). In most cases, city procurement Process compliance audits evaluate whether the vendor is doing what it was hired to do. 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 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). Now is the time for school districts and municipalities across the Commonwealth to develop bid documents that are tailored to address the additional compliance requirements Or subcontractors that provided supplies or labor therefore, is whether the vendor to charge an fee... Or labor to this program new blog posts from the SOG is not adequately understanding the vendors,. 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