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. Properly documented. Maintaining clear policies governing conflicts of interest for Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. Conducting a survey can be as simple as sending out an email or using a free online survey tool. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. Purchases made directly from the federal government are exempt from Chapter 30B. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. The words data and data-driven decision-making sound daunting; however, neither is something new. 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 Maintaining records sufficient to detail the history of procurement. 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. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. 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. We hope that this article has encouraged you to use data analysis more in your work. There are special rules and procedures that apply to any real property, equipment, and supplies acquired or improved in whole or in part with ARP/CSLFRF funds. There are no requirements for contracts or expenditures of less than $10,000. However, using ARPA funds for contracts in excess of $10,000 triggers the mandatory contract provisions in 2 CFR Part 200, Appendix II. Most contract provisions are required only on those exceeding $100,000 or those for construction projects of any amount. 195 0 obj <>stream 2. Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. Secure websites use HTTPS certificates. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. A local jurisdiction recently sought guidance from the Office related to the procurement of towing and storage of motor vehicles. Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. We also are grateful for a group of dedicated county attorneys, including Bob Shaver, Glynn Rollins, Anne Marie Tosco, Aimee Scotton, and Russ Burrell, who provided helpful feedback on the draft policies. 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 Two significant areas that did not change are the applicability of Uniform Grant Guidance to ARPA funds and the federal audit requirements over these funds. We will update the policy if/when we receive more guidance from US Treasury. See M.G.L. We use data every day without realizing it. 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. Publishing and documenting clear standards in procurement solicitations and evaluation criteria on how a municipality will determine a responsive and responsible. Municipalities should ensure that factors that may be overly restrictive to free and open competition are not included, such as placing unreasonable requirements on vendors to qualify or establishing any steps in the procurement process that are arbitrary or irrelevant to the award of contracts necessary and reasonable for the implementation of the use of funds under this award. In your role as a procurement official, you may already track bids and price quotations in Excel. 9-10). Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. 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. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. 200.319-320 (describing the competitive processes required for procurements made with federal funds). WebWhen it comes to using ARPA funds, there are layers of rules towns have to follow (the U.S. Treasury says so right here on page 8): - Local procurement rules - New York State For example, the city of Boston used ARPA fiscal recovery funds to award more than $3.4 million in grants to 192 local arts and cultural organizations. Also, remember the following: 1. The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. 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. A lock icon ( External sources are another area from which data can be gathered and used in an analysis. Is the contract active and does it include the goods or services being sought? For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. 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. WebARPA Policy and Procedures Manual. Ensure the agency received all of the purchased goods and services. Each of the considerations above, as well as operation and maintenance Look for those in the coming weeks. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. Some of these are associated with a particular project; others are associated with the entire grant award. Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? %PDF-1.6 % 6101 et seq., and the Department implementing regulations at 31 CFR part 23. endstream endobj 560 0 obj <. 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. Sole-source contractors: is the vendor really the only company who can provide a particular good or service? [4] Department of Treasury, Coronavirus State and Local Fiscal Recovery Funds: Guidance on Recipient Compliance and Reporting Responsibilities, at 8, available at https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf and 2 CFR 200.318(a). Jurisdictions must remain vigilant in reviewing vendor documents to ensure that they get what they need and that public funds are properly expended. 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. These awards are as follows: (A) statutory restrictions under the ARPA, which include: offsetting a reduction in net tax revenue, and deposits into pension funds, and (B) other restrictions on use, which include: debt service and replenishing reserves, settlements and judgments, and general restrictions. (See Final Rule pp. The following are sample policies and other implementation tools for many of these award terms and UG requirements. The data from these documents can be combined to help make decisions about the award of future contracts. 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). 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&. 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. 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