The feedback will only be used for improving the website. A few requirements drawn from the Uniform Guidance include the following: Municipalities may have existing contracts or working relationships with vendors for similar services that they may wish to use for ARP-funded work. This goal may be accomplished, in part, by using high quality data for informed decision making and risk assessment. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. In addition to Karas post, there is another new post on Procuring Single Audit services for ARPA funds. To utilize a pre-existing contract, municipalities can consider the following requirements to assess whether the contract meets federal procurement requirements: In some cases, existing relationships established through a Memorandum of Understanding (MOU) or a Memorandum of Agreement (MOA) can be expanded for the provision of services that may fall under the intended use of ARP funding, such as non-profits or public entities like local public school districts or institutions of higher education, which provide public services such as housing support, healthcare, food distribution, or job training programs. There is a visible correlation between the number of change orders and the contract length, which makes intuitive sense: generally, longer contracts have more change orders. In order to maintain the vendors trust and cooperation, the team should only ask for information necessary to achieve the goal of the audit and documents that have a true business justification. The OIG is developing classes to introduce local officials to specific data analysis techniques. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. 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. Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. 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. While a right-to-audit clause gives the team the contractual authority to conduct the audit, getting buy-in from management will help make the audit more efficient and effective. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. The funds can be used to purchase equipment that improves or enhances the delivery of daily Therefore, support from potential stakeholders senior management, the Board of Directors, department decision-makers is important for a successful audit engagement. ARPA Expenditure Category 2.15 and 2.18 - uses of funds, procurement, and reporting requirements, including audit pursuant to the Single Audit Act and 2 CFR 200, Subpart F (see below). procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. Please limit your input to 500 characters. 0 First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. Written procedures that do not meet UG standards must be revised to include these 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. 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 For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. Share sensitive information only on official, secure websites. Prior to beginning the audit, the team should provide logistical information to the vendor in order to combat potential pushback throughout the audit. 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. These risk assessments may include factors such as prior experience in managing Federal funds, previous audits, personnel, and policies or procedures for award execution and oversight. The course will have three parts, including brief overview videos, a 1-day live (Zoom) workshop, and extended daily Zoom Help Desk Office Hours the last two weeks of April (to help with implementation issues and completion of the Project & Expenditure report due by April 30). hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. Some of the data within your organization may already be in an analyzable format. [2] Per 2 CFR 200.318(a), non-Federal entities, such as municipalities, must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. 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. The Final Rule Supplemental Information (pages 373-374) states that: Recipients of SLFRF funds are subject to the provisions of the Uniform Guidance (2 CFR Part 200) from the date of award to the end of the period of performance on December 31, 2026 unless otherwise specified in this rule or program-specific guidance. Copyright 2009 to Present School of Government at the University of North Carolina. If a local government does not already have a written nondiscrimination policy, it must adopt and implement one consistent with this guidance. 2 CFR 200.320(c). 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. The prevention and detection of fraud, waste and abuse of public funds always an important issue for government entities is even more critical now that jurisdictions are receiving billions of additional dollars in ARPA funding. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. 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. ARPA REQUIREMENTS TO BE INCLUDED IN *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. Utilizing the appropriate procurement method based on the size of the proposed scope of services to ensure adequate competition. After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. The question, therefore, is whether the project is for a public building or public work, not who is performing the work. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. Still, working with data at all levels of government can be challenging. Track and maintain records of all grant-related documents, including communications, receipts and invoices. 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. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. 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. Recipients of SLFRF funds should calculate, document, and record the organizations program income. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate on the basis of race, color, national origin (including limited English proficiency), disability, age, or sex (including sexual orientation and gender identity), in accordance with the following authorities: Title VI of the Civil Rights Act of 1964 (Title VI) Public Law 88-352, 42 U.S.C. 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