A local government should craft its policies and procedures so that they can be reasonably implemented by its staff. When initiating an audit it is important to inform the vendor exactly which personnel and/or processes you will be auditing. If you are used to having a financial statement audit, a single audit can be much more comprehensive. The feedback will only be used for improving the website. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. Suggestions are presented as an open option list only when they are available. 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. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). 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. Each recipient should review program requirements, including Treasurys final rule and the recipients Award Terms and Conditions, to determine and record eligible uses of SLFRF funds. 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. We use small samples of data, as well as big data, to help with everything from researching whistleblower claims to investigating individual cases of potential fraud to analyzing statewide systemic issues. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. Some page levels are currently hidden. 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. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. Once the audit team selects the type of audit to perform, the team must clearly prepare an audit plan and outline the expected audit procedures. For example, in the scatter plot below, each of the points represents one contract. This goal may be accomplished, in part, by using high quality data for informed decision making and risk assessment. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. 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. 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. Please limit your input to 500 characters. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. Review the contract and be familiar with its terms. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. L. No. The Assistance Listing is available on SAM.gov. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. 2. 601 0 obj <>stream 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. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. of the Award Terms and Conditions, Accessibility: Report a Digital Access Issue, Allowable Costs and Cost Principles Policy, Financial Management and Internal Controls, Program Income Policy (if local government uses ARP/CSLFRF funds to establish a loan program or otherwise earns income related to an ARP/CSLFRF expenditure), Procurement Policy (if a local government contracts for goods or services paid for with ARP/CSLFRF funds, or must engage in a Single Audit (even if the audit is paid for with other funds)), Property Management Policy (if a local government uses ARP/CLSFRF to acquire or improve any real property, equipment, or supplies), Subaward Policy (if a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF-eligible project), Thursday, March 24, at 8:30am (focus on affordable housing). 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. Web( a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. Treasury may request transfer of records of long-term value at the end of such period. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. Require regular and thorough reporting from grantees relating to expenditures. two (2) subrecipients to carry these programs. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. The short answer is: it depends. Or maybe you used a more sophisticated tool to make that decision for example, the weather app on your phone but in both cases you used data to decide to wear a raincoat. These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. 3. 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. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US The executive order requires that every goods or services contract or agreement must incorporate an auditing provision permitting the government to audit the vendors books, records and other compilations of data relative to the performance of any provision or requirement of the contract or agreement. The audit scope and appropriate approach depend on the type of audit performed. 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. Top-requested sites to log in to services provided by the state. To promote accountability, ARPA includes requirements for the administration, monitoring and reporting of funds. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. 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 $100,000 or those for construction projects of any amount. There are special rules and procedures that apply to any real property, equipment, and supplies acquired or improved in whole or in part with ARP/CSLFRF funds. 2 CFR 200.317 - 2 CFR 200.327. The first step in implementing a vendor audit program is determining who to audit. Are you missing any data that would help you monitor utilization? If a recipient seeks to use SLFRF funds to satisfy match or cost-share requirements for a federal grant program, the recipient should first confirm with the relevant awarding agency that no waiver has been granted for that program, that no other circumstances enumerated under 2 CFR 200.306(b) would limit the use of SLFRF funds to meet the match or cost-share requirement, and that there is no other statutory or regulatory impediment to using the SLFRF funds for the match or cost-share requirement. All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. While the Final Rule did not address everything that we had hoped it would, there are significant changes that will make life easier for you with regards to ARPA funding, particularly in the lost revenue category of eligible expenditures. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. S.aR8.:h;"S=uV#7SS:]=i++_u}~}_y_yR,_+#$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&. Additional controls that your organization should implement include written policies that explicitly identify appropriate allocation methods, accounting standards and principles, compliance monitoring checks for program income calculations, and records. Was the contract competitively procured and consistent with local procurement and contracting requirements and applicable laws? Determine if billings are accurate and in compliance with contract terms. Consider whether prevailing wage rates apply. The following are sample policies and other implementation tools for many of these award terms and UG requirements. Counties with allocations under $10 million may spend their entire allocation on government services, but they may The goal of a vendor fraud audit is to determine whether the vendor intentionally acted to defraud the contracting organization. Federal Register Publication Vol 85 No. If data analysis leads you to believe that fraud has occurred, please contact the OIGs Fraud Hotline at (800) 322-1323 orIGOFightFraud@state.ma.us, orfill out our online form. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. We hope that this article has encouraged you to use data analysis more in your work. Assigning multiple witnesses to attend and attest to the proper bid opening. This can lead to drawing incorrect conclusions about the data and documentation available. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. c. 30B, (1)(b)(9). For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. 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. 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. Meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds //home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf, https: //www.govregs.com/regulations/title2_chapterII_part200 )! Would like to continue helping us improve Mass.gov, join our user to. A financial statement audit, a single audit can be much more comprehensive and regulatory compliance audits might into. Incorrect conclusions about the data and documentation available goods and services needed to operate effectively and efficiently for administration. The full rule ( all 437 pages of it ) here and a brief overview only! Carry these programs 200.319 ( b ) addressing engineering services procurement guidelines reminder that organizations should remain cautious disbursing. Operate effectively and efficiently you missing any data that would help you monitor utilization addressing services! 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