hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U 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 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. The standard allowance is available to all counties, including ones with allocations under $10 million. 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. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. A helpful starting point is to pull data from current and historical sources and compile it into a more data-friendly format, such as an Excel spreadsheet file. Becoming overly friendly threatens the auditors independence in performing their review. 117- 2 (March 11, 2021). This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. This page is located more than 3 levels deep within a topic. Subrecipients are subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements, whereas contractors are not subject to an audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements. The four primary reasons to conduct audits of vendors and supplies are to: To set expectations from the outset and to ensure that your jurisdiction has a right to audit include a right-to-audit provision in contracts. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. Suggestions are presented as an open option list only when they are available. 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 Regulatory compliance audits determine whether the vendor is following all of the laws and regulations relevant to the goods and services they provide (e.g., environmental regulations). Also, remember the following: 1. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ Specifically, Ohios political subdivisions have Generally, program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under Federal awards, and principal and interest on loans made with Federal award funds. 2 CFR 200.317 - 2 CFR 200.327. A .mass.gov website belongs to an official government organization in Massachusetts. To ensure that jurisdictions get the supplies and services they need and to combat fraud, waste and abuse, it is essential that jurisdictions carefully review all vendor payment requests. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. Each category of cost should be treated consistently in like circumstances as direct or indirect, and recipients may not charge the same administrative costs to both direct and indirect cost categories, or to other programs. [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. In most cases, city procurement Financial compliance audits examine whether the vendor is billing appropriately. 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. 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. Justifying and documenting the selection of vendors, including: (1) that a vendor is responsive to the requirements outlined in the procurement, (2) responsible, (3) not debarred from doing business with the federal government, and (4) offering a reasonable, competitive cost, based on cost or price analysis completed by the municipality. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). Noncompetitive procurement is only allowed if certain criteria are met. When was the last time your client revised their procurement contracts? 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. 0 Suggestions are presented as an open option list only when they are available. This collection does not apply to Tribal governments. 200.319-320 (describing the competitive processes required for procurements made with federal funds). These are largely based on the type of contract, the goals of the audit, specific management concerns and other relevant variables. Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. Therefore, when your jurisdiction uses federal funds to pay for supplies or services, you need to check your federal funding documents and any other federal guidance applicable to the type of funding you received to determine which procurement laws to follow. 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 With the upcoming Project and Expenditure Report deadline fast approaching on April 30, join NACo and Government Finance Officers Association for an overview of what you need to know when it comes to reporting for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Local governments should look at this and other ways to maximize the benefit of the ARP/CSLFRF while minimizing its administrative burden. Mathematicians studied collections of numbers and found that the first digit will be a 1 about 30% of the time and a 2 about 17% of the time, with subsequent numbers following a similar decreasing pattern, as shown in the data visualization on the next page. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. However, the audit team should be careful not to become too friendly with their auditees. See 2 C.F.R. This information is invaluable to managers. When was the last time your client revised their procurement contracts? Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. 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). The American Rescue Plan will deliver $350 billion for eligible state, local, territorial, and Tribal governments to respond to the COVID-19 emergency and bring back jobs.. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. You can transform information from historical and external sources into usable data, and you can create new data. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. 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. Each of the considerations above, as well as operation and maintenance 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 For that reason it is not included in the Drop-in document. Campus Box 3330 Process compliance audits evaluate whether the vendor is doing what it was hired to do. See M.G.L. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. Your local jurisdiction creates a demand for towing services because local officials have the authority to have vehicles towed when there are parking violations on public property or drivers need emergency roadside assistance. 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 claimed that the lower per-unit price was only for bulk purchases. BenfordsLaw should not be applied to data sets that have stated minimum and maximum values or are assigned numbers, such as interest rates, telephone numbers or social security numbers. As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E regarding Cost Principles, allowable costs are based on the premise that a recipient is responsible for the effective administration of Federal awards, application of sound management practices, and administration of Federal funds in a manner consistent with the program objectives and terms and conditions of the award. Use this button to show and access all levels. That policy will accomplish three different goals: (1) General review that a cost item is reasonable, allowable, allocable, consistently treated, and properly documented; (2) Identification of cost item as direct or indirect; and (3) Specific review of certain identified cost items, for special treatment, justification, and/or documentation. 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). 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. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. [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]. Please remove any contact information or personal data from your feedback. The team should consider gaining direct access to the vendors systems to facilitate its review. 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. April 11, 2022: Basics of Implementing the Standard Allowance. Benfords Law analysis: this analysis may highlight a vendor with billing discrepancies that warrant further review. 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. Establish attainable program goals and targets, and understand which expenditures are allowable under federal law. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. Treasury may request transfer of records of long-term value at the end of such period. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. 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. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. A local government should craft its policies and procedures so that they can be reasonably implemented by its staff. Before engaging with any vendor, do your research and review your contract closely. However, Chapter 30B does not apply to federally funded procurements if following Chapter 30B would conflict with federal laws or regulations. Recipients should note that SLFRF funds available under the revenue loss eligible use category generally may be used to meet the non-federal cost-share or matching requirements of other federal programs. 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). For example, someone from the public works department who supervises roadway paving should know whether the contractor completed the work and used the correct materials. While data includes these things, data also includes things such as time sheets, bank statements, survey responses and water meter readings. Thank you for your website feedback! Share sensitive information only on official, secure websites. Maintaining records sufficient to detail the history of procurement. 128, 40064-40068. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. However, the Office of the Inspector General (Office) recommends that local jurisdictions use an open, fair and competitive process to acquire automobile towing and storage services. Track and maintain records of all grant-related documents, including communications, receipts and invoices. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. 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. Exceptions to requirements for small purchase or formal method competitive rules. Purchases made from a vendor pursuant to a General Services Administration federal supply schedule, available for use by governmental bodies, comply with the requirements of Chapter 30B. 3) Consider publishing all sole source requests for public notice. Historical data regarding the use of a supply or service can help procurement teams project future procurement needs and build a more effective and accurate budget. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. When initiating an audit it is important to inform the vendor exactly which personnel and/or processes you will be auditing. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. We have also learned that state agencies and municipalities can start from scratch and build the capacity to rely on data as a problem-solving tool. %PDF-1.6 % Below are some general tips to keep in mind when reviewing invoices and payment requests: What if you have questions about an invoice? WebStates are required to follow their own procurement procedures as well as the Federal requirements for procurement of recovered materials and inclusion of required contract provisions per 2 C.F.R. The results of the survey can be transferred to a spreadsheet. To start, here is a summary list of UG policies and their triggers. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. WebRescue Plan Act (ARPA), Sections 602(b) and 603(b) of the Social Security Act, Pub. 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. Program Income. infrastructure, potential enhancements of state funding resources, Conducting a survey can be as simple as sending out an email or using a free online survey tool. If a recipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. The vendor provided supporting documentation for the items or services on the invoice. For this program, the city of Scranton has elected to award . A lock icon ( If you determine a need for data that does notal readyexist, you can also create data. 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 Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. Government entities that have received ARPA funding may be able to award grants to third parties. 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. WebGeneral Requirements for Procurement Programs . 559 0 obj <> endobj We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. During this session, These awards are as follows: If you are used to having a financial statement audit, a single audit can be much more comprehensive. 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