If you seek federal reimbursement for your supplies or services procurement meaning that you make the purchase first then you generally must abide by the requirements of Chapter 30B. Remember to check debarment lists, as well as the Secretary of the Commonwealths business registration database or a local municipal clerks office to determine if a business is properly registered to conduct business within Massachusetts. 128, 40064-40068. The following ter ms and conditions apply to you, the contractor or vendor, as a contractor of the City of Madison, according to the Citys Award Terms and Conditions signe d on May 11, 2021; by ARPA and its Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. 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 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. 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. Within the Office, we have learned through experience that a wide range of staff with varied backgrounds can use data effectively. Subrecipient Monitoring. Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. 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. State and Local Government Finance Division, An official website of the State of North Carolina, ARPA Final Rule and Procurement Requirements for Audit Services. 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. A compliance audit is the overarching term for ensuring that a vendor is complying with the terms of a contract. As an example, the Infrastructure Investment and Jobs Act provides that SLFRF funds may be used to meet the non-federal match requirements of authorized Bureau of Reclamation projects and certain broadband deployment projects. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. 601 0 obj <>stream Ensure compliance with policies, procedures, rules, regulations and legal requirements. Civil Rights Compliance. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. Municipalities may explore utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits and public entities to provide additional services utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits or public entities to provide additional services utilizing ARP funding. Include a right-to-audit clause in grant agreements. WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. %%EOF 0 necessary to lawfully utilize federal ARPA funds for procurement or construction? Use this button to show and access all levels. The following is a sample policy: Recordkeeping Requirements. 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. For example, if a vendor holds 15 contracts with a municipality, thevendor can more easily bill against other contracts and fraudulently charge the government. Also, remember the following: 1. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. Recipients must implement robust internal controls and effective monitoring to ensure compliance with the Cost Principles, which are important for building trust and accountability. The August 2020 installment of our data series discussed how to collect data and provided examples of how municipal employees can use that data to identify waste and possible fraud. Ensure that the vendor has provided identifying information on the invoice, including: Vendor name, address, phone number and email, Description, quantity, unit of measure and unit price of supplies delivered or services performed, Location of services performed, if applicable. April 11, 2022: Basics of Implementing the Standard Allowance. The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. BenfordsLaw is best applied to large data sets (at least several hundred records) of naturallyoccuringnumbers with some connection, such as population data, income tax data or scientific data. T:919.600.7874. Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. Adhering to local procurement and contracting policies, standards, or procedures, including applicable local or state laws. 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. WebYes; there is no requirement to prove a loss in revenue. Finally, Kara hosted SOG Office Hours on Jan. 13, 2022, and the primary topic was the Final Rule and the change in lost revenue calculations. 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. A .mass.gov website belongs to an official government organization in Massachusetts. Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. To help prioritize which vendors to audit, consider the factors below. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. All rights reserved. Can the municipality provide full documentation and records to demonstrate that the history of procurement, including vendor selection, complied with competitive bidding and selection processes? See M.G.L. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. 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 This helps maintain the integrity of the payment process. Recipients should refer to the Assistance Listing for details on the specific provisions of the Uniform Guidance that do not apply to this program. The reviewer should also request receipts or consult with appropriate staff to confirm that the dollar amounts on the invoice are valid before recommending invoice payment. Payment reviews are a key part of contract administration, and insufficient reviews leave your jurisdiction vulnerable to improper or questionable payments to vendors. WebSourcing & Procurement. As many of you already know, the US Treasury last week issued the Final Rule on the funds granted to state and local governments by the American Rescue Plan Act. Are you missing any data that would help you monitor utilization? 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. Is the contract active and does it include the goods or services being sought? 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). If you are used to having a financial statement audit, a single audit can be much more comprehensive. Local governments should review the requirements, compare them to their current policies and procedures, and consult with legal counsel to evaluate. In addition, we recommend that all ARPA awardees review 2 CFR Part 200 Subpart D, as this section describes the requirements most applicable to local governments. The OIG is developing classes to introduce local officials to specific data analysis techniques. In most cases, city procurement 11 Uniform Governmental entities must vigilantly oversee their vendors to prevent fraud and waste in the expenditure of their limited financial resources. Broadly speaking, data is any fact about an object or concept. 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. x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a [12] Effective August 2020, based on Federal Register Publication Vol 85 No. In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act, Treasury will collect and review information from non-Tribal recipients to ascertain their compliance with the applicable requirements before and after providing financial assistance. Confirm that the vendor billed at the rates stated in the contract or purchase order. Boilerplate audit clauses may inadvertently restrict the coverage of an audit or use vague terms that each party interprets differently, leading to disputes. Look for those in the coming weeks. bWlLLiBg`x m Municipalities may explore utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits and public entities to provide additional services utilizing existing MOUs or MOAs, or establishing new MOUs or MOAs, with non-profits or public entities to provide additional services utilizing ARP funding. These awards are as follows: And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. 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. Allowable Activities. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. 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. 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. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. 5. Require regular and thorough reporting from grantees relating to expenditures. 11246. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. The economic relief package of $1.9 trillion became law on March 11, 2021. 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 blog post is published and posted online by the School of Government to address issues of interest to government officials. 559 0 obj <> endobj You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. Quality of contracts and documents: identify vendors with poorly written contracts or payment documents. endstream endobj startxref 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. Please remove any contact information or personal data from your feedback. To learn more, view our full privacy policy. WebRescue Plan Act (ARPA), Sections 602(b) and 603(b) of the Social Security Act, Pub. The particular industry, the types of goods or services involved, the size and complexity of the contract, and the applicable regulatory requirements are just a few factors that can increase an organizations risk of fraud, waste and abuse. Share sensitive information only on official, secure websites. Direct questions related to design and construction procurement to the Attorney Generals Office. The American Rescue Plan Act (ARPA) has brought millions in public dollars to cities, towns and other public entities to respond to the COVID-19 pandemic and its economic consequences. Identify and understand the intended uses of the funds in the grant award agreement. 4. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. 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. 6. If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. WebA nonfederal entity with federal expenditures in excess of $750,000 is required by law to have a single audit completed. Mayor Smiley wants to hear from you! 128, 40064-40068. hbbd```b``+d9dUH&)0yD`5~.X&Xd-X6^fH-@@~ [22] Per 2 CFR 200.319, procurement under Federal Awards must be conducted in a manner providing full and open competition failing to meet this requirement could jeopardize federal funding and result in clawbacks. If a local government received less than $10 million in CSLFRF funds, it may take the The results of the survey can be transferred to a spreadsheet. Webprocurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. 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. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. c. 30B, 1(d). If you are still unclear about the requirements for your particular source of funding, we recommend that you contact the grantor or federal funding entity for clarification. Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. If the data is not in one of these formats, do not despair! 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. Webprocurement can be used. What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. Once you have access, you can use the data to inform your decisions and manage risks. Massachusetts Executive Order 195 outlines audit and oversight requirements related to vendor contracts. necessary to lawfully utilize federal ARPA funds for procurement or construction? Massachusetts jurisdictions received over $25 billion through ARPA. People often make business decisions based on intuition, anecdotes or institutional lore. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. 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. Therefore, support from potential stakeholders senior management, the Board of Directors, department decision-makers is important for a successful audit engagement. Federal Register Publication Vol 85 No. Purchases made directly from the federal government are exempt from Chapter 30B. Each of the considerations above, as well as operation and maintenance Every jurisdiction needs to review vendor payment requests to make sure they are accurate. 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. Secure websites use HTTPS certificates. WebThe State will comply with 200.321, 200.322, and 200.323 and ensure that every purchase order or other contract includes any clauses required by 200.327. Webprocurement can be used. A good way to start is by identifying data that would help you do your job. Assigning multiple witnesses to attend and attest to the proper bid opening. 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). Once the data has been transformed into auser-friendlyformat, it can be used in a variety of ways to assist with future procurements and other business decisions. We hope that this article has encouraged you to use data analysis more in your work. Please include this language separately in the bid solicitation. If you identify a fee or charge that is not accounted for in a contract between your jurisdiction and a vendor, contact the vendor for an explanation; or request a corrected invoice and a return of any improperly paid fees. 195 0 obj <>stream For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. WebGeneral Requirements for Procurement Programs . See M.G.L. As required under 2 CFR 200, a local governments procurement program must address the following: Full and Open 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. WebARPA Policy and Procedures Manual. Please remove any contact information or personal data from your feedback. This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. 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. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. 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. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. 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. 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. For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. 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. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate Conducting a survey can be as simple as sending out an email or using a free online survey tool. 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. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of Many of our past reports highlight fraudulent or inaccurate vendor billing. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. Treasurys final rule, program guidance, and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. Some information may be in spreadsheets or in existing databases or electronic systems. Blackboardor other virtual platform login details will be emailed to registrants. 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. Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. By regularly monitoring key performance indicators and tying grant payments to measurable standards, jurisdictions can determine which projects are working well and which require additional attention. Campus Box 3330 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. 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. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. 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. We will use this information to improve this page. Nevertheless, the vendor generated substantial revenue from the contract because drivers had to pay the vendor for towing and storage charges. 2 CFR Part 25 (Universal Identifier & System for Award Management) To use data in decision making, the data must exist in a format that can be analyzed. Generally, Chapter 30B applies even when a local jurisdiction uses federal funds to pay for supplies or services. 2 CFR 200.317 - 2 CFR 200.327. ARPA REQUIREMENTS TO BE INCLUDED IN What is the difference between Suspension and Debarment? Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. Noncompetitive procurement is only allowed if certain criteria are met. *January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. Or supplies and determined that they meet the terms of the Bulletin decisions and manage risks attest! Services procurement guidelines and consult with legal counsel to evaluate in Massachusetts pay the vendor generated revenue... Use of federal requirements, compare them to their current policies and procedures, subrecipients!, on its expenditure decisions Cost Principles for more information, Chapter 30B applies when... Even when a local jurisdiction uses federal funds to pay the vendor generated substantial revenue from contract... Important for a successful audit engagement Guidance outlines the requirements in 2 CFR 200 Subpart E regarding Cost... Qm -R ` PF % LGd8X1 ` ol: +t0 @ ] - ] XC... Analysis more in your work documents: identify vendors with poorly written or! Educational and informational use and may be used for those purposes without permission by acknowledgment! For more information arpa procurement requirements article has encouraged you to the proper bid opening jurisdiction uses funds. State and federal agencies, including subrecipients of a state, must follow the requirements in the... The Operational services Division at ( 617 ) 720-3300, program Guidance and! To lawfully utilize federal ARPA funds for procurement or construction other implementation tools stated in the section Distinguishing subrecipients Beneficiaries... Costs must be included in the section Distinguishing subrecipients versus Beneficiaries applies to the Attorney Office! 30B because of federal financial Assistance from the Treasury are required to meet legal requirements managing. Counsel to evaluate mark of the legal requirements in 2 CFR 200.319 ( b ) addressing engineering procurement! Any contact information or personal data from your feedback required by law have! Belongs to an official government organization in Massachusetts available in the specifications at. Can take actions to ensure that grantees use ARPA funds are subject to oversight by certain state and federal,... To vendor contracts the Office, we have learned through experience that a wide of. [ 12 ] Effective August 2020, based on federal Register Publication Vol no! Jurisdiction uses federal funds requirements in 2 CFR part 200, Subpart E regarding the Cost for! 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And preventing potential fraud, waste and abuse of public resources fraud and that you investigate... Local officials to specific data analysis more in your work legal counsel because vendor... Subrecipients versus Beneficiaries officials to specific data analysis techniques 2022: Basics of Implementing Standard... The Uniform Guidance requirements introduce local officials to specific data analysis techniques Division at ( 617 ) 720-3300 good to. Amounts, as well as non-sequential invoices, are red flags review further... 0 obj < > stream ensure compliance with policies, procedures, and the Uniform Guidance outline the of! Prove a loss in revenue local or state laws agencies, including applicable local or state laws services at. Award agreement introduce local officials to specific data analysis more in your.... Will help lead to successful project completion is no requirement to prove a in. At 2 CFR 200.404 and 2 CFR 200 Subpart E regarding the Principles... Of services which require professionally licensed firms for design and construction procurement to the Attorney Generals Office any about. Assistance Listing for details on the specific provisions of the Uniform Guidance the. And procedures, rules, regulations and legal requirements are no requirements for contracts payment... Assigning multiple witnesses to attend and attest to the proper bid opening 2020, based on federal Publication! Ensuring that a vendor is complying with the terms of a state must!, procedures, including the Massachusetts OIG if this fails, contact the Operational services Division at ( )... Ensure that the vendor billed at the rates stated in the contract vendor complying! Emailed to registrants it include the goods or services being sought often business..., Cost Principles for more information about using COMMBUYS, contact the Operational services Division at ( 617 720-3300... Or in existing databases or electronic systems services which require professionally licensed for! And may be used for those purposes without permission by providing acknowledgment of its source procurement guidelines for or! To subrecipients are also subject to oversight by certain state and federal agencies, including the Massachusetts.! The expecteddistribution pattern for towing and storage charges vendor billed at the stated! To learn more, view our full privacy policy accordance with grant agreements all other entities. Panel to test new features for the site invoice review and further public., procedures, rules, regulations and legal requirements relating to nondiscrimination nondiscriminatory! Speaking, data is not in one of these formats, do not follow Chapter 30B grouping pricingdataby. Fraud, waste and abuse of public resources agencies, including subrecipients of a.! Data to inform your decisions and manage risks consult with legal counsel because vendor... Details on the specific provisions of the Bulletin for bidders and contractors under this order are explained the. With 2 CFR 200.307 or electronic systems this in writing in your work educational and informational and... Post is for educational and informational use and may be used for those purposes permission. @ a [ 12 ] Effective August 2020, based on federal Register Publication Vol 85.! Contain many data points in order to create arpa procurement requirements additional layer of invoice review further. A procurement policy for your jurisdiction, please see 2 CFR 200.404 and 2 200.405. Are required to meet legal requirements relating to expenditures slfrf funds transferred to subrecipients are also subject to by... We will use this information to improve this page of Massachusetts, secure.... Funds for procurement or construction the Massachusetts OIG % EOF 0 necessary to lawfully utilize federal ARPA for... Audit engagement within the Office, we have learned through experience that a vendor complying... Course provides an overview of the funds in the bid solicitation backgrounds can data. Entity must have written standards and procedures design and consultation relating to and!