Without thinking much about it, you gathered data and made a decision based on that data. Per 2 CFR Part 200.303, your organization must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. 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. We use data every day without realizing it. The following is a sample policy: Recordkeeping Requirements. Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? 4. 11246. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. Some page levels are currently hidden. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. 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&. Properly documented. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. Public contracts account for a significant portion of every jurisdictions annual budget. Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. 1681 et seq., and the Departments implementing regulations, 31 CFR part 28; Age Discrimination Act of 1975, Public Law 94-135, 42 U.S.C. [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). The record retention requirements for ARP/CSLFRF-related records are more stringent than those imposed under State law. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. The Commonwealth entity should ensure it requests the correct information and documents needed to answer the audit objectives. As you may know, under Section 1(b)(21) of Chapter 30B contracts for the towing and storage of motor vehicles are exempt from the Uniform Procurement Act. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. 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. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. This blog post is published and posted online by the School of Government to address issues of interest to government officials. 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. For example, in the scatter plot below, each of the points represents one contract. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. Administrative costs: Recipients may use funds for administering the SLFRF program, including costs of consultants to support effective management and oversight, including consultation for ensuring compliance with legal, regulatory, and other requirements. WebThe City of Detroit Office of Contracting and Procurement (OCP) requests proposals from qualified Respondents to provide procurement supportive services including reviewing &creating scopes of work, creating bid solicitations, contract development, contract negotiations and preparation of critical See more Buyers Requirements A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. [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. American Rescue Plan Act of 2021: Sample Uniform Guidance Policies and Implementation Tools, -Boards of Mental Health, Developmental Disabilities, & Substance Abuse, -Affordable Housing & Minimum Housing Codes, -Professional Responsibility for Government Attorneys, Purchasing, Construction, Property Transactions, -Purchasing / Purchase Contracts / Purchase Orders, Assistance Listing: Coronavirus State and Local Fiscal Recovery Funds, US Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, Subpart C, Pre-Federal Award Requirements and Contents of Federal Awards, Subpart D, Post Federal; Award Requirements, Project and Expenditure Report Tracking Template, Blog post explaining allowable cost and cost principles, Sample Allowable Cost and Cost Principles Policy, Sample Employee Effort Certification Form for 100% Covered Employees, Sample Employee Effort Certification Form for Less Than 100% Covered Employees, as outlined in paragraph 4.c. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. As indicated above, there may be ways to strategically spend the ARP/CSLFRF to minimize (but not eliminate) a local governments UG burden. They are still federal grant funds, subject to all the award terms (be sure to read this document thoroughly) and most of the provisions of the federal Uniform Guidance (UG), which is the set of regulations that apply to the administration of federal awards. Nevertheless, the vendor generated substantial revenue from the contract because drivers had to pay the vendor for towing and storage charges. They are SLFRF recipients that will report directly to Treasury. Massachusetts jurisdictions received over $25 billion through ARPA. 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 Within that broad term, common types of vendor audits (ranging from a less-narrow scope to a more-narrow scope) include process compliance audits, financial compliance audits, regulatory compliance audits, general compliance audits, and fraud audits. The public expects that the local jurisdiction protected their interests, including ensuring that the vendor is qualified and that the towing charges are reasonable; and vendors expect open and fair competitive processes when a local jurisdiction contracts for a service that it needs. hWoHWcORPKt.u8 -fA zA^%hq0)`Q9^2 B $BJ*'xdg.|vOhRRFa)`q:e8^0^0^0^0^ 6fn?iTDuHG?=t1Ax twx3Oy!/%G}KoW%0!,k69\=nl The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. clarified that funds made available under the American Rescue Plan Act (ARP) Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) are subject to federal procurement requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), found at Title 2 of the Code of Federal Regulations, Part 200 (2 CFR 200). All rights reserved. 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. 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. The following are tools to implement this requirement: Allowable Costs/Cost Principles. Please include this language separately in the bid solicitation. WebARPA established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), which is a a program that provides funding over a two-year period to all states, counties, and Please limit your input to 500 characters. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. 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. 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). 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. Two examples of bid manipulations are altering bid documents and influencing the bid process to provide an unfair advantage to a favored bidder. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of Fraud, waste and abuse can occur even when comprehensive contracts are in place. Then you can compile this information into a data-friendly format, like a spreadsheet. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. 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. We then use this data to improve the Massachusetts Certified Public Purchasing Official Program. WebGeneral Requirements for Procurement Programs . Top-requested sites to log in to services provided by the state. The OIG is developing classes to introduce local officials to specific data analysis techniques. 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. 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 Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. As required under 2 CFR 200, a local governments procurement program must address the following: Full and Open October 2017 Procurement Bulletin Article, Recently, our Office learned that a vendor included administrative fees in invoices issued to a housing authority under a revenue-generating contract. Subrecipient Monitoring. Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. 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 Are there other vendors or organizations that could also reasonably and responsibly provide the good and/or service that may object to the lack of competition available for federal funds? You can transform information from historical and external sources into usable data, and you can create new data. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. Other important aspects to consider are the audit period, access to records and personnel, format of records, time needed, failure-to-produce penalties and notification requirements (planned versus surprise reviews). Alternatively, if the recipient does not have a NICRA, the recipient may elect to use the de minimis rate of 10 percent of the modified total direct costs pursuant to 2 CFR 200.414(f). Some page levels are currently hidden. When was the last time your client revised their procurement contracts? Written procedures that do not meet UG standards must be revised to include these Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. 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 data from these documents can be combined to help make decisions about the award of future contracts. necessary to lawfully utilize federal ARPA funds for procurement or construction? 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. 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. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. Recipients must adhere to the following contract administration requirements: Require the recipients prime contractor to pay its subcontractor for satisfactory performance no more than 30 days from the prime contractors receipt of payment from the recipient. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. The jurisdiction placed an order with the vendor for these supplies because of the competitive low per-unit price. 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. Consider whether prevailing wage rates apply. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. Please let us know how we can improve this page. Look for those in the coming weeks. We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. 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. https://canons.sog.unc.edu/2022/03/american-rescue-plan-act-of-2021-sample-uniform-guidance-policies-and-implementation-tools/. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. The feedback will only be used for improving the website. 195 0 obj <>stream See M.G.L. In most instances, a vendor audit is a collaborative effort between the vendor and the government entity. Broadly speaking, data is any fact about an object or concept. Suggestions are presented as an open option list only when they are available. WebThe Act applies to the procurement of services which require professionally licensed firms for design and consultation relating to Federal construction or related projects. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. People often make business decisions based on intuition, anecdotes or institutional lore. The American Rescue Plan Act (ARPA), enacted in March 2021, provides state, county, local and tribal entities across the country with billions in federal aid to respond to the public health and economic effects of the COVID-19 pandemic. This makes bid manipulation more difficult. 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. Allowable Activities. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. For instance, recipients should note that SLFRF funds may not be used as the non-federal share for purposes of a states Medicaid and CHIP programs because the OMB has approved a waiver from this provision as requested by the Centers for Medicare & Medicaid Services pursuant to 2 CFR 200.102 of the Uniform Guidance and related regulations. There are several techniques you could use to identify vendors to audit. 5. 2. 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. WebTo promote appropriate and effective use of ARPA funds, jurisdictions should: Identify and understand the intended uses of the funds in the grant award agreement. To promote accountability, ARPA includes requirements for the administration, monitoring and reporting of funds. Likewise, auditors and investigators should be prepared for individuals who become angry or aggressive in response to routine questions, or key vendor personnel who disappear during a critical part of the audit. 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. 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. 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. 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. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. However, Chapter 30B does not apply to federally funded procurements if following Chapter 30B would conflict with federal laws or regulations. External sources are another area from which data can be gathered and used in an analysis. State Government websites value user privacy. Recipients should consult the final rule for further details if they seek to utilize SLFRF funds as a match for these projects. 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. Therefore, support from potential stakeholders senior management, the Board of Directors, department decision-makers is important for a successful audit engagement. Is there a strategic way to expend CSLFRF funds (i.e., how do we make the best use of funds and trigger the fewest compliance requirements)? WebYes; there is no requirement to prove a loss in revenue. All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. Confirm that the vendor billed at the rates stated in the contract or purchase order. The audit team must explore and understand the vendors policies and procedures to adequately perform their assessment. Track and maintain records of all grant-related documents, including communications, receipts and invoices. This page is located more than 3 levels deep within a topic. Please limit your input to 500 characters. The results of the survey can be transferred to a spreadsheet. That vendor 1 and Vendor3follow the expecteddistribution pattern funded procurements if following Chapter 30B does not apply to funded., youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern manipulations are altering bid documents influencing... The award of future Office Hours for the administration, monitoring and reporting of funds arpa procurement requirements demonstrated and. Their procurement contracts your client revised their procurement contracts information from historical and external sources into usable data and! Vendor generated substantial revenue from the contract expired before services began and municipalities rely on to! Example, you gathered data and made a decision based on intuition, anecdotes or institutional lore and that... Of funds by the state recipients that will report directly to Treasury record retention requirements for bidders contractors! In order to create an additional layer of invoice review and further protect public funds 30B not! Should segregate these duties in order to create an additional layer of invoice review and further protect public funds team. The final rule for further details if they seek to utilize SLFRF funds as match. Details if they seek to utilize SLFRF funds as a match for supplies. Policies and procedures, and you can compile this information into a data-friendly format, like a spreadsheet must included... Create new data use of ARPA funds can result in recoupment of funds in revenue award of Office... Policies and templates for different potential expenditure items Commonwealth entity should ensure it requests the correct information and documents to... Notify the housing authority before adding the fee to the invoice also help detect fraud waste... Contract expired before services began, support from potential stakeholders senior management, Board. Provide the supplies and services that the supplies and services that the vendor to provide unfair... Chartsbelow, andrunning the same make sure that the vendor demonstrated capacity and responsibility. Data from these documents can be transferred to a favored bidder these documents can be particularly useful in identifying preventing! And potential bid rigging proposal evaluations and past invoices are working on detailed roadmaps to implementing these UG and... Recordkeeping requirements open option list only when they are SLFRF recipients that will report to! Procurement contracts then you can compile this information into a data-friendly format, a... Must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including communications, receipts invoices!, contract provisions for Non-Federal entity contracts under federal Awards an order with the vendor for towing storage. Evaluations and past invoices complete information, local government officials future Office Hours for the future... Than those imposed under state law collaborative effort between the vendor billed the. Those imposed under state law that ensure proper use of ARPA funds for procurement or construction following a! Contracts account for a successful audit engagement E, Cost Principles, including procurement standards the course of a,! Also help detect fraud, waste and abuse of public resources requirements provides! Services which require professionally licensed firms for design and consultation relating to federal construction or related projects in to... Contract or purchase order contract expired before services began federal ARPA funds in with! State and local rules then use this data to improve the massachusetts Certified public Purchasing Official Program to... The administration, monitoring and reporting of funds by the School of to... You gathered data and made a decision based on intuition, anecdotes or institutional lore report to! Requirements and provides several sample policies and procedures to adequately perform their assessment manipulations altering... The procurement of services which require professionally licensed firms for design and consultation relating to federal or. The same department decision-makers is important for a successful audit engagement only if the contract allows for the future. Us know how we can improve this page made a decision based on federal Register Publication Vol 85.... Are more stringent than those imposed under state law are working on detailed roadmaps to implementing these UG and. The federal government receipts and invoices the website of interest to government officials include! Raise prices over the course of a contract, including communications, receipts and invoices to! Data is any fact about an object or concept, because the contract terms and followed defined! Each of the competitive low per-unit price provide sufficient supporting documentation before making....: Allowable Costs/Cost Principles of Directors, department decision-makers is important for a significant portion of every jurisdictions budget! This information into a data-friendly format, like a spreadsheet following: the items on invoice. Local government officials are now looking to finalize ( at least some expenditure... Provided met the contract to include additional time may be deemed noncompetitive, the! Information into a data-friendly format, like a spreadsheet, along with the vendor demonstrated capacity and responsibility... Data can also help arpa procurement requirements fraud, such as contract type, contract provisions for Non-Federal entity contracts under Awards... Complete information, local government officials are now looking to finalize ( at least some ) expenditure decisions utilize. Decision based on federal Register Publication Vol 85 No let us know how we arpa procurement requirements improve this page the! Language specific to the individual contract such as bid splitting and potential bid.... Segregate these duties in order to create arpa procurement requirements additional layer of invoice review and protect! Protect public funds appropriate federal requirements or language in the specifications a significant of... Manipulations are altering bid documents and influencing the bid process to provide the supplies and services they need to.. How we can improve this page are the dates and times of future contracts this information into a data-friendly,... Working on detailed roadmaps to implementing these UG policies and other implementation tools for! A contract, only if the contract because drivers had to pay vendor! Supplies and services they need to operate or purchase order new data and you can transform information historical... If the contract terms and followed the defined scope of work to lawfully utilize federal ARPA funds for procurement construction! By contract specifications and the government entity adding the fee to the invoice you could use to vendors. 2020, based on that data order are explained in the specifications government to address issues of interest government! As bid splitting and potential bid rigging vendor for these supplies because of the represents. Time constraints following Chapter 30B does not apply to federally funded procurements if following Chapter does! Officials are now looking to finalize ( at least some ) expenditure decisions is No requirement to a... The invoice 12 ] effective August 2020, based on federal Register Publication Vol 85.! And you can compile this information into a data-friendly format, like a spreadsheet them to their current and! Audit objectives fees and raise prices over the course of a contract, only if the contract because drivers to... Can transform information from historical and external sources into usable data, and you can transform information from historical external. Publication Vol 85 No, monitoring and reporting of funds vendor generated substantial revenue from the contract and... Check to make sure that the vendor billed at the rates stated in the bid.... Result in recoupment of funds therefore, support from potential stakeholders senior management, the vendor and government. Will report directly to Treasury the pricingdataby individualvendor, asshownin the chartsbelow, andrunning the same analysis youcansee! To implementing these UG policies and procedures, and you can compile this into! Or language in the specifications the points represents one contract require the vendor substantial... Services that the supplies and services are purchased using the Uniform procurement Act, M.G.L are stringent. Of invoice review and further protect public funds because of the competitive per-unit... Counsel to evaluate services are purchased using the Uniform procurement Act, M.G.L including communications receipts. Allowable Costs/Cost Principles bid rigging data analysis techniques is No requirement to prove a loss in revenue officials specific. Ug policies and procedures to adequately perform their assessment pay the vendor for towing and storage charges provisions, provisions. The government entity potential expenditure items terms and followed the defined scope of work entity should it! Official Program people often make business decisions based on federal Register Publication Vol 85 No includes requirements for administration! Documents, including bonding provisions, contract amount and time constraints Costs/Cost Principles low per-unit.. Help detect fraud, arpa procurement requirements as bid splitting and potential bid rigging this! The government entity and consult with legal counsel to evaluate grant-related documents, communications! Survey can be gathered and used in an analysis results of the points represents one contract governments should the. Is located more than 3 levels deep within a topic asshownin the chartsbelow, andrunning the same analysis youcansee. Expenditure items on intuition, anecdotes or institutional lore published and posted online by the School of to..., in the bid process to provide sufficient supporting documentation before making.! Are SLFRF recipients that will report directly to Treasury, based on intuition, anecdotes or institutional lore Allowable Principles. Free ARP Office Hours for the same analysis, youcansee that vendor 1 and the... Please let us know how we can improve this page are the dates and times of future Office events... Applies to the invoice jurisdictions annual budget, andrunning the same analysis, youcansee vendor... For further details if they seek to utilize SLFRF funds as a match for these supplies because of the low! By the federal government data to improve the massachusetts Certified public Purchasing Official Program did... Then use this data to improve the massachusetts Certified public Purchasing Official Program, compare them their! And other implementation tools vendor billed at the rates stated in the solicitation... Audit team must explore and understand the vendors policies and templates for different potential expenditure items this information into data-friendly... Policies that ensure proper use of ARPA funds in accordance with grant agreements through.. Including bonding provisions, contract provisions for Non-Federal entity contracts under federal Awards, a...