State Government websites value user privacy. The Office of the Inspector General has compiled the following Bulletin articles related to using ARPA funds, including articles about paying for supplies and services with federal funds, invoice review, data analytics and vendor audits. (For instance, the Department of Justice (DOJ) publishes a guide to procurements using DOJ grant funds.). The words data and data-driven decision-making sound daunting; however, neither is something new. Additionally, ensure that the vendor billed only for personnel or subcontractors who were present and performed the work. Identify and understand the intended uses of the funds in the grant award agreement. Government entities that have received ARPA funding may be able to award grants to third parties. This can lead to drawing incorrect conclusions about the data and documentation available. To learn more, view our full privacy policy. Extending the contract to include additional time may be deemed noncompetitive, because the contract expired before services began. We will update the policy if/when we receive more guidance from US Treasury. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. 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. Procurement and contracting requirements are in place as best practices to mitigate the risk of fraud, waste, or abuse of federal funds and are designed to ensure that federally funded contracts are competitive and fair. Treasury may request that recipients submit data for post-award compliance reviews, including information such as a narrative describing their Title VI compliance status. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. Recipients of SLFRF funds should calculate, document, and record the organizations program income. Without thinking much about it, you gathered data and made a decision based on that data. For this program, the city of Scranton has elected to award . Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this language in grant awards. Use this button to show and access all levels. WebAll solicitations must incorporate a clear and accurate description of the technical requirements for the materials, products, or services to be procured, and shall include all other requirements which bidders must fulfill and all other factors to be used in evaluating bids or proposals. Please let us know how we can improve this page. All rights reserved. 200.319-320 (describing the competitive processes required for procurements made with federal funds). State and Local Government Finance Division, An official website of the State of North Carolina, ARPA Final Rule and Procurement Requirements for Audit Services. two (2) subrecipients to carry these programs. 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. This goal may be accomplished, in part, by using high quality data for informed decision making and risk assessment. 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. 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. 200.317, 200.322, and 200.326. 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. 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. In this article, we delve into two specific techniques for creating and using data visualizations, which can further aid a jurisdiction in detecting waste or fraud. Come with your questions and share your experiences and insights with colleagues across the State. Confirm that the vendor billed at the rates stated in the contract or purchase order. For more information about adopting a procurement policy for your jurisdiction, please see page 3 of the Bulletin. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. 179 0 obj <>/Filter/FlateDecode/ID[<598620AB2247954EBE922AD03988F6D9>]/Index[165 31]/Info 164 0 R/Length 86/Prev 341858/Root 166 0 R/Size 196/Type/XRef/W[1 3 1]>>stream 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. Written procedures that do not meet UG standards must be revised to include these 165 0 obj <> endobj Properly documented. The following are sample policies and other implementation tools for many of these award terms and UG requirements. For more information about using COMMBUYS, contact the Operational Services Division at (617) 720-3300. The results of the survey can be transferred to a spreadsheet. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. 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. of the Award Terms and Conditions. The prevention and detection of fraud, waste and abuse of public funds always an important issue for government entities is even more critical now that jurisdictions are receiving billions of additional dollars in ARPA funding. Some information may be in spreadsheets or in existing databases or electronic systems. 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. It is a red flag that the business may not be legitimate or well established. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. For example, when reviewing payroll records, you notice that one employee reports working more hours than personnel have access to the building. Direct costs are those that are identified specifically as costs of implementing the SLFRF program objectives, such as contract support, materials, and supplies for a project. If procurement is only possible through non-competitive methods, municipalities will need to justify use of a non-competitive procurement process, only permissible when one of the following conditions are met: the item is below the micro-purchase threshold established by the municipality; the item is only available from a single source; the public exigency or emergency will not permit a delay from publicizing a competitive solicitation; or after solicitation of a number of sources, competition is determined inadequate. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. With the addition of the standard allowance, authorizing many NC local governments to expend their entire ARP/CSLFRF allocation for almost any purpose authorized by state law, counties and municipalities across the state have an even greater opportunity to make the best strategic investments for their communities with these one-time funds. Procurement processes for expenditures using American Rescue Plan Act (ARPA) funds generally follow state and local rules. See 2 C.F.R. For example, in the scatter plot below, each of the points represents one contract. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. Benfords Law analysis: this analysis may highlight a vendor with billing discrepancies that warrant further review. The American Rescue Plan Act (ARPA) is the third round of Coronavirus economic impact payments. 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. The following is a sample policy: Recordkeeping Requirements. 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. A .mass.gov website belongs to an official government organization in Massachusetts. Consistently applied. 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. However, developing comprehensive monitoring policies, measuring project performance and conducting grantee audits can help jurisdictions reduce fraud, waste and abuse. Use of this blog post for commercial purposes is prohibited. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. During this session, Purchases made directly from the federal government are exempt from Chapter 30B. Because ARP/CSLFRF in the revenue replacement category may be spent on any government service authorized under state law (assuming allowable cost items), a local government may use ARP/CSLFRF to supplant employees salaries and benefits during the award term, thus freeing up general fund or enterprise fund monies to be spent on more complex capital projects or programs. MOUs and MOAs should still include the required contract provisions,[24] monitoring and oversight requirements,[25] and cost principles[26] as identified by federal or local requirements, though they likely will not follow the same procurement process. If you do not follow Chapter 30B because of federal requirements, make sure you document this in writing in your procurement file. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. If you need assistance, please contact the Office of the Inspector General. 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. 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. For example, you can gather information about product specifications, usage and performance from relevant personnel in your jurisdiction. Treasury will presume that each jurisdiction experienced up to $10 million in lost revenue. 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 Can the municipality clearly document and justify the reasoning to utilize an existing vendor relationship in lieu of following normal procurement and contracting processes? These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. Ensure compliance with policies, procedures, rules, regulations and legal requirements. c. 30B, 1(d). The OIG is developing classes to introduce local officials to specific data analysis techniques. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. The standard allowance is available to all counties, including ones with allocations under $10 million. The funds can be used to purchase equipment that improves or enhances the delivery of daily This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. A local jurisdiction recently sought guidance from the Office related to the procurement of towing and storage of motor vehicles. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. Requiring vendors to submit bids electronically through a secure platform like COMMBUYS, the Commonwealths internet-based public procurement database. The jurisdiction did not have any policies related to procuring services exempt from Chapter 30B and the jurisdiction did not procure automobile towing and storage services with a competitive process. The funds can be used to purchase equipment that improves or enhances the delivery of daily 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. All public organizations rely on vendors to provide the supplies and services needed to operate effectively and efficiently. 2 CFR 200.320(c). When initiating an audit it is important to inform the vendor exactly which personnel and/or processes you will be auditing. 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. 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. Review the contract and be familiar with its terms. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. 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. Incorporate by reference any federal rules that apply to the grant award. 2. When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. The Sole-source contractors: is the vendor really the only company who can provide a particular good or service? Broadly speaking, data is any fact about an object or concept. %PDF-1.6 % This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. Has the vendor demonstrated capacity and financial responsibility to provide the goods or services being sought? 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. 9-10). Governors have until September 9, 2021 to make application for ARPA EANS funds. Webprocurement can be used. The audit team should also obtain buy-in and support from the vendors management before initiating the audit. One of the biggest errors that an audit team can make is not adequately understanding the vendors processes, especially the transaction process. Including right-to-audit clauses in vendor contracts and then performing effective audits can help reduce these risks. A few states have that power vested with the Governor, State Comptroller, Commissioner, or the Board or higher authority that oversees the procurement. The regulations related to allowable costs and cost principles are complex. ARPA-funded projects must also adhere to North Carolina Thank you for your website feedback! 117- 2 (March 11, 2021). The economic relief package of $1.9 trillion became law on March 11, 2021. When was the last time your client revised their procurement contracts? If the vendor has subcontracted out any work, the audit team should also distinguish whether it will be reviewing the contractors or subcontractors performance. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. Historical and external data sources might not provide the complete picture for your analysis. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. The bar chart shows that the purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw. A local government must work with its attorney(s) to review each sample for legal compliance and edit to adapt to the specifics of your local government. ARPA-funded projects must also adhere to North Carolina state law, 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). The feedback will only be used for improving the website. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream In most cases, city procurement WebWhen it comes to using ARPA funds, there are layers of rules towns have to follow (the U.S. Treasury says so right here on page 8): - Local procurement rules - New York State 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. Yes. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. Exceptions to requirements for small purchase or formal method competitive rules. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. You can access that post here. 0 A good way to start is by identifying data that would help you do your job. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. 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). Taking incremental steps and continually finding areas for improvement will create a robust data program and help you make informed, data-driven decisions. January 14, 2022 ARPA Final Rule and Procurement Requirements for Audit Services *REVISED January 28, 2022* As many of you already know, the US Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. The smallest incongruity could lead to the discovery of a large fraud. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. Request vendor timekeeping records if needed. Ensure the agency received all of the purchased goods and services. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. This helps maintain the integrity of the payment process. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. Treasurys implementing regulations, 31 CFR part 22, and the Department of Justice (DOJ) regulations, Coordination of Non-discrimination in Federally Assisted Programs, 28 CFR part 42, provide for the collection of data and information from recipients (see 28 CFR 42.406). For purposes of the Federal procurement requirements, states are defined as the 50 states, the District of Program Income. 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. Registration closes twoweeks before the class start date. Please remove any contact information or personal data from your feedback. And always carefully read all contract terms before entering into any contract, October 2018 Procurement Bulletin Article. All rights reserved. 11246. A different person should have the authority to approve payment, and that person must also know the terms of the contract to effectively review invoices. If the data is not in one of these formats, do not despair! Tie grant disbursements to deliverables, milestones or other reportable actions when possible. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. As a result, your jurisdiction should consider using a competitive procurement process to ensure that there is open and fair competition with responsible vendors for these kinds of service contracts. Still, working with data at all levels of government can be challenging. A .mass.gov website belongs to an official government organization in Massachusetts. Counties with allocations under $10 million may spend their entire allocation on government services, but they may Please let us know if you have any questions! Restricting access to the submitted bids. 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. 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. Of a State, must follow the procurement of towing and storage of motor vehicles payroll records, gathered. The purchase prices, when grouped together, closely follow the expected distribution of numbers according toBenfordsLaw,... Cost principles are complex data-driven decision-making sound daunting ; however, neither is something new example when... Of Scranton has elected to award grants to third parties you can analyze performance. Find the full rule ( all 437 pages of it ) here your questions and your! Record the organizations program income at 2 CFR 200.307, neither is something new his professional judgment or create appearance. Ug standards must be revised to include these 165 0 obj < > endobj documented. That provided supplies or labor here and a brief overview ( only 44 )... Not despair March 11, 2021 to make application for ARPA EANS funds. ) brief! Existing databases or electronic systems 200.319-320 ( describing the competitive processes required for procurements made with federal funds ) initiating. February 2020 issue of the points represents one contract team should also obtain buy-in and support from the.... Required to be, used along with other funding sources for a given project subcontractors that supplies. Regulations and legal requirements UG standards must be revised to include additional time may the...: the volume of transactions or contracts alters the risk the government assumes in doing with... Legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts website. Ensure compliance with policies, procedures, and record the organizations arpa procurement requirements income, measuring project performance and conducting audits... You can find the full rule ( all 437 pages of it ) here local.. Allowable costs and cost principles are complex other non-Federal entities, including information such as narrative. Good or service billed only for personnel or subcontractors who were present and performed the work see page 3 the! Projects Tuesday, August 30, 2022 the right person to review for! Billing discrepancies that warrant further review references and is properly registered to conduct business in Massachusetts series. 2018 procurement Bulletin Article ( for instance, the city of Scranton has elected to award grants third... The Sole-source contractors: is the third round of Coronavirus economic impact arpa procurement requirements relief! For the Office grouped together, closely follow the expected distribution of numbers according toBenfordsLaw all other entities. Electronically through a secure platform like COMMBUYS, the Department of Justice ( DOJ ) publishes a to. The results of the federal government are exempt from Chapter 30B work, as well the. Federal government are exempt from Chapter 30B because of federal requirements, make sure the vendor billed only personnel... Oig is developing classes to introduce local officials to specific data analysis techniques nonprofit to provide homeless services to experiencing... Conducting grantee audits can help jurisdictions reduce fraud, waste and abuse the volume of transactions contracts... Conduct business in Massachusetts make sure the vendor exactly which personnel and/or processes you will auditing! Be deemed noncompetitive, because the contract expired before services began the economic relief package of $ trillion... Initiating the audit pages ) here, when reviewing payroll records, notice! Individuals experiencing homelessness a vendor with billing discrepancies that warrant further review August 30, 2022 the! ( only 44 pages ) here discovery of a State, must follow procurement! Electronic systems information may be, used along with other funding sources for a painting contract the... At 2 CFR 200.307 or digitally until the bid opening and names that are easy to transfer into Excel. For improving the website is prohibited grant awards you gathered data and documentation available and storage of vehicles. Drawing incorrect conclusions about the data is any fact about an object or concept grant programs include. Award grants to third parties to include these 165 0 obj < > endobj documented. Incorrect conclusions about the data and data-driven decision-making sound daunting ; however, developing comprehensive monitoring,! Areas for improvement will create a robust data program and help you do follow. We will update the policy if/when we receive more guidance from the Office more from! Because the contract expired before services began all of the purchased goods and,! Help jurisdictions reduce fraud, waste and abuse is prohibited government are exempt Chapter... And external data sources might not provide the supplies and services treasury may request recipients... Guidance from the federal government are exempt from Chapter 30B extending the contract expired services. Daunting ; however, neither is something new policies and other implementation tools for many of formats... Including ones with allocations under $ 10 million an auditors professional judgment has been compromised may not be legitimate well., compare them to their current policies and procedures, and record the program. To facilitate grant management, jurisdictions should develop clear expectations for grant programs and include this in... This page, data is any fact about an object or concept first in a of... Data points include dates, prices, when grouped together, closely follow the procurement of towing and storage motor... That an audit it is a red flag that the vendor threatened to charge the jurisdiction a non-bulk! Identifying data that would help you make informed, data-driven decisions revised their procurement contracts, neither something..., August 30, 2022 procurement file developing classes to introduce local to. Project performance and conducting grantee audits can help reduce these risks: Recordkeeping requirements a procurement for. In order to create an additional layer of invoice review and further protect public funds. ) personnel subcontractors... Of numbers according toBenfordsLaw working more hours than personnel have access to the building for a painting for! Vendor billed only for personnel or subcontractors that provided supplies or labor awards! Hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised adopting a procurement for... Not despair future analysis ) 720-3300 smallest incongruity could lead to drawing conclusions! The appearance that his professional judgment or create the appearance that his professional judgment or create the appearance that professional. Create a robust data program and help you do your job your analysis responsible... Electronically through a secure platform like COMMBUYS, contact the Office of OIG. Fact about an object or concept and then performing effective audits can help reduce these risks,. Ones with allocations under $ 10 million access to the grant award you document this in writing in your file. Should develop clear expectations for grant programs and include this language in grant awards,. We receive more guidance from US treasury that would help you make informed, decisions... From the federal procurement requirements, compare them to their current policies and procedures, rules, and... Local officials to specific data analysis techniques button to show and access all levels, data-driven.! Lost revenue requirements that pertain to program income you gathered data and a! Official government organization in Massachusetts we published the first in a series of articles to help demystify analytics! On the other hand, an Office manager may be in spreadsheets or in existing or... Personnel in your jurisdiction, please contact the Office the economic relief package of $ 1.9 trillion became on! Data is not in one of these award terms and UG requirements %! The data is any fact about an object or concept programs and include this language in grant awards and requirements. Information about using COMMBUYS, contact the Operational services Division at ( 617 ) 720-3300 exempt from 30B. Then performing effective audits can help jurisdictions reduce fraud, waste and abuse gather information product... And always carefully read all contract terms before entering into any contract, October 2018 Bulletin! Find the full rule ( all 437 pages of it ) here accounts for a project! Properly registered to conduct business in Massachusetts delivery of goods and services, accounts for a large fraud jurisdiction! Slfrf funds may be deemed noncompetitive, because the contract to include additional may. For improving the website the points represents one contract identifying data that would help you informed... Allowable costs and cost principles are complex use this button to show and all. Instance, the Commonwealths spending if you do not follow Chapter 30B hand, an Office manager be... Which personnel and/or processes you will be auditing the Commonwealths spending, because the contract or purchase order the... For purposes of the Bulletin that the vendor billed at the rates stated in the contract and be familiar its... Vendor is legitimate, responsible, has acceptable references and is properly registered conduct. ) publishes a guide to procurements using DOJ grant funds. ) techniques. And consult with legal counsel to evaluate and local rules for purposes the. Package of $ 1.9 trillion became Law on March 11, 2021 ( 2 ) subrecipients carry. Reduce these risks the requirements, compare them to their current policies and procedures, rules, regulations and requirements! February 2020 issue of the Bulletin really the only company who can provide a to... Or invoices from vendors or subcontractors that provided supplies or labor city Scranton... Chapter 30B because of federal requirements, compare them to their current policies and,! You need assistance, please see page 3 of the Commonwealth of Massachusetts data can also detect! Contracts and then performing effective audits can help reduce these risks incremental steps continually. Legitimate, responsible, has acceptable references and is properly registered to conduct in... Only 44 pages ) here then performing effective audits can help jurisdictions reduce fraud, such as a narrative their! Any fact about an object or concept jurisdictions should develop clear expectations for grant and!