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Pandemic Funding Oversight Resources

Under the American Rescue Plan Act of 2021 (ARPA), Massachusetts state, county, tribal and local entities are receiving federal aid to respond to the public health and economic impacts of the COVID-19 pandemic. The Office of the Inspector General (OIG) has compiled the following rules and resources related to the American Rescue Plan Act from our Office, the federal government, other state agencies and private organizations.

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Office of the Inspector General Resources

This short guidance briefly summarizes advice about project management from the Federal Acquisition Institute, communicated in its Guide for Project Managers. This guidance breaks up the process of project management into discrete steps and provides a list of considerations that public leaders will find helpful as they approach projects.

Federal law requires that agreements between non-federal recipients of federal awards (including local jurisdictions receiving federal grants) and transferees (subrecipients and contractors) include certain statutory or regulatory language. This checklist is intended to provide talking points for your conversation with your legal counsel to ensure that your agreement is compliant with federal rules.

The OIG has compiled OIG 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.

These questions and answers are from the ARPA webinar presented by the OIG.

This manual contains guidance for complying with Chapter 30B of the Massachusetts General Laws, known as the Uniform Procurement Act. Chapter 30B governs the procurement of supplies, services, and real property by municipal and governmental bodies. Chapter 30B applies to procurements made with federal funds, including from ARPA’s Coronavirus Local Fiscal Recovery Fund (CLRF).

The Designing and Constructing Public Facilities manual describes requirements and recommendations for awarding public design and construction project contracts. Massachusetts awarding authorities conduct a variety of construction projects, including schools, police and fire stations, roads, bridges, and wastewater treatment plants. Please note that infrastructure projects using assistance from the Coronavirus State and Local Fiscal Recovery Funds (CSRF/CLRF) must meet federal eligible use requirements. 

These charts are intended for local officials to use as a quick guide on public procurement procedures that must be followed pursuant to the Massachusetts General Laws. Your local rules may establish stricter or additional requirements that you must follow. Contact your chief procurement officer or legal counsel for advice on your local rules and procurement procedures.

This guide provides information on writing and organizing clear, effective invitations for bids (IFBs) and requests for proposals (RFPs) for supplies and services. The guide includes general instructions, a model IFB, model RFP language and sample bid forms.

This guide recommends methods and identifies resources for hiring audit firms and managing audit services contracts. The guide also clarifies Chapter 30B’s narrow exemption for certified public accountants.

Additional Resources

Report Fraud, Waste or Abuse of Government Funds or Property, including ARPA funds, to the Office of the Inspector General  Link to an online form 
Request Public Procurement Technical Support  Link to an online form 

Federal Resources

Primary Guidance

The Treasury's web page on the Coronavirus State and Local Fiscal Recovery Funds provides important information about funding requests, funding amounts, allocations, permitted uses, as well as reporting and compliance responsibilities.

The Treasury's Final Rule updates and replaces the Interim Final Rule. It responds to comments received by stakeholders in response to the IFR.

The Treasury's Interim Final Rule (IFR) provides guidance on eligible uses, reporting and oversight requirements and spending prohibitions. The IFR explains how to determine whether a project is eligible for funding pursuant to ARPA.

This FAQ sheet answers questions regarding the Coronavirus State and Local Fiscal Recovery Funds, including questions relating to eligibility, allocations, permitted uses and reporting.

This page is for metropolitan cities to request Coronavirus State and Local Fiscal Recovery Funds. Metropolitan cities are those that are currently metropolitan cities under the Community Development Block Grant (CDBG) program. Metropolitan cities will receive municipal allocations directly from the Treasury and can consult the portal found on this page to apply for funding.

Non-entitlement Units

Non-entitlement units (NEUs) of local governments are local governments typically serving populations of less than 50,000. This guidance addresses distributions of Fiscal Recovery Funds to NEUs and answers questions relating to eligibility, allocations, permitted uses and reporting.

Compliance and Reporting

The following compliance and reporting guidance, presentation slides and associated webinars created by the Treasury Department describe compliance and reporting requirements for recipients of state and local fiscal recovery funds.

Uniform Audit Requirement

All non-federal government entities that spend $750,000 or more during the non-Federal entity's fiscal year in Federal awards, including ARPA funds, must have a single or program-specific audit conducted for that year in accordance with the provisions of this regulation, 2 CFR 200.

Evidence and Evaluation

The webinar and presentation slides describe the use of evidence in determining the efficacy and efficiency of investments using ARPA funds. ARPA requires that expenditures of fiscal recovery funds are supported by a strong or moderate evidence base, based on prior studies, that the expenditure will meet the intended goal of the funding.

Equity

The webinar and presentation slides provide examples of how jurisdictions are driving equity with fiscal recovery funds, including through engagement of historically underserved communities, using data to drive targeted investments and through performance management.

Examples of Uses

These documents have examples compiled by the Treasury Department showing how jurisdictions are using state and local fiscal recovery funds.

Taxes

This fact sheet answers frequently-asked questions related to taxation of state and local fiscal recovery funds. These were issued to provide general information to taxpayers and tax professionals as expeditiously as possible. 

Pandemic Oversight

The Pandemic Response Accountability Committee (PRAC) is composed of Federal inspectors general. It was established by the CARES Act to promote transparency and coordinate oversight of the pandemic response.

Data for Determining Low and Moderate Income Thresholds

The Treasury has provided this spreadsheet showing Federal Poverty Guidelines and area median income levels for determining low- and moderate-income thresholds. It is categorized by locality, HUD area and Federal Information Processing Standards (FIPS). This chart is useful for jurisdictions as certain services provided to disproportionately impacted communities are presumed an eligible use of FRF.

Qualified Census Tracts and Difficult Development Areas

The U.S. Department of Housing and Urban Development has provided spreadsheets for Qualified Census tracts and Difficult Development Areas. These are another way to determine whether a community has been disproportionately impacted by COVID.

Federal Funds Equity & Accountability Review Panel

The Federal Funds Equity and Accountability Review Panel, created by Chapter 102 of the Acts of 2021, is charged with setting target goals for the amount of COVID-19 Response Funds spent in disproportionately impacted communities and creating a public-facing tracking system showing how COVID-19 Response Funds are spent. This page includes information about the panel, panel members, proposed equitable allocation of ARPA funds, panel agendas and minutes, and contact information to provide feedback to the panel.

Other State Resources

Federal Funds Office (FFO)

This page provides information about federal funds provided to the Commonwealth in response to the COVID-19 public health emergency, including the Coronavirus Relief Fund and the Coronavirus State Fiscal Recovery Fund; federal funds distributed to municipalities and school districts; and FFO's role in compliance for federal funds, including compliance resources for municipalities and state agencies 

This memorandum states the differences in reporting requirements for “metropolitan cities” and counties as opposed to “non-entitlement units of local government” (NEUs).

This presentation serves as a guide for the reporting requirements outlined in the Treasury documents. It focuses on non-entitlement units of government which are required to submit annual project and expenditure reports. 

This page includes information about the $347 million in funds earmarked in the ARPA appropriations bill enacted in December 2021. An earmark directs funds to a specific recipient, including programs, projects, or organizations. This page also includes the full list of earmarks and instructions for recipients of earmarks.

Division of Local Services Bulletins 

This write-up is intended to inform decision makers about allowable uses of ARPA State and Local Fiscal Recovery Funds, including through local subrecipients such as municipalities and nonprofits.

This FAQ sheet answers frequently-asked questions relating to municipal audits.

The webpage above provides information relating to accounting and auditing municipal spending.

Massachusetts Office of the Comptroller 

This memorandum sets forth the Office of the Comptroller's (CTR) accounting guidance for revenue and grants received pursuant to ARPA. ARPA-related revenue and grant transactions will post to a separate MMARS sub-fund.

Due to the COVID-19 pandemic causing significant changes to the operation of public agencies, the State Comptroller and Auditor's Office is recommending that all agencies update their Internal Control Plans to reflect the new conditions caused by the pandemic. This page identifies several goals, objectives, and risks that public agencies should work to address when constructing their Internal Control Plan. The page is a great jumping off point for further resources to inform how you think about internal controls.

Executive Office of Technology Security and Services

The Municipal Cybersecurity Awareness Grant Program is a program that will help local government to improve overall cybersecurity posture through end-user training, evaluation and threat simulation. 

Executive Office for Administration and Finance

Coronavirus Local Fiscal Recovery Fund (LFRF) Second Tranche Payment Request Form for Nonentitlement Units (NEU) of Local Government

Non-entitlement Units (NEUs) are local governments typically serving populations of less than 50,000. In order to receive the second tranche payment from the Commonwealth, NEUs must obtain an updated SAM.gov registration that includes a Unique Entity ID (UEI) number. The System for Award Management (SAM.gov) is an official website of the U.S. Government. Once NEUs have their UEI number they can request payment by filling out the form on this page.

Non-governmental Resources

GFOA Guidance on Procurement of Independent Audit Services

This webpage from the Government Finance Officers Association provides recommendations regarding the procurement of audit services. 

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