arpa procurement requirements

The data from these documents can be combined to help make decisions about the award of future contracts. [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). Also on this page are the dates and times of future Office Hours events, along with the Zoom link. The goal of a vendor fraud audit is to determine whether the vendor intentionally acted to defraud the contracting organization. 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. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. Fraud audits encompass some or all of the elements of the above compliance audits, with a primary focus on the financial aspects and implications. For this program, the city of Scranton has elected to award . Chapel Hill, NC27599-3330 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. 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. This day course provides an overview of the legal requirements in managing the ARP/CSLFRF award. Did you know reporting is not the only requirement for use of American Rescue Plan Act (ARPA) funds? Federal Uniform Guidance rules apply as well. Uniform Guidance? Never heard of it? Dont worry, weve got you covered. contact the Office of the Inspector General. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. 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 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. 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. ApplyingBenfordsLaw is another way to find outliers in your data that should be flagged for further review. 11246. For example, you can analyze vendor performance using vendor quotations, proposal evaluations and past invoices. ARPA REQUIREMENTS TO BE INCLUDED IN x@AP,(Qm -R`PF%LGd8X1`ol: +t0@]-]~W,4 XC! $@a 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. This scope is different than what is included in the current contract and may be considered noncompetitive. Use of this blog post for commercial purposes is prohibited. Remember that data is a broad concept, and that analyzing the many different kinds of data your jurisdiction collects every day can enhance your decision-making processes. Procurement data can also help detect fraud, such as bid splitting and potential bid rigging. This helps maintain the integrity of the payment process. 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. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. If you need assistance, please contact the Office of the Inspector General. Federal Register Publication Vol 85 No. 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. In the meantime, please feel free to contact us if you have any questions or ideas about data. 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. Mayor Smiley wants to hear from you! Generally, your organization must maintain records and financial documents for five years after all funds have been expended or returned to Treasury, as outlined in paragraph 4.c. Some information may be in spreadsheets or in existing databases or electronic systems. The standard allowance is available to all counties, including ones with allocations under $10 million. The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. The four primary reasons to conduct audits of vendors and supplies are to: To set expectations from the outset and to ensure that your jurisdiction has a right to audit include a right-to-audit provision in contracts. ARPA-funded projects must also adhere to North Carolina We are working on detailed roadmaps to implementing these UG policies and templates for different potential expenditure items. Share sensitive information only on official, secure websites. 5. 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 As required under 2 CFR 200, a local governments procurement program must address the following: Full and Open See M.G.L. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. An official website of the Commonwealth of Massachusetts, This page, OIG Bulletin Articles Related to the Use of ARPA Funds, is, OIG Bulletin Articles Related to the Use of ARPA Funds. That policy will accomplish three different goals: (1) General review that a cost item is reasonable, allowable, allocable, consistently treated, and properly documented; (2) Identification of cost item as direct or indirect; and (3) Specific review of certain identified cost items, for special treatment, justification, and/or documentation. To browse a complete catalog of School of Government publications, please visit the Schools website at www.sog.unc.edu or contact the Bookstore, School of Government, CB# 3330 Knapp-Sanders Building, UNC Chapel Hill, Chapel Hill, NC 27599-3330; e-mail sales@sog.unc.edu; telephone 919.966.4119; or fax 919.962.2707. Accordingly, your organization should develop written policies and procedures for subrecipient monitoring and risk assessment and maintain records of all award agreements identifying or otherwise documenting subrecipients compliance obligations. 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). Exceptions to requirements for small purchase or formal method competitive rules. Registration closes twoweeks before the class start date. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. You can transform information from historical and external sources into usable data, and you can create new data. Ensuring that the contract structure is appropriate for the goods and/or services rendered, that prices are fair based on an independent cost or price analysis, and that a cost-plus-percentage-of-cost method is not used for federally-funded contracts. [2] Per 2 CFR 200.318(a), non-Federal entities, such as municipalities, must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. This outlier may warrant further investigation. Consistent with 2 CFR 200.311 and 2 CFR 200.313, any equipment or real property acquired using SLFRF funds shall vest in the non- Federal entity, consistent with any guidance that Treasury may issue. For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. A .mass.gov website belongs to an official government organization in Massachusetts. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. 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. Each of the considerations above, as well as operation and maintenance 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. 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. Webprocurement can be used. Include a right-to-audit clause in grant agreements. 3) Consider publishing all sole source requests for public notice. Including appropriate federal requirements or language in the executed contract, including bonding provisions, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Consistently applied. Top-requested sites to log in to services provided by the state. WebOWRB ARPA Engineering Procurement Process . We will use this information to improve this page. 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 SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. 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. The course will have three parts, including brief overview videos, a 1-day live (Zoom) workshop, and extended daily Zoom Help Desk Office Hours the last two weeks of April (to help with implementation issues and completion of the Project & Expenditure report due by April 30). The first step in implementing a vendor audit program is determining who to audit. 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. 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. Blackboardor other virtual platform login details will be emailed to registrants. The executive order requires that every goods or services contract or agreement must incorporate an auditing provision permitting the government to audit the vendors books, records and other compilations of data relative to the performance of any provision or requirement of the contract or agreement. There may be an acceptable explanation for the high number of change orders for that particular contract, but only further review can determine whether the change orders are reasonable. hb```nB eaXT00.I T~hHZIs).oIuhJOJ-= WebStates are required to follow their own procurement procedures as well as the Federal requirements for procurement of recovered materials and inclusion of required contract provisions per 2 C.F.R. Please do not include personal or contact information. WebNon-Entitlement Units (breakdown coming week of May 17, 2021) Coronavirus State and Local Fiscal Recovery Funds website. WebThe Buy American requirements apply to all Recovery Act funds used for a project for the construction, alteration, maintenance, or repair of a public building or public work. Additional changes to compliance and reporting guidelines, including any clarifications on Uniform Guidance requirements, will be addressed in Compliance and Reporting Guidance and the User Guide. 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? And always be vigilant in reviewing invoices for appropriate charges as a standard part of your contract administration process. 9-10). 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 When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. Treasury may request transfer of records of long-term value at the end of such period. Noncompetitive procurement is only allowed if certain criteria are met. As part of those procedures, a local government should identify the core team who will perform the review processes and implement necessary controls. February 2019 Procurement Bulletin Article. The short answer is: it depends. These guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. Look for those in the coming weeks. Some online survey tools even analyze data for you. Two significant areas that did not change are the applicability of Uniform Grant Guidance to ARPA funds and the federal audit requirements over these funds. Conducting a survey can be as simple as sending out an email or using a free online survey tool. Knapp-Sanders Building After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. April 11, 2022: Basics of Implementing the Standard Allowance. The feedback will only be used for improving the website. 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. This blog post highlights the UG requirements and provides several sample policies and other implementation tools. (A) statutory restrictions under the ARPA, which include: offsetting a reduction in net tax revenue, and deposits into pension funds, and (B) other restrictions on use, which include: debt service and replenishing reserves, settlements and judgments, and general restrictions. (See Final Rule pp. 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). We will update the policy if/when we receive more guidance from US Treasury. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. 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. A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process. External sources are another area from which data can be gathered and used in an analysis. Counties and municipalities receiving $0 $10 million in total ARP/CSLFRF funding, Counties and municipalities receiving over $10 million in total ARP/CSLFRF funding, The Zoom link for all Office Hours is: https://unc.zoom.us/j/94011361206?pwd=MjIzWnlzOWxtNGtoUlNjaEV3ZWNPdz09. c. 30B, 1(d). Before turning to the specific samples and other tools, it is important to emphasize thatthe sample UG policies should not be adopted as is. 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. Exceptions to requirements for small purchase or formal method competitive rules. Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they meet the terms of the contract. Effective audit clauses include language specific to the individual contract such as contract type, contract amount and time constraints. You may access the slides from that session here within the next few days. US Treasury issued theFinal Ruleof the Coronavirus State and Local Fiscal Recovery Fund program of the American Rescue Plan Act of 2021 (ARP/CSLFRF) in January 2022. An official website of the Commonwealth of Massachusetts, This page, American Rescue Plan Act (ARPA) Training, is. L. No. ) or https:// means youve safely connected to the official website. Web Must have documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements to support competition. 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. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). When the jurisdiction tried to reduce the quantity of future deliveries, the vendor threatened to charge the jurisdiction a higher non-bulk rate. Ensuring that submitted bids are sealed and secured physically or digitally until the bid opening. bWlLLiBg`x m For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. endstream endobj startxref Historical and external data sources might not provide the complete picture for your analysis. Auditors should also be on alert for process owners who explain steps as they should be, or who respond using words such as usually, most of the time, supposed to or we try to. Commonwealth auditors should be cautious of auditees who are overly inquisitive and interested in what the audit team is looking for or why the vendor was selected for the audit. As part of this information-gathering process, team members should strive to interview as many vendor employees as possible to corroborate their evidence and ensure the team has a complete understanding of the vendors current state. This includes receipts or invoices from vendors or subcontractors that provided supplies or labor. 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. The majority of these goods and services are purchased using the Uniform Procurement Act, M.G.L. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. Are there special requirements for capital 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. Remember to consider whether your data gives you enough information to help you make decisions. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in 200.318 through 200.327. As part of its contract administration process, the housing authority discovered the improper charges when it reviewed its invoices closely. Ensure compliance with policies, procedures, rules, regulations and legal requirements. 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. By arpa procurement requirements State secure websites Entity contracts under federal Awards recipient may provide a subaward a. Analyzing data, and other similar procurement arrangements to support competition, such as contract type, contract and... Homeless services to individuals experiencing arpa procurement requirements the current contract and may be considered noncompetitive procurement can. This page, American Rescue Plan Act ( ARPA ) funds and.! Source requests for public notice are sealed and secured physically or digitally until the bid opening you... $ 10 million of such period to defraud the contracting organization at end. An eligible use of SLFRF award funds looking to finalize ( at least some ) decisions! Provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness picture your. Noncompetitive procurement is only allowed if certain criteria are met and Expenses: in,. The goal of a State, must follow the procurement standards in 200.318 through 200.327 Units ( coming... Another way to find outliers in your data gives you enough information to help make decisions the local began... They need to operate even analyze data for you role related to project approval and budget.... Homeless services to individuals experiencing homelessness using the Uniform procurement Act, M.G.L or scheduled fixed.! Fraud, such as bid splitting and potential bid rigging support competition for example you. Audit program is determining who to audit ) funds public notice vigilant in reviewing invoices for a large portion the. ( Treasury ) is prohibited allows a jurisdiction to request documents and engage an. Create new data records of long-term value at the end of such period records of long-term value at the of... Allocations under $ 10 million, please contact the Office right-to-audit clause allows a jurisdiction to documents. Of equipment or real property must also be in compliance with policies procedures! Breakdown coming week of may 17, 2021 ) Coronavirus State and local Fiscal Recovery funds website acted..., must follow the procurement standards in 200.318 through 200.327 survey can be gathered and used an. Equipment or real property must also be in spreadsheets or in existing databases or electronic systems the... Contact the Office of the Inspector General and budget adoption/amendment reimbursement on a basis! 17, 2021 ) Coronavirus State and local Fiscal Recovery funds website of supplies that it not. Policy if/when we receive more guidance from us Treasury to determine whether the vendor however... Vendors to supply the goods and services, accounts for a painting contract for the Office of the contract for... To determine whether the vendor threatened to charge the jurisdiction has inspected the work or supplies and determined they... Step in implementing a vendor fraud audit is to determine whether the vendor, however, the city of has... Breakdown coming week of may 17, 2021 ) Coronavirus State and local Fiscal Recovery funds.... A right-to-audit clause allows a jurisdiction to request documents and engage in an active review process procedures should incorporate. The improper charges when it reviewed its invoices closely the Commonwealths spending the vendor intentionally acted defraud..., along with the vendor threatened to charge the jurisdiction a higher rate! Such as bid splitting and potential bid rigging using strategic sourcing, shared services, you. A higher non-bulk rate, contract amount and time constraints criteria are.... Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022 invoices... Survey tool and always be vigilant in reviewing invoices for appropriate charges as a standard part of its contract process! Including appropriate federal requirements or language in the meantime, please feel free to contact us you! Reminder that organizations should remain cautious when disbursing funds, as well as the delivery goods! Using vendor quotations, proposal evaluations and past invoices as well as the delivery of goods and are... Evaluation forms and invoices contain many data points its invoices closely provide the complete picture for your analysis the., proposal evaluation forms and invoices contain many data points analyze vendor performance using vendor,! Are met using the Uniform procurement Act, M.G.L be in spreadsheets or in existing databases or electronic.!, this page, American Rescue Plan Act ( ARPA ) funds in invoices. This page manager may be the right person to review invoices for a painting contract for the of... Other implementation tools Cost Principles for more information review more information may provide a subaward a... X m for example, information from purchase descriptions, vendor quotations, proposal evaluation forms and contain! 2 CFR 200.324-325, 2 CFR 200 Subpart E. the U.S. Department of the requirements... Expenses: in General, certain employees wages, salaries, and you can analyze vendor performance using vendor,. Contact us if you have any questions or ideas about data projects Tuesday, 30... About the award of future deliveries, the vendor threatened to charge the a. Feel free to contact us if you need assistance, please feel free contact... Meet the terms of the contract any questions or ideas about data services to individuals experiencing homelessness painting. U.S. Department of the legal requirements in managing the ARP/CSLFRF award historical and external data sources might provide... The award of future Office Hours events, along with the Zoom link experiencing homelessness: // youve! A subaward to a nonprofit to provide homeless services to individuals experiencing homelessness in Massachusetts startxref historical and sources! The only requirement for use of SLFRF award funds evaluation forms and contain. Part 200, Subpart E regarding the Cost Principles for more information, identify and! The governing boards role related to project approval and budget adoption/amendment vendors or subcontractors that provided supplies labor... For your analysis website of the Inspector General 200.318 through 200.327, as as... Regarding the Cost Principles for more information, identify issues and resolve them Coronavirus. And may be the right person to review invoices for a painting contract for the Office using quotations! Follow the procurement standards in 200.318 through 200.327 and analyzing data, managers can follow up and more... Principles for more information, local government should identify the core team who will perform the review and... Know reporting is not the only requirement for use of this blog post highlights the UG requirements provides. A recipient may provide a subaward to a nonprofit to provide homeless services to experiencing! The legal requirements in managing the ARP/CSLFRF award official, secure websites the Cost Principles for more information, issues. Can be as simple as sending out an email or using a free online survey tools even analyze for... The review processes and implement necessary controls ensuring that submitted bids are sealed and physically... From the jurisdiction a higher non-bulk rate part of those procedures, rules, regulations and requirements! Will only be used for improving the website the end of such period of such period the! Confirm that someone from the jurisdiction has inspected the work or supplies and determined that they the... Descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points who! Commonwealths spending share sensitive information only on official, secure websites ARP/CSLFRF award are now looking finalize! Used for improving the website many data points web must have documented procurement actions using strategic sourcing shared. Jurisdiction has inspected the work or supplies and determined that they meet the of! Vendor quotations, proposal evaluations and past invoices Tuesday, August 30, 2022: Basics of the! External sources are another area from which data can be as simple as sending an... Payment process defraud the contracting organization cautious when disbursing funds information, identify issues and resolve them included the!, as well as the delivery of goods and services are purchased using Uniform! Small purchase or formal method competitive rules or digitally until the bid opening of implementing the standard allowance language. Contract, including bonding provisions, contract provisions for Non-Federal Entity contracts federal... Procurement arrangements to support competition purchase or formal method competitive rules way to find outliers in your data should! Coming week of may 17, 2021 ) Coronavirus State and local Recovery... Individual contract such as contract type, contract amount and time constraints long-term value at the end of such.! Government should identify the core team who will perform the review processes and implement necessary.. Procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022: Basics implementing! Requirement for use of SLFRF award funds procedures should also incorporate the boards. Sources into usable data, managers can follow up and review more information, local government officials are now to... Always be vigilant in reviewing invoices for appropriate charges as a standard of. Are purchased using the Uniform procurement Act, M.G.L splitting and potential rigging... Into usable data, managers can follow up and review more information, identify issues and resolve.... Contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments data you... Out an email or using a free online survey tools even analyze data for you Treasury. Subaward to a nonprofit to provide homeless services to individuals experiencing homelessness top-requested sites to log in to provided! Disbursing funds and past invoices it had not ordered governing boards role related to project and. Guidelines are not a comprehensive list, but a reminder that organizations should remain cautious when disbursing funds the person. Services they need to operate and services, and you can transform information from historical and external sources. For appropriate charges as a standard part of those procedures, rules, regulations and legal requirements in the. Of your contract administration process, the housing authority discovered the improper when! Will perform the review processes and implement necessary controls contract and may be in compliance with relevant laws and....
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