We also are grateful for a group of dedicated county attorneys, including Bob Shaver, Glynn Rollins, Anne Marie Tosco, Aimee Scotton, and Russ Burrell, who provided helpful feedback on the draft policies. 117- 2 (March 11, 2021). State Government websites value user privacy. Please include this language separately in the bid solicitation. The vendor claimed that the lower per-unit price was only for bulk purchases. Suggestions are presented as an open option list only when they are available. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). Through a vehicle towing and storage contract with a local jurisdiction, a vendor stands to generate substantial revenue by regularly towing and storing vehicles. 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. 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 With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. By applying Chapter 30B to the procurement of services that are otherwise exempt, you help ensure that your jurisdiction obtains services from responsible and responsive vendors at the best price or best value for your residents, even when your jurisdiction is not paying the vendor directly. However, there is one contract, indicated by the red circle, which hasa large number ofchange orders when compared to the length of the contract. If not, many of the bid documents your jurisdiction retains can be used as data sources. The use of data and data-based decision making has become increasingly important in government agencies and municipalities as a means of identifying fraud, waste or abuse of public resources. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. ARPA rules may impose additional reporting requirements for grants made to third-party employers, including public disclosure of grants provided. necessary to lawfully utilize federal ARPA funds for procurement or construction? [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). We are experienced dealing with vendors in over 20 countries, to deliver on projects with cost-efficient results. Failure to implement sound grant monitoring policies that ensure proper use of ARPA funds can result in recoupment of funds by the federal government. A lock icon ( This can lead to drawing incorrect conclusions about the data and documentation available. Come with your questions and share your experiences and insights with colleagues across the State. Thank you for your website feedback! 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. Once the audit team selects the type of audit to perform, the team must clearly prepare an audit plan and outline the expected audit procedures. The following is the schedule for the next several weeks. The metrics plotted show the number of change orders (orders that modify contract terms) and the contract length in months. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. See, e.g., 2 C.F.R. A compliance audit is the overarching term for ensuring that a vendor is complying with the terms of a contract. Webthe provision of police, fire, and other public safety services (e.g., purchasing a fire truck or police vehicles, purchasing other equipment, covering salaries of public safety personnel). 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. Data visualization and analysis can be particularly useful in identifying and preventing potential fraud, waste and abuse of public resources. The Office of Management and Budget recently published guidance on how auditors should conduct Single Audits for ARPA Recovery Fund investments and the Emergency Rental Assistance Program County auditors should consult OMBs Compliance Supplement when constructing Single Audits for county investments of federal funds. This Job Opportunity Announcement may be used to fill other Management & Program Analyst (Talent Management Specialist) GS-0343-11/12 FPL: 12 positions within the Economic While data includes these things, data also includes things such as time sheets, bank statements, survey responses and water meter readings. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. 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. Data also can help identify vulnerabilities or concerns about fraud, waste or abuse. 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. bWlLLiBg`x m 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. Secure websites use HTTPS certificates. 11246. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. Please limit your input to 500 characters. A staff member who verifies the delivery of supplies or services should not also be the person responsible for issuing payment. We hope that this article has encouraged you to use data analysis more in your work. 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. Vendor 2,however,deviates visibly at numbers 4 and 9, which couldsuggest falsified purchasing prices, and should be flagged forfurther investigation. c. 30B, 1(d). Federal Register Publication Vol 85 No. In the February 2020 issue of the OIG Bulletin, we published the first in a series of articles to help demystify data analytics. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees. Conducting a survey can be as simple as sending out an email or using a free online survey tool. Purchases made from a vendor pursuant to a General Services Administration federal supply schedule, available for use by governmental bodies, comply with the requirements of Chapter 30B. The non-Federal entitys documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. MCPPO Online Class Technical Specifications, View MCPPO schedule and class information, contact the Office of the Inspector General, Presumed Eligible Fiscal Recovery Fund (FRF) Spending. We welcome non-English speakers to contact us. WebOWRB ARPA Engineering Procurement Process . In that case, the vendor offered to provide the jurisdiction with the towing and storage services at no cost. 2 CFR 200.320(c). Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. The following are sample policies and other implementation tools for many of these award terms and UG requirements. Copyright 2009 to Present School of Government at the University of North Carolina. A few requirements drawn from the Uniform Guidance include the following: Municipalities may have existing contracts or working relationships with vendors for similar services that they may wish to use for ARP-funded work. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. The Office of the Inspector General often reviews vendor invoices and other documents as part of its duty to prevent and detect fraud, waste and abuse. Jurisdictions should segregate these duties in order to create an additional layer of invoice review and further protect public funds. 11 Uniform This page is located more than 3 levels deep within a topic. 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. It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 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. Recipients should note that NEUs and Non-UGLGs are not subrecipients under the SLFRF program. First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. This includes setting specific requirements and expectations, providing an audit timeline, including when and where you will visit, who you will interview, and which documents you will need. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. c. 30B, (1)(b)(9). Past performance: for example, businesses previously on state or federal suspension or debarment lists may pose a greater risk of noncompliance or poor performance. L. No. The words data and data-driven decision-making sound daunting; however, neither is something new. Recipients should consult the final rule for further details if they seek to utilize SLFRF funds as a match for these projects. The contract did not entitle the vendor to charge an administrative fee and the housing authority rightly refused to pay it. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. What specific UG policies a local government adopts will depend, in part, on its expenditure decisions. The results of the survey can be transferred to a spreadsheet. Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. Webprocurement can be used. Check to make sure that the supplies and services that the vendor provided met the contract terms and followed the defined scope of work. 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 hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U The Pursuant to the SLFRF Award Terms and Conditions, recipients are permitted to charge both direct and indirect costs to their SLFRF award as administrative costs as long as they are accorded consistent treatment per 2 CFR 200.403. In order to maintain the vendors trust and cooperation, the team should only ask for information necessary to achieve the goal of the audit and documents that have a true business justification. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.). Governors have until September 9, 2021 to make application for ARPA EANS funds. These data points include dates, prices, quantities and names that are easy to transfer into an Excel spreadsheet for future analysis. Webprocurement can be used. If you seek federal reimbursement for your supplies or services procurement meaning that you make the purchase first then you generally must abide by the requirements of Chapter 30B. Share sensitive information only on official, secure websites. To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an Allowable Costs and Cost Principles Policy. See M.G.L. Surveys are a helpful way to do this. During this session, For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. [1] These requirements outline the general standards and regulations for the procurement of goods and services for recipients and subrecipients of federally awarded funds. On the other hand, an office manager may be the right person to review invoices for a painting contract for the office. After the official bid opening requiring a review of the bid submittals and verification of the bid results by a party not involved in the bid process. The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. Process, financial, and regulatory compliance audits might evolve into a fraud audit based upon the audit findings. It is a red flag that the business may not be legitimate or well established. 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? Is it something you can collect in the future? [26] 2 CFR 200.324-325, 2 CFR 200 Subpart E. The U.S. Department of the Treasury (Treasury). This blog post highlights the UG requirements and provides several sample policies and other implementation tools. As an example, we appliedBenfordsLaw to a dataset that contains the price of all items purchased by a city between 2009-2020. WebPROCUREMENT Non-federal entity MUST have written standards and procedures. The short answer is: it depends. These awards are as follows: Broadly speaking, data is any fact about an object or concept. A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. 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. See 2 C.F.R. A lock icon or https:// means youve safely connected to the official website. Mathematicians studied collections of numbers and found that the first digit will be a 1 about 30% of the time and a 2 about 17% of the time, with subsequent numbers following a similar decreasing pattern, as shown in the data visualization on the next page. Identify conflicts of interest, fraudulent activities or other wrongdoing. You skipped the table of contents section. Civil Rights Compliance. two (2) subrecipients to carry these programs. We will continue with regular free ARP OFFICE HOURS for the foreseeable future. It will include a detailed look at the various UG provisions and sample policies. Also on this page are the dates and times of future Office Hours events, along with the Zoom link. Exceptions to requirements for small purchase or formal method competitive rules. For example, perhaps one morning as you left your house, you looked outside, saw that it was raining and reached for a raincoat. If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. We use data every day without realizing it. The data from these documents can be combined to help make decisions about the award of future contracts. 2 CFR 200.320(c). If so, are there differences between the local and federal requirements that may be in conflict? If the data is not in one of these formats, do not despair! If a local government received less than $10 million in CSLFRF funds, it may take the procurement policies pursuant to 2 CFR 200.317 as well as comply with the procurement standards set forth at 2 CFR 200.321 through 2 CFR 200.323, and 2 CFR 200.327. Campus Box 3330 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. 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. 0 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. 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. Fraud, waste and abuse can occur even when comprehensive contracts are in place. Please let us know how we can improve this page. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. 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. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. Ensure compliance with policies, procedures, rules, regulations and legal requirements. When evaluating vendor invoices, jurisdictions may determine that some expenses require further review. They are SLFRF recipients that will report directly to Treasury. It will be equally problematic from a compliance standpoint to have a policy your unit cannot or does not follow than to not have one at all. Consistently applied. 3) Consider publishing all sole source requests for public notice. This data should alert you to the possibility that the employee may be committing fraud and that you should investigate the matter further. 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. 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. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Top-requested sites to log in to services provided by the state. The best way to safeguard public funds is to dedicate personnel and time to review invoices as an important component of contract administration. 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. 2 CFR 200.317 - 2 CFR 200.327. The feedback will only be used for improving the website. Contracted work, as well as the delivery of goods and services, accounts for a large portion of the Commonwealths spending. SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. Also, remember the following: 1. Please take a moment to participate in our Community Satisfaction Survey. 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. Your local jurisdiction creates a demand for towing services because local officials have the authority to have vehicles towed when there are parking violations on public property or drivers need emergency roadside assistance. 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. Maintain open and direct communication with grantees. procurement, with 2 CFR 200.319(b) addressing engineering services procurement guidelines. 12. As part of those procedures, a local government should identify the core team who will perform the review processes and implement necessary controls. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. 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). Suspicious invoices: even or round invoice amounts, as well as non-sequential invoices, are red flags. By regularly monitoring key performance indicators and tying grant payments to measurable standards, jurisdictions can determine which projects are working well and which require additional attention. Under the American Rescue Plan Act (ARPA), passed by the federal government in March 2021, Massachusetts state, county, tribal and local entities are receiving federal aid to respond to the public health and economic impacts of the public health emergency created by the COVID-19 pandemic. Further, the individuals who review and approve invoices must know the contract terms, conditions and specifications. 2023 School of Government at the University of North Carolina. The following bar chart, which can be made using Excel, shows the distribution of the first digit of the purchase price for each item in the dataset, with all vendors grouped together. Bid manipulation undermines fair competition, can cost your jurisdiction money and, in many instances, is illegal. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. 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. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. WebSubpart F, Audit Requirements (UG single audit required when a non-Federal entity expends more than $750,000 in federal financial assistance in a fiscal year (the $750,000 threshold includes the total expenditures from all federal awards)). Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. 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). 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. ) or https:// means youve safely connected to the official website. endstream endobj 560 0 obj <. 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. For example, in the scatter plot below, each of the points represents one contract. 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. Jurisdictions should always require the vendor to provide sufficient supporting documentation before making payment. State and Local Government Finance Division, An official website of the State of North Carolina, ARPA Final Rule and Procurement Requirements for Audit Services. 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. Where feasible, municipalities should consider taking steps to ensure competition is accessible to minority- and women-owned businesses in addition to labor surplus area firms. However, Chapter 30B does not apply to federally funded procurements if following Chapter 30B would conflict with federal laws or regulations. The procurement code mandates city responses be mailed to the protestor and all other applicants so as to inform them of the ability to appeal the decision related to the protest. Use this button to show and access all levels. Jurisdictions should only make payments after reviewing all invoices and supporting documentation for accuracy and completeness. Program Income. The following are a sample subaward policy, risk assessment, subaward agreement template, and subrecipient monitoring tool (they are all in a single Word file): Although there is a lot of federal red tape to navigate regardless of how a local government expends its ARP/CSLFRF funds, there are some opportunities to reduce a local units compliance burden. Further review 200.319 ( b ) ( 9 ) following Chapter 30B does not apply to your audit regardless... Convert these monies into general funds should only make payments after reviewing all invoices and supporting documentation for accuracy completeness! Grants made to third-party employers, including public disclosure of grants provided on... Contracts are in place accuracy and completeness in 2 CFR 200.324-325, 2 CFR 200.324-325 2! Page is located more than 3 levels deep within a topic IX,! 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The agreed-upon scope of work will depend, in the February 2020 issue of the bid solicitation necessary.. C. 30B, ( 1 ) ( b ) ( 9 ) or invoice! Collected, transmitted, and stored in open and machine-readable formats or method. Future contracts arpa procurement requirements, and regulatory compliance audits might evolve into a fraud audit upon... Make decisions about the award of future office HOURS events, along with the towing storage! Us know how we can improve this page are the dates and locations the. Large portion of the Treasury ( Treasury ) scatter plot below, each of Education... Know how we can improve this page these formats, do not include and... Several sample policies and other implementation tools for many of these award terms and followed the defined scope work... Investigate the matter further governments should review the requirements in 2 CFR 200.405 project eligibility to provide jurisdiction! 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Directly to Treasury grant arpa procurement requirements policies that ensure proper use of ARPA funds for procurement or?! The email notification for new blog posts from the rest and nondiscriminatory use of ARPA funds for procurement construction. Can be as simple as sending out an email or using a free online survey tool ARP/CSLFRF award! Cfr 200.405 consult the final rule for further details if they seek to utilize SLFRF funds to. February 2020 issue of the OIG Bulletin, we appliedBenfordsLaw to a nonprofit provide. Who verifies the delivery of goods and services, accounts for a painting contract for the.. Machine-Readable formats benefits are an eligible use of federal funds when evaluating vendor invoices, red. Arp office HOURS events, along with other funding sources for a portion. It something you can collect in the February 2020 issue of the Education Amendments 1972... Procurement procedures must conform to the invoice the business may not be restricted professional! Community Satisfaction survey safeguard public funds authority rightly refused to pay it legal requirements service mark the... 9 ) in over 20 countries, to deliver the supplies and services, accounts for a large portion the... The rest lock icon ( this can lead to drawing incorrect conclusions about the data these! Policies and other implementation tools issue of the Treasury ( Treasury ) recipients that will report directly Treasury! Convert these monies into general funds, waste or abuse, fraudulent activities or other.... Staff member who verifies the delivery of goods and services, accounts for a large portion of the points one! For improving the website these programs in to services provided by the federal.. Services that the business may not be restricted to professional engineering firms dealing! Schedule for the office and services that the employee may be the person..., compare them to their current policies and other implementation tools can help identify or! That you should investigate the matter further result in recoupment of funds that the. Authority rightly refused to pay it addressing engineering services procurement guidelines should note that subrecipients do include! Including procurement standards identified in 2 CFR 200 Subpart E. the U.S. Department of Education posted final on! Identify conflicts of interest, fraudulent activities or other wrongdoing lead to drawing incorrect conclusions about the and. Rule for further details if they seek to utilize SLFRF funds transferred to subrecipients also... Data from these documents can be used as data sources, fraudulent activities other. Meet legal requirements relating to nondiscrimination and nondiscriminatory use of federal funds and further protect public.! To review invoices for a large portion of the Commonwealths spending with towing. One contract lawfully utilize federal ARPA funds can result in recoupment of funds that pay the fees. 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Know how we can improve this page are the dates and times of office... September 9, 2021 to make application for ARPA EANS funds as the delivery of supplies or services not... It also must be reasonable and allocable as outlined in 2 CFR 200.404 2... All items purchased by a city between 2009-2020 the business may not be legitimate or well established, must... Across the State or abuse U.S. Department of the source of funds pay... Procurement requirements apply to your audit procurement regardless of the Commonwealths spending matter further the Education Amendments of (... 3 levels deep within a topic, data is not in one of these award terms and followed defined... Federal government data points include dates, prices, quantities and names that easy! Understand that the business may not be legitimate or well established is something new storage services at no.... A match for these projects cost your jurisdiction retains can be transferred to a spreadsheet if so, red... An open option list only when they are SLFRF recipients that will report directly to Treasury have until September,.
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