ARPA FUNDING-.docx

ARPA FUNDING

· General Obligations

· Adopt and abide by a conflicts of interest policy, prohibiting subrecipients from competing for awards or grants in which they develop or draft specifications, requirements, or statements of work [See 2 CFR 2 CFR 200.319(b)].

· Audit/Financial Management

· The subrecipient makes audit reports available for public inspection [See 2 CFR 200.507].

· Make subrecipient’s personnel available to speak with federal auditors [See 2 CFR 200.508(d)].

· Document any material deviations from budget or project scope or objective, and request prior approval from VDH [See 2 CFR 200.308(b)]

· Equipment Management

· Procure insurance policies for equipment purchased with federal funds equal to the value of such equipment for the duration of the project [See 2 CFR 200.310]

· Maintaining equipment records that include equipment description, a serial number or other identification number, Federal funding source (if applicable), the acquisition date, acquisition cost, location, and equipment condition [See 2 CFR 200.313(d)]

· At least every two years, take a physical inventory of equipment and reconcile the results with equipment records [See 2 CFR 200.313(d)]

· Contracting

· Incentivize cost reductions and opportunities to reduce operating cost going forward [e.g., see 2 CFR 200.318(g)]

· Describe the process by which VDH may withhold payments, including determining unallowable costs, from a subrecipient and the subrecipient’s options to appeal such a decision [See 2 CFR 200.305(b)(6) and 2 CFR 200.410]

· Monitoring/Reporting

· Relate financial data and accomplishments to performance goals and objectives when preparing periodic reports [See 2 CFR 200.329(b)]

· Conduct onsite technical inspections and gain certified percentage of completion data to monitor for construction project completion [See 2 CFR 200.329(d)]

· Inform VDH if the supported activity is significantly impacted by unforeseen positive or negative events [See 2 CFR 200.329(e)]

· Quarterly reporting for all subrecipient ARPA funded Water, Sewer, and Broadband projects include: (1) Projected/actual construction start date; (2) Projected/actual initiation of operations date; (3) Location (for broadband, geospatial location data); (4) Labor documentation requirements for projects over $10 million [See SLFRF Compliance and Reporting Guidance, pg. 21]

· Quarterly reporting for all subrecipient ARPA funded Broadband projects include:(1) Speeds/pricing tiers to be offered; (2) Technology to be deployed; (3) Miles of fiber; (4) Cost per mile; (5) Cost per passing; (6) Number of households projected to have increased access to broadband (7) Number of institutions and businesses projected to have increased access to broadband [See SLFRF Compliance and Reporting Guidance, pg. 22]

· Quarterly reporting for all subrecipient ARPA funded Water and/or Sewer projects include: (1) National Pollutant Discharge Elimination System (NPDES) Permit Number for projects aligned with the Clean Water State Revolving Fund; (2) Public Water System (PWS) ID number for projects aligned with the Drinking Water State Revolving Fund [See SLFRF Compliance and Reporting Guidance, pg. 22]

· Ensure subrecipients prepare, complete, and submit ARPA SLFRF financial, performance, and compliance reporting within 30 days of each quarter [See SLFRF Compliance and Reporting Guidance, pg. 9]

· Project Wrap-up

· Remit the value of any unused supplies in excess of $5,000 to VDH [See 2 CFR 200.314(a)]