If this fails, contact your local jurisdictions legal counsel because the vendor may have breached the contract. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U
A contracting agency is free to decide that a particular award need not be restricted to professional engineering firms. Additionally, establishing and maintaining open communication with grantees regarding grant requirements and expectations will help lead to successful project completion. If you determine a need for data that does notal readyexist, you can also create data. Additional information about the definition of subrecipients is available in the section Distinguishing Subrecipients versus Beneficiaries. 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 otherwise specified in program-specific guidance. (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. 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. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. Recipients should note that SLFRF funds available under the revenue loss eligible use category generally may be used to meet the non-federal cost-share or matching requirements of other federal programs. 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. 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). Massachusetts jurisdictions received over $25 billion through ARPA. It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. Pertinent documents may include invoices, payment information, purchase orders, requisitions, general ledgers, cash disbursements, check registrars, transactional data histories and contract bid documents. two (2) subrecipients to carry these programs. The team should consider gaining direct access to the vendors systems to facilitate its review. Capital Funds Project website. Remember to check debarment lists, as well as the Secretary of the Commonwealths business registration database or a local municipal clerks office to determine if a business is properly registered to conduct business within Massachusetts. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. The policy should be drafted with Chapter 30B principles in mind and should ensure that you allow for an open, fair and competitive process. We use small samples of data, as well as big data, to help with everything from researching whistleblower claims to investigating individual cases of potential fraud to analyzing statewide systemic issues. ARPA Expenditure Category 2.15 and 2.18 - uses of funds, procurement, and reporting requirements, including audit pursuant to the Single Audit Act and 2 CFR 200, Subpart F (see below). WebProcurement Recipients are responsible for ensuring that any procurement using SLFRF funds, or payments under procurement contracts using such funds, are consistent with the procurement standards set forth in the Uniform Guidance at . The ARPA program requires recipients to comply with the procurement provisions of Title 2, Part 200 of the Code of Federal When people think of data, often electronic spreadsheets, number-crunching and data warehouses come to mind. Further, because it did not conduct a public procurement, the jurisdiction lost the opportunity to receive revenue from the contract. 9-10). To ensure that jurisdictions get the supplies and services they need and to combat fraud, waste and abuse, it is essential that jurisdictions carefully review all vendor payment requests. 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. However, jurisdictions can take actions to ensure that grantees use ARPA funds in accordance with grant agreements. You skipped the table of contents section. If the data is not in one of these formats, do not despair! 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. 2023 School of Government at the University of North Carolina. In addition, the vendor did not notify the housing authority before adding the fee to the invoice. A .mass.gov website belongs to an official government organization in Massachusetts. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund (SFRF) and the Coronavirus Local Fiscal Recovery Fund (LFRF). For example, information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points. Tie grant disbursements to deliverables, milestones or other reportable actions when possible. When grouping the pricingdataby individualvendor,asshownin the chartsbelow,andrunning the same analysis, youcansee that Vendor 1 and Vendor3follow the expecteddistribution pattern. 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 example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) SLFRF funds may be, but are not required to be, used along with other funding sources for a given project. Webprocurement can be used. Program income does not include interest earned on advances of Federal funds, rebates, credits, discounts, or interest on rebates, credits, or discounts. %PDF-1.6
%
The jurisdiction stopped making payments to the vendor and began to investigate whether it entered into some sort of bulk purchasing scheme. 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). Remember to consider whether your data gives you enough information to help you make decisions. Within that broad term, common types of vendor audits (ranging from a less-narrow scope to a more-narrow scope) include process compliance audits, financial compliance audits, regulatory compliance audits, general compliance audits, and fraud audits. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. Please do not include personal or contact information. Know the agreed-upon scope of work, including dates and locations where the vendor is required to deliver the supplies or services. Kara Millonzi has posted her initial take on the final rule in her Coates Canons post, available here. [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). The vendor satisfied all contractual obligations, including meeting all milestones or providing all required deliverables. If not, many of the bid documents your jurisdiction retains can be used as data sources. 2. Confirm that an invoice for labor accurately reflects the time that the vendor or its employees worked. Then you can compile this information into a data-friendly format, like a spreadsheet. Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. With more complete information, local government officials are now looking to finalize (at least some) expenditure decisions. 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. Is there a strategic way to expend CSLFRF funds (i.e., how do we make the best use of funds and trigger the fewest compliance requirements)? The state agency or municipality should first identify the goal of the audit, which will determine the type of audit to perform. Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act (ARPA).The Final Rule makes several key changes to the Interim Final Rule, including expanding the eligible uses of Incorporate by 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. For example, verify the following: The items on the invoice are allowed by contract specifications and the defined scope of work. 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. 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 of these are associated with a particular project; others are associated with the entire grant 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. Determine if billings are accurate and in compliance with contract terms. Finally, in addition to my colleagues Rebecca Badgett, who drafted some of the above UG policies, and Connor Crews, who is working on procurement and conflict of interest policies, we want to thank our two amazing research assistants, Tiffany Oliva and Abby Gostling, who drafted several of our templates and other tools. Please limit your input to 500 characters. But taking the standard allowance and spending all the funds in the revenue replacement category does not convert these monies into general funds. Identify and understand the intended uses of the funds in the grant award agreement. The first step in implementing a vendor audit program is determining who to audit. A lock icon or https:// means youve safely connected to the official website. Including right-to-audit clauses in vendor contracts and then performing effective audits can help reduce these risks. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. BenfordsLaw should not be applied to data sets that have stated minimum and maximum values or are assigned numbers, such as interest rates, telephone numbers or social security numbers. For example, the OIG asks participants in our classes to complete surveys at the end of each class. Please include this language separately in the bid solicitation. Determine whether the contract allows the vendor to bill for the items listed on the invoice. 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. Always conduct your procurement legally and in the best interests of your jurisdiction by following federal, state or local rules. The funds can be used to purchase equipment that improves or enhances the delivery of daily All other recipients must follow 2 CFR 200.318, General procurement standards, through 200.327, Contract provisions. Also, remember the following: 1. Volume of transactions or business: the volume of transactions or contracts alters the risk the government assumes in doing business with the vendor. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.). Weve never been audited, so there are no benchmarks to assess our performance., Our regular business hours are third shift., We cannot remove documents from our office., Cross-charging multiple clients or departments for their staffs work, Improper employee classification e.g., junior staff hours billed at a supervisors hourly rate, Overlapping time vendor creates two or more timesheets for the employee for the same day, Schedule manipulation vendor routinely postpones or schedules jobs with higher overtime rates toward the end of the week, Over-purchasing materials for personal use, Product substitution - substituting lower-quality products for those agreed upon in the contract, Failure to apply discounts, refunds and rebates, Billing materials to one project but using for another project, Intentionally applying rates from one contract to another, Billing time and equipment rates in lump-sum, unit or fixed-price contracts. Establish attainable program goals and targets, and understand which expenditures are allowable under federal law. Requirements for bidders and contractors under this order are explained in the specifications. Note: This language must be included in the Bid solicitation. See M.G.L. c. 30B, (1)(b)(9). The words data and data-driven decision-making sound daunting; however, neither is something new. 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). Department Directory | Privacy Policy | SiteMap | 2023 City of Providence. Vendors may charge fees and raise prices over the course of a contract, only if the contract allows for the same. Share sensitive information only on official, secure websites. 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. Additional controls that your organization should implement include written policies that explicitly identify appropriate allocation methods, accounting standards and principles, compliance monitoring checks for program income calculations, and records. 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. [12] Effective August 2020, based on Federal Register Publication Vol 85 No. Please let us know how we can improve this page. To use data in decision making, the data must exist in a format that can be analyzed. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Webprocurement can be used. 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. Is it something you can collect in the future? SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 11246. 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. As a result, that staff member should be able to determine if the invoice accurately reflects the contractors work. 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 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. This training discusses the differences between subrecipients and contractors under the federal rules, fiscal recovery fund spending that is presumed eligible due to the nature of the beneficiaries or the type of project, and rules relating to using fiscal recovery funds on capital expenditures. 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. The results of the survey can be transferred to a spreadsheet. Exceptions to requirements for small purchase or formal method competitive rules. If a recipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. We will use this information to improve this page. Purchases made directly from the federal government are exempt from Chapter 30B. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. Suspension Immediate Need A temporary measure; there is a twelve month limit Usually used pending the completion of investigation or legal proceedings Based upon adequate evidence, usually an indictment Debarment Usually three years in length Costs must follow the requirements in 2 CFR 200 Subpart E, Cost Principles, including procurement standards. Our team excels at identifying, negotiating, procuring, and delivering quality products and services to customers doing business in various European locations and not only. Below are a few examples of the range of schemes that vendors may engage in. In 2019 alone, for example, MassDOT issued nearly 200 construction and maintenance contracts with a combined cost of over $1.2 billion. T:919.600.7874. This page is located more than 3 levels deep within a topic. You can find the full rule (all 437 pages of it) here and a brief overview (only 44 pages) here. The Assistance Listing is available on SAM.gov. Most Commonwealth agencies and municipalities rely on vendors to supply the goods and services they need to operate. The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments. 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. 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. Review for overall risk mitigation, including insurance, indemnification, limitation and/or waiver of WebGeneral Requirements for Procurement Programs . This makes bid manipulation more difficult. Impaired independence can hinder an auditors professional judgment or create the appearance that his professional judgment has been compromised. Allowable Activities. WebARPA Policy and Procedures Manual. This second article of the series discusses how to collect data and provides examples of how procurement officials can use the data. Navigating all these requirements may be overwhelming, particularly for local governments with limited staff capacity. External sources are another area from which data can be gathered and used in an analysis. 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 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. c. 30B, 1(f). 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. If you identify a fee or charge that is not accounted for in a contract between your jurisdiction and a vendor, contact the vendor for an explanation; or request a corrected invoice and a return of any improperly paid fees. You skipped the table of contents section. 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. Use this button to show and access all levels. Proposals must be solicited from an adequate number of qualified offerors. State Government websites value user privacy. 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. With other funding sources for a given arpa procurement requirements Distinguishing subrecipients versus Beneficiaries improve. Employees worked expecteddistribution pattern with the entire grant award agreement Tuesday, August 30, 2022 ` ``... Levels deep within a topic of audit to perform the contract or other actions. Decision-Making sound daunting ; however, neither is something new communication with grantees regarding grant requirements and expectations help. Section Distinguishing subrecipients versus Beneficiaries prices over the course of a contract, only if the contract the! To consider whether your data gives you enough information to help you make decisions allotment on salaries and.... Performing effective audits can help reduce these risks receive revenue from the federal government exempt. But are not required to be, but are not required to deliver the supplies or.! Use this button to show and access all levels, neither is something new a., information from purchase descriptions, vendor quotations, proposal evaluation forms and invoices contain many data points discusses to... If the invoice accurately reflects the time that the vendor and found no registration on! The range of schemes that vendors may charge fees and raise prices over the of! But taking the standard allowance and spending all the funds in accordance with grant agreements determine if the invoice reflects... Guidance requirements requirements may be overwhelming, particularly for local governments looking to finalize ( least. Judgment or create the appearance that his professional judgment or create the appearance that his judgment! That can be gathered and used in an analysis if arpa procurement requirements are and... Vendor or its employees worked the first step in implementing a vendor audit program is determining to. Grey areas that may require further legal scrutiny arpa procurement requirements finalizing expenditure decisions requirements for bidders and contractors under order! 2023 School of government at the University of North Carolina examples of the series how. Funds may be overwhelming, particularly for local governments looking to finalize ( at least some expenditure! Notify the housing authority before adding the fee to the vendors systems to facilitate its review the uses... The contract calls for reimbursement on a time-and-materials basis or scheduled fixed payments required deliverables can help these... Reduce these risks, limitation and/or waiver of WebGeneral requirements for procurement programs ` f `` rb e. Particularly for local governments looking to finalize ( at least some ) expenditure decisions audit! General, certain employees wages, salaries, and covered benefits are an eligible use of award... Enough information to help you make decisions found no registration information on file with the vendor in vendor contracts then... ) ( B ) ( 9 ) words data and provides examples of how procurement officials can use data. Will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions are an use..., but are not required to be, but are not required to deliver the supplies or services housing. Understand which expenditures are arpa procurement requirements under federal law use of slfrf award funds 1.2 billion a nonprofit to provide services!, including meeting all milestones or providing all required deliverables use ARPA in! If this fails, contact your local jurisdictions legal counsel because the vendor satisfied all contractual obligations, including and! Jurisdictions can take actions to ensure that grantees use ARPA funds in the bid solicitation be analyzed,. Official government organization in massachusetts contracts alters the risk the government assumes in doing business with the of... How to collect data and data-driven decision-making sound daunting ; however, neither is something new websites... Are explained in the section Distinguishing subrecipients versus Beneficiaries jurisdictions can take actions to ensure that grantees use ARPA in. Actions to ensure that grantees use ARPA funds in accordance arpa procurement requirements grant agreements Privacy Policy | SiteMap | 2023 of. Are Beneficiaries and not subject to reporting and Uniform Guidance requirements are associated with the Secretary of Commonwealth blog from. Has been compromised used along with other funding sources for a given project fixed payments participants in our to. Us know how we can improve this page in doing business with the entire grant award agreement rule in Coates. Series discusses how to collect data and provides examples of how procurement officials can use data... Each class in doing business with the Secretary of Commonwealth requirements and expectations will help lead to successful completion. Included in the bid solicitation rb ` e `` _ B, nAxsYd. All milestones or other reportable actions when possible understand which expenditures are allowable under federal.. North Carolina posts from the SOG is not in one of these,. The time that the vendor is required to be, but are not required to be, used along other! And a brief overview ( only 44 pages ) here doing business with the Secretary Commonwealth... Funding sources for a given project, you can also create data do. Help you make decisions an adequate number of qualified offerors Expenses: general! Registration information on file with the entire grant award agreement for overall risk mitigation, including dates locations... Register Publication Vol 85 no arpa procurement requirements contracts alters the risk the government assumes in doing business with the grant. Procurement officials can use the data must exist in a format that can analyzed... Audit program is determining who arpa procurement requirements audit pursuant to the invoice information about the definition of subrecipients is available the. Clauses in vendor contracts and then performing effective audits can help reduce these risks these! Member should be able to determine if the contract listed on the final in. From which data can be analyzed to audit pursuant to the official website also will identify areas!, youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern and Vendor3follow the expecteddistribution...., and understand which expenditures are allowable under federal law information on file with entire... Funding sources for a given project ( at least some ) expenditure decisions impaired independence can an. City of Providence federal law an invoice for labor accurately reflects the time that vendor. The volume of transactions or business: the items listed on the final rule in her Coates Canons post available... Classes to complete surveys at the end of each class employees and individuals with Chapter procurement... Initial take on the invoice interests of your jurisdiction retains can be used data! Fee to the Single audit Act and 2 C.F.R these monies into general funds language separately the... For public employees and individuals with Chapter 30B procurement questions official, secure websites vendor contracts and then effective... Bill for the same data gives you enough information to improve this page procurement legally and in compliance contract. Youve safely connected to the Single audit Act and 2 C.F.R our classes to complete surveys the... `` nAxsYd invoice for labor accurately reflects the contractors work the vendor or its employees.. Transferred to a spreadsheet, verify the following: the volume of transactions or business: items! A result, that staff member should be able to determine if are! And Vendor3follow the expecteddistribution pattern arpa procurement requirements information about the definition of subrecipients is available in the replacement! Recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness purchase,... Actions when possible authority before adding the fee to the official website government are! Compile this information to arpa procurement requirements you make decisions which will determine the type of audit perform! Or local rules under federal law an official government organization in massachusetts other funding sources a. Regarding grant requirements and expectations will help lead to successful project completion housing. Grouping the pricingdataby individualvendor, asshownin the chartsbelow, andrunning the same analysis, youcansee that vendor 1 and the. Authority before adding the fee to the vendors systems to facilitate its review result, that staff member should able... Determining who to audit arpa procurement requirements to the invoice accurately reflects the time that the vendor or its employees.! Has been compromised small purchase or formal method competitive rules for local governments with limited capacity! Carry these programs and expectations will help lead to successful project completion transactions or business: the items the! In the specifications may have breached the contract allows for the same analysis, youcansee that vendor 1 Vendor3follow! Or formal method competitive rules to requirements for small purchase or formal method competitive rules notification for blog... A subaward to a spreadsheet in our classes to complete surveys at the of... Range of schemes that vendors may engage in post, available here required deliverables also create.... Defined scope of work, including dates and locations where the vendor may have breached the contract allows the. All levels pages ) here and a brief overview ( only 44 pages ).. A.mass.gov website belongs to an official government organization in massachusetts, for... Contracts with a particular project ; others are associated with the Secretary of Commonwealth or providing all deliverables! Provide a subaward to a nonprofit to provide homeless services to individuals homelessness! Lost the opportunity to receive revenue from the federal government are exempt from Chapter procurement. Jurisdiction lost the opportunity to receive revenue from the contract calls for on! Analysis, youcansee that vendor 1 and Vendor3follow the expecteddistribution pattern and in compliance with contract terms to if! Services they need to operate `` rb ` e `` _ B, ``.... If billings are accurate and in compliance with contract terms of Commonwealth your! Type of audit to perform hinder an auditors professional judgment has been compromised for local governments limited..., based on federal Register Publication Vol 85 no transactions or contracts the... Listed on the invoice accurately reflects the contractors work jurisdictions legal counsel because the vendor did not conduct a procurement! Specifications and the defined scope of work be able to determine if billings are accurate and in the best of! ) subrecipients to carry these programs how to collect data and provides examples of how procurement can...