Are you on track to adopt required updates to your procurement policies for federal grants under the Uniform Guidance? Chances are, if you are like the majority, you have been putting it off. Well, you have been very fortunate in that the guidance has allowed for several additional grace periods to implement the new procurement standards, although that luck has run out. Unless an additional grace period is allowed, local governments with June 30 year-ends will be required to implement new procurement standards effective July 1, 2018. So…. What do you need to know:
Go to www.ecfr.gov. Review title 2, subtitle A, chapter II, part 200. Specifically, pay attention from Section 200.318 – 200.326. Make sure your policy addresses these sections, as it relates to federal grant purchases, although consideration should be given for all purchases.
A few key points as you to cover:
- Procurement Policy must be documented and address procurement sections of the Uniform Guidance.
- Conflict of Interest Policy must be documented to ensure procurement process contains no conflicts of interest. Document language in section 200.318 (c). Make sure specific disciplinary action for violations are included or referenced.
- Purchases must be necessary and limit waste of government spending. Include specific language from the Uniform Guidance regarding these and related provisions.
- Procurement must be subject to full and open competition among vendors. Section 200.319. No preference for geographical preferences
- Specific Methods for Procurement to Follow:
a) Micro-purchase
- Without soliciting competitive quotes if reasonable
- Current threshold $3,500 (subject to change)
b) Small purchase
- Price or rate quotes must be obtained from an adequate number of qualified sources
- Current threshold $150,000 (subject to change)
c) Sealed Bid
- Formal advertising awarded to lowest responsible bidder
- Amounts greater than small purchase
d) Competitive proposal
- Must meet requirements to use this method
- Amounts greater than small purchase
f) Noncompetitive proposal
- Document justification and must meet requirements to use this method
- Amounts greater than micro-purchase
- Procurement must take all necessary steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible.
- Perform and Document cost analysis with every procurement and contract modification over the threshold
Good luck…. and if you need anything, feel free to reach out to your resources at LSL CPAs.
