UG procurement standards have gotten another reprieve in an announcement in the May 17 Federal Register. The Office of Management and Budget (OMB) issued an amendment to the uniform grant guidance that provided for an additional one-year grace period for implementation of the UG procurement standards.
The implementation date for the procurement standards will now start for fiscal years beginning on or after Dec. 26, 2017. No other provisions of the uniform guidance were changed in this amendment.
What This Means for Federal Grant Recipients
If you receive federal funding this is great news for you. You’ll have more time to implement all 10 sections of the procurement standards, and to address questions, nuances and challenges that will arise when your staff begin implementing new procurement practices.
If you’re still working towards compliance, we’ve created a simple UG Procurement Readiness Checklist that you can download and follow to undertake the activities needed to get compliant.
And Don’t Forget to Document Your Deferral Election
If you decided to delay implementation of the procurement standards, make sure you document your election. It’s required under the UG, and your auditors will likely ask to see it.
If you haven’t yet documented your election to defer implementation of the UG procurement standards, here is some sample language we developed (with the assistance of a few of our auditor colleagues) that should be acceptable to your auditors when they ask. We recommend, however, you refine the language to meet your organization’s unique circumstances.
“ABC Organization has elected to defer its implementation of the Uniform Guidance procurement standards until fiscal year [insert appropriate date]. ABC Organization will continue to comply with existing OMB Circular [insert appropriate circular reference] through fiscal year [insert proper date], but will also work to update policies and procedures to ensure full compliance with the new procurement standards beginning in fiscal year [insert date].”
Author: Tom Rogers
Job Title: CEO
Organization: Vendor Centric
Tom is the founder and CEO of Vendor Centric, he has been a trusted advisor to nonprofit organizations for 30 years, with a focus on helping them align the right people, processes and systems to mitigate third-party risk and drive more value from third-party contracts and relationships.