UPDATE – The micro purchase and simplified acquisition thresholds have been amended since this blog was written. See the blog post titled for more details.
In our 2017 survey of nearly 150 federal grant recipients, we learned that nearly 4 out of 5 were not yet compliant with the Uniform Guidance procurement standards. And of those, 25% weren’t even sure of where they were in the process!
The Uniform Guidance procurement standards have brought about sweeping changes for many federal grant recipients.
In addition to prescribing five methods of procurement that must be used when purchasing goods or services with federal dollars, the standards also laid out a variety of other fundamental procurement requirements that must be followed including:
- Avoiding conflicts of interest by employees, officers or agents who are engaged in the selection, award and administration of a contract.
- Performing an appropriate level of due diligence to ensure contracts are only awarded to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement.
- Ensuring prospective and current contractors are not on the System for Award Management (SAM) exclusion list.
- Maintaining a history of the procurement process that should include, at a minimum, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.
- Conducting procurements in a manner that provides full and open competition.
- Taking affirmative steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible.
- Performing a cost or price analysis when procurements exceed the Simplified Acquisition Threshold (currently $150,000).
- Requiring certain contractual provisions are included in contracts as defined in Appendix II to Part 200—Contract Provisions.
If your organization is still working to get compliant, you no longer have to guess as to how much further you have to go to be ready to implement these new procurement standards.
We’ve developed a Uniform Guidance Procurement Readiness Checklist that you can use to evaluate where you are in the process to get compliant, and identify the activities you may still need to undertake to become fully compliant before the procurement regulations go into full effect in 2018.
Download your free copy of the checklist now.
Author: Tom Rogers
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.