Be Informed: Procurement Policy under the Uniform Guidance - Grants

Procurement Policy under the

Uniform Guidance

15th Annual Governor's Grants Conference October 15, 2019

Presenter

Meet the Instructor

Paul H. Calabrese Principal

Outsourced Accounting & Advisory Services

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Sources

? Uniform Guidance 2 CFR 200 or 45 CFR 75 for HHS Awards

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? COFAR FAQs under the CFO Council

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UniformGuidanceFrequentlyAskedQuestions.pdf

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Regulatory Requirements for Procurement

Types of policies and processes, roles and procedures in a Uniform Guidance compliant procurement system for the acquisition of goods and services

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The Procurement Standards

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5 Types of Procurement under the New Standards

Micro Purchase Small Purchase Procedures Competitive Procurements Sealed Bid Procurements Sole Source

The updated thresholds:

1. Micro Purchase updated threshold $10,000

2. Small Purchase Threshold from $10,000 to the updated Simplified Acquisition Threshold (SAT) of $250,000

3. Competitive Procurements updated SAT of $250,000

4. Sealed Bid Procurements updated SAT of $250,000

5. Sole Source does not have a threshold

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Updated Procurement Thresholds

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Procurement 200.320 FAQ.320-1

All (5) procurement types include the following standards

? Purchase complies with Non-Federal Entity's (NFE) documented procedures in place (audit & agency concern)

? Purchases are necessary (direct charge to a grant) ? Open competition as required for any of the methods (obtain

best/lowest price) ? Conflict-Of-Interest (price is not unduly high, arm's length

transactions) ? Proper documentation of the purchases (audit & agency concern)

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