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
2
Sources
? Uniform Guidance 2 CFR 200 or 45 CFR 75 for HHS Awards
? ?
? COFAR FAQs under the CFO Council
? ?
UniformGuidanceFrequentlyAskedQuestions.pdf
3
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
4
The Procurement Standards
5
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
6
Updated Procurement Thresholds
7
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)
8
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