The two-year deferral period for implementation of the procurement standards under Uniform Guidance (UG) is officially over. As of midnight on January 1, 2017, organizations receiving federal funds with a calendar year-end of December 31 MUST implement policies and procedures to ensure compliance with the standards effective immediately. Is your organization behind or struggling with the new procurement standard? You may be one of many organizations that underestimated the significance of the standard and/or the amount of resources an organization will need to comply.
Before you do anything, it is important to understand the five methods of procurement under the new UG procurement standard*.
- Small purchase procedure
- Sealed bids
- Competitive proposals
- Noncompetitive proposals
Detailed definitions of each method of procurement are available here on the website of the Government Publishing Office.
If your organization is behind with implementation, there are 10 things you can do immediately to fast track your organization in reaching compliance.
- Read the standard: 2 CFR Part 200 Sections 200.317-200.326
- Document your policies and procedures in writing as required.
- Publish your standards of conduct regarding conflict of interest in writing as required.
- Use responsible contractors and provide oversight.
- Avoid acquisition of unnecessary or duplicative purchases.
- Focus on efficiency via shared goods and services.
- Encourage the use of federal excess and surplus property in lieu of buying new property.
- Use value-engineering clauses in contracts for construction projects.
- Maintain records to detail the history of the procurement. Providing a standardized form is a great tool to ensure compliance by staff.
- TRAIN, TRAIN and TRAIN. Continuous training of staff is crucial to ensure a successful implementation.
With their start dates approaching quickly, non-federal entities with fiscal year ends other than December 31 are also advised to begin preparing now. For more information or questions about the new UG procurement standard, contact GRF Nonprofit Audit Partner, Terri McKnight, CPA at firstname.lastname@example.org or 301-951-9090.
* UPDATE: The Office of Management and Budget (OMB) recently published exceptions to the Uniform Guidance Procurement Standards which increase the Simplified Acquisition Threshold (SAT) from $150,000 to $250,000, and the Micro-Purchase Threshold (MPT) from $3,500 to $10,000. Click here for the OMB Memorandum.