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Uniform Grant Guidance Procurement Methods

Audit|Higher Education|Not-for-Profit

By Tracy Smith

The Uniform Grant Guidance (UGG) has brought about sweeping changes to grants management and includes many changes to procurement policies and procedures.  The actual code of federal regulations related to grants and agreements can be found at www.ecfr.gov.  The section is 2 CFR Title 2, part 200.  If you don’t have a few hours to read and digest the entire section of code related to these changes, then the information in this article will be a helpful tool to get your procurement policies and procedures in line with the latest guidance.

The UGG has defined five specific allowable methods of procurement when purchasing items with federal funds. 

Five Methods of Procurement Defined by the Uniform Grant Guidance (UGG)

  • Micro Purchase – aggregate dollar amount does not exceed $3,000
    • when practical, distribute equitably among qualified suppliers
    • this type of procurement does not require competitive quotes if management determines the price is reasonable
  • Small Purchases – up to the Simplified Acquisition Threshold (currently $150,000)
    • informal procedures are acceptable
    • price or rate quotes must be obtained from an adequate number of sources
  • Sealed Bids – purchases over the Simplified Acquisition Threshold
    • formal solicitation required
    • fixed price awarded to responsible bidder who conformed with all material terms and is the lowest in price
    • most common for construction projects
  • Competitive Proposals – purchases over the Simplified Acquisition Threshold
    • formal solicitation required
    • fixed price or cost-reimbursement contracts; used when sealed bids are not appropriate
    • awarded to responsible firm whose proposal is most advantageous to the program, with price being one of the factors
  • Noncompetitive Proposals – this may be used only when one or more of the following apply:
    • the item is available from a single source
    • the public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation
    • the federal awarding agency (or pass-through entity) expressly authorizes this method in response to a written request from the non-federal entity
    • after solicitation of a number of sources, competition is determined to be inadequate

Updating your policies and procedures to include the above changes was necessary by December 27, 2015, if you receive and expend federal funds. 

Stay tuned to our website for more articles to assist your organization in complying with the rigorous UGG requirementsIf you have any questions on the above material, please contact your Schneider Downs team members, and we will be happy to assist your organization in meeting these new requirements.

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Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.

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