Can you believe it? The first quarter of 2017 has ended, spring is here and we are headed toward summer. This also means that the deferment period on the U.S. Office of Management and Budget’s (OMB) procurement standards has come to a close.
In September 2015, the OMB issued an amendment providing a two-year grace period for implementation of the procurement standards in 2 CFR 200.317 through 200.326 for all non-Federal entities. The grace period referenced a full fiscal year that began on or after December 26, 2014, the effective date of Uniform Guidance. Therefore, if a non-Federal entity’s fiscal year begins on January 1st, that entity’s procurement procedures must comply with Uniform Guidance as of January 1, 2017. Likewise, for June 30 fiscal year end non-Federal entities, the procurement procedures must comply as of July 1, 2017.
So for those of you who deferred, does your procurement policy cover the required documentation? Here is a brief refresher of key things to make sure you have documented in your policy.
- Process for contractor selection – The contractor selection process must be in line with set acquisition thresholds and demonstrate full and open competition, which are defined by the five methods of procurement:micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive proposals.
- Contractor oversight – The entity must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.
- Written employee conduct policies – The entity must have policies to cover conflicts of interest and the monitoring of performance for employees engaged in the selection, award and administration of contracts.
- Record maintenance – The entity must maintain records that document the rationale for the method of procurement, selection of contract type, contractor selection or rejection and the basis for the contract price.
Make sure that you are covered and review the complete procurement requirements here.