Updating Your Organization's Procurement Policy

The Uniform Grant Guidance (UGG) has brought about sweeping changes to grants management with a focus on an organization’s internal controls.  The UGG requires an organization to establish and maintain effective internal controls over federal programs.  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 policies and procedures in line with the latest guidance.  One of the areas affected by the new UGG is procurement. 

Important Items to Consider When Updating Your Organzation's Procurement Policies and Procedures

  1. Organizations receiving federal funds must have documented procurement policies that reflect federal law, standards of the UGG and any state regulations, 
  2. Organizations must have written standards of conduct that include policies about conflicts of interest and governing the actions of employees engaged in the selection, award and administration of contracts,   
  3. Organizations must maintain oversight of their contractors,
  4. Records must be maintained sufficiently to detail the history of the procurement, such as:
    1. rationale for the method of procurement,
    2. selection of contract type,
    3. contractor selection or rejection, and
    4. basis of the contract price.
  5. Prior to entering into a contract that uses federal funds, organizations must ensure that the contractor has not been suspended or debarred from doing business with the federal government.  The website to check for suspended and debarred parties is www.sam.gov.  

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 requirements.  If 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.

our thoughts on

array(3) { [0]=> string(1) "6" [1]=> string(2) "53" [2]=> string(2) "21" }
Artificial Intelligence in Higher Education
Why Higher Education Institutions Must Comply with GDPR
Audit BY Adam Goode
Is It Time to Overhaul the Income Statement?
The Dichotomy of Cybersecurity in Higher Education
Minimizing Higher Ed Risks - Utilizing Internal Audit and Data Analytics
Enterprise Risk Management in Higher Education, and How Internal Audit Can Help

Register to receive our weekly newsletter with our most recent columns and insights.

Have a question? Ask us!

We’d love to hear from you. Drop us a note, and we’ll respond to you as quickly as possible.

Ask us

contact us

Map of Pittsburgh Office

One PPG Place, Suite 1700
Pittsburgh, PA 15222

p:412.261.3644     f:412.261.4876

Map of Columbus Office

65 East State Street, Suite 2000
Columbus, OH 43215

p:614.621.4060     f:614.621.4062