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Federal Award Procurement Requirements - What You Need to Know Now
Christina Rothman Ondrako, CPA, Partner
March 2016

As mentioned in a previous article, the "Uniform Guidance" reforms are wide sweeping and will impact all entities that receive federal and state monies. One of these reforms has to do with procurement requirements.

Under the new OMB Uniform Guidance (2 CFR 200) there are significant procurement requirements that are now in effect. This guidance applies to ALL entities receiving Federal awards. We have included some of the highlights of the new requirements below; however, it is important that you read and become familiar with the Uniform Guidance general standards section 200.318:


Some of the most important areas to address right now are:

  1. Agencies must have formally documented procurement policies which reflect federal law, standards of Uniform Guidance, and any state regulations and follow such policies;
  2. All expenditures should be necessary (and economical - shared service purchases recommended where practical);
  3. Written standards of conduct covering conflicts of interest and governing the performance of employees engaged in the selection, award and administration of contracts; actual and apparent conflicts must be documented and such individuals must excuse themselves from the selection process; 
  4. Agencies must maintain a record of procurement activities/steps including selection of contractor and price;

Full and open competition must be maintained in accordance with section 200.319. https://www.gpo.gov/fdsys/pkg/CFR-2015-title2-vol1/pdf/CFR-2015-title2-vol1-sec200-319.pdf

There are 5 methods of procurement outlined in the guidance section 200.320.  https://www.gpo.gov/fdsys/pkg/CFR-2015-title2-vol1/pdf/CFR-2015-title2-vol1-sec200-320.pdf

1. Micro Purchase

a.  Aggregate dollar amount does not exceed $3,000 ($2,000 if subject to Davis Bacon)

b.  When practical, distribute equitably among qualified suppliers

c.  No competitive quotes required if management determines pricing is reasonable

2. Small Purchase

a.  Purchases up to the Simplified Acquisition Threshold (currently $150,000)

b.  Informal procedures acceptable

c.  Price or rate quotes must be obtained from an adequate number of sources

3. Sealed Bids (preferred)

a.  Purchases over the Simplified Acquisition Threshold (currently $150,000)

b.  Formal solicitation required

4. Competitive Proposals

a.  Purchases over the Simplified Acquisition Threshold (currently $150,000) when sealed bids not appropriate

b.  Formal solicitation required

c.  Awarded to responsible firm whose proposal is most advantageous to the program, with price being one of various factors

5. Noncompetitive Proposals

May be used only when one or more of the following apply:

  • The item is available only from a single source
  • Emergency situations that will not permit a delay for competitive solicitation
  • The Federal awarding agency (or pass-through entity) expressly authorizes this method in response to a written request from the Agency
  • After solicitation of a number of sources, competition is determined inadequate

For guidance on the new non-profit audit requirements, contact Christina Rothman Ondrako, CPA, Partner.  

Christina is in charge of non-profits in the areas of audit and attest engagements, financial statement preparation, internal control review and special agreed upon attest procedures.

She can be reached at 315.701.6342 or condrako@gsacpas.com.

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