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Uniform Guidance procurement changes: implementation reminders and resources

Many questions have arisen for governmental, not-for-profit and higher education organizations implementing the Uniform Guidance (UG) procurement standards. These standards became effective, after a two-year grace period, for fiscal years beginning after Dec. 26, 2017.

Here are important considerations as you implement the UG procurement standards:

  • Ensure documentation exists as to whether or not your organization took advantage of the grace period allowing delayed adoption of the new procurement changes under the UG
  • Review the Office of Management and Budget (OMB) memorandum issued June 20, 2018 raising the threshold for micro purchases under federal financial assistance awards to $10,000 from $3,500 and the threshold for simplified acquisitions to $250,000 from $150,000 “for all recipients.” OMB has subsequently indicated these new thresholds become effective after codification in the Federal Acquisition Regulation. Reach out to your federal cognizant agency with questions on timing of this increase.
  • Review the key considerations outlined in the standards and ensure you are meeting the minimum “must” requirements, which include having a documented policy that outlines the procurement methods to be followed
  • Ensure your organization has adequate conflict of interest policies and procedures
  • Maintain documentation of the selection process when procurement is sourced from multiple vendors

To further help organizations navigate the minimum requirements of the UG procurement policies and procedures, Baker Tilly has created a Uniform Guidance procurement policy checklist. This resource outlines the Uniform Guidance key provisions, identifies “must” versus “should” requirements and provides an overview of the procurement methods to be followed.

For more information on this topic, or to learn how Baker Tilly state and local government specialists can help, contact our team.