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OMB Uniform Guidance
Key
Impacts on CNCS Grantee
3 - Procurement
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Dear Colleagues,
This
is the third in a series of messages concerning the Uniform Guidance, and what
it means to CNCS grantees.
§§200.317-200.326. Procurement Standards
Grant-funded
contracts must be managed in accordance with the procurement requirements in 2 CFR
Part 200.
Alternatively,
non-federal entities may continue to comply with the Procurement Standards in
previous OMB guidance for two additional fiscal years after December 26, 2014.
Such election must be specified in the non-federal entity’s internal
procurement policies.
Why
is this important?
- All CNCS grantees must have written
procurement policies and procedures that conform with applicable Federal,
State and local laws and regulations that demonstrate a fair and reliable
process, with standards of conduct addressing conflicts of interest, for
obtaining grant-funded goods and services. Typically, this involves full
and open competition and a bidding process, among other aspects, which are
outlined in this section of the Uniform Guidance. These policies and procedures
must also guard against the acquisition of unnecessary or duplicative
items.
- Grantees must use §200.330 –
Subrecipient and contractor determinations – to determine when a
contemplated arrangement is a subgrant or a contract.
- Grantees must ensure
adequate oversight over contracts awarded.
- Grantees must maintain
records that sufficiently detail the history of the procurement.
- Grantees must be good
stewards of taxpayer dollars.
- Failing to follow the
Procurement Standards in acquiring grant-funded goods and services may
result in the disallowance of the claimed costs by the awarding agency.
What
You Should Do
While grantees do have additional time to implement
the Procurement Standards at §§200.317-.326, grantees should begin to address
their procurement policies to ensure that the requirements of the Procurement
Standards will be timely incorporated. Grantees
should also obtain training in procurement if necessary and/or review their
policies and procedures to ensure that they are designed to maintain a
trustworthy and reliable procurement process that is in accord with the
Procurement Standards. Additionally, grantees’ internal controls must
provide for effective oversight and monitoring to ensure that they are in
compliance with their procurement procedures.
If
you have concerns or questions regarding the mandatory disclosure rules, please
send them to blewis@cns.gov. Your feedback and questions will guide us to
develop additional information and guidance.
In Service,
Dana Bourne
Corporation for National and Community Service Grant Offices
Washington, DC and Philadelphia, Pennsylvania
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