OMB Guidance – Key Impacts – Procurement

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                      OMB Uniform Guidance

Key Impacts on CNCS Grantee
3 - Procurement

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  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