Higher education institutions and not-for-profit organizations now need to consider the Uniform Guidance procurement requirements for fiscal year beginning July 1, 2018 when entering into construction contracts that have an element of federal funding. We have been tracking the key challenges faced by the Office of 管理 and Budget (OMB)’s release of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, referred to as “Uniform Guidance,” since it became effective in December 2014. 经过三年的延期期, the time is finally here for non-Federal entities with a June 30 year-end for fiscal year July 1, 2018年至6月30日, 2019年遵守.
All non-federal entities should update and enhance their written policies, 如果你还没有这样做, in order to comply with the modified procurement requirements. Policies should address the various types of procurement methods concerning tiers, 根据金额和奖励要求. The types of procurement methods vary from mico purchases of $3,000或以下, 150美元的小额购买,000美元或更少的密封出价超过150美元,000.
For non-federal entities entering into construction contracts, the small purchases and sealed bids will be most applicable procurement methods used. 当你购买3美元以下的小物品时,000 to $150,000, quotes must be obtained from an adequate number of qualified sources. OMB指南指出,“在密封投标过程中, public solicitation and a firm fixed price contract is awarded to the responsible bidder whose bid, confirming with all the material terms and conditions of the invitation for bids, 价格是最低的吗.” According to the procurement sections of the Uniform Guidance, located at 2 CFR 200.320, “the preferred method of procuring construction is the sealed bid method.“在竞标过程中, non-federal entities should consider a complete and adequate specification of the services requested, ensure two or more bidders are willing to complete for the business, and the selection of the successful bidder can be made principally based on price. 在与中标人签订合同之前, also remember to check that the Company is not on the suspended or debarred vendor lists. Solicitation is normally based on competitive proposals through a request for proposal process or noncompetitive negotiations from a single source when the services are unique.
With many of the non-federal entities electing the defer implementation of the Uniform Guidance requirements over the past handful of years, make sure your procurements policies and contracts are updated this summer to ensure that you comply and do not run into issues with purchasing.