Has your Procurement Department implemented the new Uniform Guidance for grant spending yet Cheat Sheet Procurement?
Thinking there will be another extension of the three-year grace period/
(Are you wondering “What grace period?” Keep reading…)
But the Procurement Department has had an extra long time to get everything in place for the new federal grant requirements. And that means that your purchasing folks may not be aware of the 823 “musts” for Federal grant recipients contained in 2 CFR Part 200.
Here are 14 questions for your Procurement Department Staff to make certain they are ready for the biggest change to grant management in decades!
But don’t worry about digesting all 100+ pages of the Administrative Requirements and Cost Principles.
We narrowed it down to these key areas:
14 Questions for Your Procurement Department
1) What is your process to update your contract provisions to comply with the new uniform grant guidance and terms and conditions on new awards and funding increments?
Monitoring and Reporting
2) What is your process to evaluate and monitor compliance with statute, regulations and the terms and conditions of Federal awards including contract provisions?
3) What is your process for taking action when instances of noncompliance are identified?
4) How do assure that all necessary affirmative steps are taken to include minority businesses, women’s business enterprises, and labor surplus area firms in procurements when possible?
5) If you are a pass-through entity, how will you comply with the new risk assessment and monitoring requirements that must be done prior to awarding work?
6) What internal controls are in place to mitigate risks of waste, fraud, and abuse of Federal funding?
7) What internal controls are in place to safeguard against any inappropriate alteration of records?
8) What are ways that you demonstrate compliance with Federal statutes, regulations, and the terms and conditions of the Federal award?
Written Policies and Procedures
9) What is your process to update your written procurement policies and procedures to reference the requirements in the new 2CFR Part 200 Administrative Requirements and Cost Principles?
10) What is your process to monitor for conflicts of interest, violations of law and gratuity violations potentially affecting the Federal award?
11) What is your process to notify the funding agency for mandatory disclosures of conflicts of interest, violations of law and gratuity violations potentially affecting the Federal award?
12) How do new staff members receive training on the employee requirements for conflicts of interest, compliance with award terms and conditions and Federal procurement requirements Cheat Sheet Procurement?
13) How will current staff members be trained on the new requirements contained in 2 CFR Part 200 Administrative Requirements and Cost Principles Cheat Sheet Procurement?
14) What is your process to keep staff up-to-date on changes to grant guidelines and the terms and conditions of specific Federal awards?
Three-Year Grace Period for Procurement
When the new grant regulations took effect on December 26, 2015, many of us were wondering how Procurement Departments would be ready to go on such short notice of the final agency guidance.
Not to worry…at least not TOO much…
The OMB extended three full fiscal year grace period for implementation of the procurement standards and that period is now ending.
How Does The Procurement Grace Period Work?
Here’s is an example:
If your fiscal year ends on June 30…then you would NOT be required to have the new procurement standards fully implemented until three full fiscal years after Dec. 26, 2014. In this case, that would be June 30, 2018.
Note if you are thinking you can wait to implement ALL of the new Uniform Guidance that is WRONG!
This grace period ONLY affected the procurement standards, not the rest of the new grant regulations implementation.
Pick a Procurement Standard
This grace period doesn’t mean you don’t need ANY standards, it means you have to pick either the old or new guidance to operate under.
Then you have to tell your auditors which procurement standards you are using so they know what compliance standards to use during their Single Audit Act audit.
The auditors would then audit you to those requirements during this grace period.
So take your pick!
It’s your choice during the grace period.
Ready to Improve Your Grant Management?
How about you?
Would you like to be a better grant manager?
We have another grant management training seminar coming soon.
Click here to get all the details!
Hope to see you there!
Lucy Morgan CPA, MBA
CEO, Compliance Warrior
Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.