This is the tenth section in our thirteen part series on “The Busy Person’s Guide to Grant Management.”
DO YOU RECOGNIZE THE FOUR MAIN ELEMENTS OF PROCUREMENT RECORDS? HERE’S A QUICK REVIEW.
Doesn’t it seem like the list of documentation requirements for Federal Grants is endless? Procurement is an area of Grants Management that requires lots of record-keeping and documentation. Yes, it does seem like even more than other areas of Grants Management!
When it comes to spending Federal funds, there may be many different people requesting things, but the purchasing department is where the auditors will focus their laser beam. That’s because Procurement is viewed as one of the first lines of defense against improper spending of Grant funds.
The Busy Person’s Guide to Procurement Records
Let’s start our review of the procurement records by looking at the four main elements of procurement records.
Four Elements of Procurement Records
Here are the four main areas that should be covered in your procurement records according to the Administrative Requirements are:
- 1) The requirements in a lease vs. buy decision
- 2) A cost or price analysis
- 3) The specific elements that must be documented for solicitation of goods and services
- 4) Contract provisions that you may need to document in procurement records
What should be included in each of these areas? Let’s take a look:
#1 Lease vs. Buy Analysis
When the Recipient has the option to either buy or lease goods, a lease vs. buy analysis must be performed.
This analysis must determine which option is the most economical and practical, and document the results of that analysis.
#2 Cost/Price Analyses
For every procurement action, the Federal Administrative Requirements requires some form of cost or price analysis. The extent of the analysis may depend on a number of factors including the size of the procurement.
This analysis should be included with the procurement documentation.
#3 Solicitations of Goods and Services
When you start soliciting goods and services, there are a number of elements that must be included with the procurement records.
Let’s look at some of the items:
- 1) The solicitation must include a description of the needed goods or services.
- 2) This description must be clear, accurate and spell out the technical requirements.
- 3) The description should not contain elements which unduly restrict competition.
It is worth noting that including “brand” names in the description of goods may be viewed restricting competition.
Bid Requirements and Evaluation
Next, the solicitation documentation should describe what requirements the bidder is expected to fulfill.
The solicitation should also include what factors will be used to evaluate the bids.
Description of Technical Requirements
Now let’s look the description of technical requirements:
- 1) Whenever practicable, the solicitation should describe the technical requirements for the procurement in terms of the “functions to be performed”.
- 2) The solicitation should include a range of acceptable characteristics or minimum standards.
Remember, the overall goal of these standards is not to impair competition by needlessly restricting the technical specifications.
Procurement Files Documentation
As part of the documentation of the solicitation for goods and services, the procurement records should also include the following items for purchases in excess of the small purchase threshold:
- 1) The basis for the contractor selection
- 2) The basis for the price or cost of the purchase
- 3) If applicable, for example, a sole source purchase, a written justification documenting the reasons for the lack of competition on the procurement
#4 Contract Provisions
Finally, there are numerous contract provisions which potentially must be included in contracts the Recipient issues with contractors.
Some of these contract provisions may be required regardless of the size of the procurement. Compliance documentation should be included in the procurement records. Let’s view a couple examples.
Examples of Contract Provisions
The Procurement Standards state that a preference and acceptance of the metric system to the extent “practicable” and “economically feasible” should be included in solicitation. Even though this system hasn’t found widespread acceptance, it is none-the-less a contract provision required in the procurement records.
Next, the Procurement Standards requires procurement documentation to contain concern types of “green” preferences when soliciting goods and services. The items cover such things as:
- 1) Conserving natural resources
- 2) Protecting the environment
- 3) Encouraging energy efficiency
Note that preferences are required “to the extent practicable and economically feasible.”
Procurement Records Checklist
Remember, procurement files are one of the areas that the auditors love to go through. We’ve include a procurement records checklist resource for you to keep all the requirements straight.
Download the Procurement Records Checklist
P.S. Here’s even more free information.
Check out the Procurement Records Video Lesson.
Length: Approx. 3 minutes
Get your own very cool, one page “Quick Reference Guide: Procurement Records.”
(Just click on the link to download the .pdf file.)
This is the tenth section in our thirteen part series on “The Busy Person’s Guide to Grant Management.”
Want to find out more?
You can find out more about the requirements for procurement of goods and services purchased with Federal funds in these online courses:
For State, Local and Tribal Governments:
http://www.myfedtrainer.com/2011/1270-procurement-standards/
For Non-profit Organizations:
http://www.myfedtrainer.com/2011/1070-procurement-standards/
For Institutions of Higher Learning:
http://www.myfedtrainer.com/2011/1170-procurement-standards/
These courses cover Procurement Standards required for Federal Grant Recipients, specifically:
- 1) The requirements for written Procedures in the Procurement Standards
- 2) Procurement elements that must be included in the written Procurement Procedures
- 3) Various topics related to “free and open” competition in Procurements
- 4) Other Contract Issues such as Contract Administration, Contract Requirements and Contract Provisions
P.S.S. These individual courses are marked down to only $49 for a limited time.
Buy now for the best pricing.
For State, Local and Tribal Governments:
http://www.myfedtrainer.com/2011/1270-procurement-standards/
For Non-profit Organizations:
http://www.myfedtrainer.com/2011/1070-procurement-standards/
For Institutions of Higher Learning:
http://www.myfedtrainer.com/2011/1170-procurement-standards/