UG significantly reforms federal grant making to focus resources on improving performance and outcomes. The intent is to reduce administrative burdens for grant applicants and recipients and reduce the risk of waste, fraud, and abuse.

Procurement guidance is specifically located in sections 200.317-200.326. This guidance focuses on increased competition and transparency in the procurement process.

General Procurement Standards

There are five general procurement standards that cover the purchase of property, supplies and services under the Uniform Guidance:

1. The organization must maintain written policies and procedures for procurement covering the methods available under these regulations.
2. Costs must be reasonable and necessary
3. Must provide for full and open competition
4. The organization must maintain written standards of conduct covering internal and external conflicts of interest
5. The organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used.

Methods of Procurement

Additionally, every sole source will require a price/cost justification.  Examples of methods of providing this documentation include:

• Documenting cost analysis efforts
• Documenting market research
• Including screenshots, emails, and/or catalog prices
• Documenting pricing information obtained from colleagues at peer institutions who have purchased the same or similar items
• Documenting prices of similar items

As part of the OMB’s Uniform Guidance, there are specific requirements for conflicts of interest within a procurement action and how the University must handle them.

The Regulation States

“No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.”