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There probably is not any feature of the Uniform Guidance issued by the Office of Management and Budget that has caused more angst than the rules on procurement of goods and services using federal grant funds. For starters, some of the policies were modeled on those that apply to the federal government itself, and frankly, those features don’t fit most recipient and subrecipient organizations very well.
Beyond that, there are other subtle and not-so-subtle departures from familiar requirements that could introduce new audit vulnerabilities. That’s why OMB made unprecedented decisions to allow an extended grace period before implementing them. Well, the grace period is over, and thousands of federal grant recipients are in the midst of implementing all of the new procurement requirements under the Uniform Guidance. And most are finding that the process isn’t so easy.
“There are over 40 new procurement requirements under the Uniform Guidance, and many of them are just very different from what our grant funded clients have been doing in the past,” says VendorCentric CEO, Tom Rogers. “As they work to adopt these new requirements, one of first big decisions our clients are having to make is whether they should try and adapt their current procurement policies and procedures, or simply start from scratch because the changes are so different from what they’ve been doing.”
Many federal grant recipients are still in the very early stages of updating their policies and procedures; and many haven’t yet started the process. Those that have gone through the process have been faced with a variety of challenges. Here are the Top 10 we’ve been seeing thus far:
Mapping the Standards to Existing P&Ps - Do they modify existing policies and procedures or start fresh?
Handling non-Federal Procurements - Should they follow Federal requirements for all procurements regardless of source of funding?
Implementing the Five Methods of Procurement - How many bids are ‘adequate’? Do they adopt all five methods even if some have never been used before?
Using Sole Source - When is it ok and what needs to be documented?
Managing SAM Checks - How frequently and at what stage(s) of the process?
Performing Cost and Price Analyses - What is required for a cost analysis and how do you actually ‘negotiate profit’?
Identifying SMWBEs to Include in Solicitations - Where do you find them and how do you ensure inclusion?
Managing Pre-Qualified Lists - How best to coordinate with departments to ensure their lists are maintained?
Ensuring Contractual Standards - What standards are required? Who is responsible for maintaining them?
Maintaining a History of All Procurement Activities - How much to document? Where should it be documented and where should it be stored?
Despite all of these challenges, a by-product of the process is that it has given organizations an opportunity to make needed changes to their procurement policies and procedures that have nothing to do with the Uniform Guidance. “In a lot of cases, our clients are taking this opportunity to step back and think about procurement more strategically,” said Rogers. “Clients are able to really look at the whole process from scratch, and then address workflow challenges that have always been an issue for them.”
Hear more about these Top 10 challenges by listening to our podcast titled 10 Policy and Procedure Challenges We’re Seeing with The Uniform Guidance Procurement Standards.
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Vendor Centric specializes in helping organizations create and mature the policies, procedures and systems they use to manage their important vendor relationships. Learn more about our vendor management software and services.