Finance Office

Grant Accounting - Uniform Guidance: Purchasing Policy & Procedures

Uniform Guidance 

Effective July 1, 2017 (FY2018) Rivier University requires compliance with the new Uniform Guidance (CFR Title 2: Grants and Agreements PART 200). Purchases funded by federal grant funds must adhere to regulations found in OMB Circular A-110, which details the administrative requirements for colleges with federally funded grants and agreements. Section e_40-48 outlines the required purchasing standards. Purchases made with federal funds are reviewed for compliance with the Federal Acquisition Regulation and the Office of Management and Budget Circular A-110.

The aim is to reduce the administrative burden on organizations that receive federal awards while mitigating the risk of waste, fraud, and abuse in purchasing practices while establishing best practices.

Overview

Rivier University previously followed the guidance in OMB Circular A-110 for newer federal awards and incremental funding but is now required to follow the new procurement guidance.

The uniform guidance is different from Circular A-110 in that it:
  • is designed to better mitigate the risk of waste, fraud, and abuse;
  • explicitly requires internal controls of how federal award money is used;
  • requires the entity to follow its own documented procurement procedures that reflect applicable state and local laws and regulations.
 

Effective Date

Rivier University’s fiscal year-end is June 30, and the effective date for the procurement requirements is July 1, 2017.
 
Methods of Procurement 
The uniform guidance outlines five methods of procurement: micropurchases, small purchases, sealed bids, competitive proposals, and non-competitive (sole source) proposals.

FinanceOffice_Grants_Purchasing_graphic

General standards apply to all types of purchases

  • Written policy guidelines for micropurchases, small purchases etc.
  • Purchases must be necessary and allowable. See Allowable/Unallowable Expense Reporting.
  • Purchases must be subject to full and open competition among vendors.
  • The purchase can't present a conflict of interest. See Requirement of Arm's Length Transaction below.

Micropurchases

  • Threshold-$3,500 and under
  • No bid or quotes are required
  • No cost or price analysis is required
  • Should be distributed to a range  of vendors

Small Purchases

  • Up to $150,000
  • Price and rate quotes are required from an adequate number of sources
  • Should be distributed to a range  of vendors

For Sealed bids, Competitive Proposals and Non-Competitive Proposals above the threshold $150,000 special documentation, analysis and vendor criteria must be considered.  See Section e_40-48.

Requirement of Arm's Length Transaction

No contract may directly benefit the employee forming the contract or the employee who is responsible for managing the contract or such a person's relative or personal friend, or poses other potential conflicts of interest whether real or perceived.

Shared Responsibility

The Principal Investigator (PI) is ultimately responsible for administering the grant. The PI must comply with the specific terms and conditions of the grant award and ensure that the program requirements of the award are fulfilled. Office of the Controller provides financial and administrative oversight for all external grants, contracts and agreements entered into by the University and works closely with the Principal Investigator to ensure that financial transactions comply with the granting agency and the University's accounting requirements.

 

 

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