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If you received federal funding, the final date to have an appropriate procurement policy in place was July 1, 2018.
If you are subject to an audit under Uniform Grant Guidance, your CPA should be testing that you in fact have adopted an appropriate procurement policy and that you are following it.
Some things to consider: Compliance with UGG was not required until 7/1/18, so purchases before that date can be under another policy, but that policy should be documented. If you a calendar year end organization, this means purchases for half the year need to be under the newly adopted policy.
If you receive both federal money and nonfederal support, you are only required to follow UGG Procurement Policy for federal expenditures. This can potentially make nonfederal purchases less cumbersome, but it will require two policies in place, and staff training to ensure the appropriate policy is followed in the appropriate circumstance.
The requirements under UGG are as follows:
- Every non-federal entity receiving federal awards must have documented procurement procedures that reflect federal law, Uniform Guidance standards, and any state regulations.
- Entities should focus on the most economical solution during the procurement process and must avoid using federal funds for the acquisition of unnecessary items. Organizations are encouraged to consider the use of shared services and intergovernmental agreements to foster greater economy and efficiency.
- Written conflict-of-interest policies are required. No employee or agent of the entity may participate in the selection, award, or administration of a contract funded by federal grant dollars if he or she has an actual or apparent conflict of interest.
- The organization must document the procurement steps and activities required to be completed. This includes the basis for the type of procurement, contract type, and the basis for the contractor selection and price.
- Ultimately, the recipient of federal awards must maintain an appropriate level of oversight to ensure that contractors perform in accordance with the terms of their contract.
There are three types of purchases that must be addressed in a procurement policy:
- Micro purchases - under $10,000
- may make purchase without a competive bid process, if entity considers the price to be reasonable
- must distribute amoung qualified suppliers
- Small purchases - under $250,000
- Price or rate quotes must be obtained from an adequate number of qualified sources
- Competitive proposals - over $250,000
- Bids publicly solicited, many more requirements.
Contact RINA if you would like assistance with your procurement policy.