There probably isn't any feature of the “super circular” 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 do not 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 is why there has been broad resistance to the revised policies and why OMB made unprecedented decisions to allow an extended grace period before implementing them. Well, the grace periods are over.
Recipient and subrecipient organizations must get with the program NOW by aligning their policies and procedures with the key changes including:
- New guidance on determining whether a relationship is with a subrecipient or a contractor
- Ramped-up code of conduct and mandatory disclosure instructions
- More directions about effective procurement planning
- Expanded discussion of the acceptable methods of purchasing, and when to use each
- Tighter requirements surrounding use of sole source purchasing
- Revised principles that must be used to assess allowability of costs that go into contract prices
- Confusion about the micro-purchase threshold for research and other activities
- Special rules for procurement of your annual single audit
The new rules are not just about how to buy supplies and equipment, where there are likely to be lots of suppliers. They must also be used when engaging professional services, collaborating on research projects and selecting service providers under social service programs. The marketplaces for these types of procurements are very different.
Join Bob Lloyd, principal of Federal Fund Management Advisor™, for this webinar that will get you up to speed on how to adjust your purchasing manual to the new requirements and how to handle grant-related purchases going forward.
Who Should Attend?
- Grant and contract managers
- Sponsored projects administrators
- Finance directors
- Purchasing agents
- Procurement Grant project directors
- Principal investigators
- Legal counsels
- Internal auditors
- External auditors
Hand-out Materials:
Attendees will receive presentation slides as well as access to background materials.
Allowable Charges
The costs of webinars sponsored by Federal Fund Management Advisor™ are allowable charges to your federal grants and subgrants. The cost principles issued by OMB under its uniform guidance (and applicable to all types of awardees) state, “The cost of training and education for employee development is allowable” (2 CFR 200.472).
Attend this Live Webinar and Earn up to 1.5 CPE Credits