In May 2017, the Office of Budget and Management (OMB) issued guidance to allow an additional grace period of one year for non-federal entities to comply with the procurement standards of the Uniform Guidance. The implementation date will now start for fiscal years beginning on or after December 26, 2017.
The original procurement guidance was included in the Uniform Guidance issued in December 2013 and represented a significant change to the current guidance at that time. Among the changes were the following requirements:
What should you do now? Even though an extended grace period has been granted, your nonprofit organization should take steps to move towards compliance with the new procurement standards. First, document your current procurement and standards of conduct (if not already done) and assess how they will need to change. Educate those in the purchasing area to ensure they are aware of the new policies. Finally, evaluate your internal controls surrounding purchasing and adjust them as needed.
Cohen & Company is not rendering legal, accounting or other professional advice. Any action taken based on information in this blog should be taken only after a detailed review of the specific facts and circumstances.
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