In 2013, the Office of Management and Budget (OMB) issued new procurement standards under Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and then extended their implementation for nonfederal entities until after 2017. The new standards bring significant documentation requirements for not-for-profits procuring goods and services from outside vendors.
However, time is up! Beginning in 2018, all not-for-profits must comply according to the schedule below:
Under the new Uniform Guidance, not-for-profits’ procurement efforts of any kind must comply with the following standards:
The most significant revision to the requirements is that there are now five allowable methods of procurement with dollar thresholds for each:
Don’t underestimate the changes in the new rules or the compliance challenges they bring. As documentation remains one of the more important requirements under the new guidance, work toward ensuring all of your policies and procedures surrounding procurement have been appropriately documented and communicated to all applicable employees. Increased documentation also includes keeping all quotes received, rationale for selections, cost/price analysis and negotiation memorandum.
This post is a primer to all of the detail included in the new procurement standards. Hopefully your not-for-profit has made the time and effort to understand the requirements and revisit your related policies and procedures. If not, begin working with your audit team now to help get you up to speed.
Read the entire text of the new procurement standards.
Please contact a member of your service team, or contact Sarah Lee at firstname.lastname@example.org or Marie Brilmyer at email@example.com for further discussion.
Cohen & Company is not rendering legal, accounting or other professional advice. Information contained in this post is considered accurate as of the date of publishing. Any action taken based on information in this blog should be taken only after a detailed review of the specific facts, circumstances and current law.
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