About
Foundational Principles In the Community Diversity, Equity & Inclusion Technical Excellence Alumni TIAG Membership
Careers
Why Cohen & Company Our Culture Total Rewards & Benefits Intern & Entry Level Opportunities Experienced Opportunities
Contact
Akron, OH Baltimore, MD Chicago, IL Cleveland, OH Detroit, MI Milwaukee, WI New York, NY Philadelphia, PA Pittsburgh, PA St. Clair Shores, MI Youngstown, OH
Client Portal
Services Industries Knowledge Center People

About Our Services

We offer tailored solutions — whether private company or owner; public or private fund, adviser or fund service provider; or Fortune 1000 enterprise. Learn how we can help you.

Learn More

Assurance Services

Employee Benefit Plan Audits Internal Controls Investment Company Audits Private Company Audits SOC Readiness & Compliance

Tax Services

Federal Tax Planning & Compliance High Net Worth & Wealth Transfer International Filings & Structuring Investment Company Tax State & Local Tax Tax Credits & Incentives Transaction Tax Planning

Advisory Services

Business Valuations Data & Insights Digital Finance Solutions IT Strategy & Implementation M&A Advisory Outsourced Accounting Solutions Transaction Services Turnaround & Restructuring

Our Industry Expertise

Our industry experience means you can find professionals who speak your language and bring earned insights to the table. Learn how we can help you.

Learn More

Key Industries

Digital Assets Investment Companies Manufacturing Private Companies Private Equity Real Estate & Construction Technology & Life Science
VIEW THE COMPLETE LIST

Knowledge Center

Our team wants to help your team stay up to date. Browse our thought leadership, events and news for insights and a point of view on business-critical topics.

Learn More

Insights

Browse valuable articles and publications our experts have written to help you and your organization answer key questions — and consider new ones.

Read Our Insights

Events

Join us in person and online for events that address timely topics and key business considerations.

Explore Our Events

News

Find out what is happening at Cohen & Company, from industry recognitions and growth updates, to where we are contributing to important media stories.

Read Our News
People
Foundational Principles In the Community Diversity, Equity & Inclusion Technical Excellence Alumni TIAG Membership
Why Cohen & Company Our Culture Total Rewards & Benefits Intern & Entry Level Opportunities Experienced Opportunities
Akron, OH Baltimore, MD Chicago, IL Cleveland, OH Detroit, MI Milwaukee, WI New York, NY Philadelphia, PA Pittsburgh, PA St. Clair Shores, MI Youngstown, OH
Client Portal
Back to Insights

What Not-for-Profits Need to Know About the New Procurement Standards Effective in 2018

by Sarah Lee

June 19, 2018 Not-for-Profit

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: 

  • December 31 year-ends went live with the new standards on January 1, 2018
  • June 30 year-ends go live July 1, 2018, and
  • September 30 year-ends go live October 1, 2018 

Under the new Uniform Guidance, not-for-profits’ procurement efforts of any kind must comply with the following standards: 

  1. Document and maintain written policies and procedures over procurement. Ensure the policies meet all standards and incorporate any other applicable laws and regulations.
  2. Ensure costs incurred are necessary and cost-effective.
  3. Conduct procurement transactions in a manner that provides full and open competition.
  4. Maintain written standards of conduct covering conflicts of interest and governing the performance of employees engaged in the selection, award and administration of contracts. Policies must include disciplinary actions to be applied in the event of any violation of the standard.
  5. Maintain documentation addressing cost and price analysis, and vendor selection, as applicable for the selected method of procurement. 

The most significant revision to the requirements is that there are now five allowable methods of procurement with dollar thresholds for each: 

  1. Micropurchases (less than to $3,000)
  2. Small purchases (less than $150,000)
  3. Sealed bids purchases (more than $150,000)
  4. Competitive proposal purchases (more than $150,000) and
  5. Noncompetitive purchases (special circumstances, which are applicable for all purchase levels). 

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 slee@cohencpa.com or Marie Brilmyer at mbrilymer@cohencpa.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.
 


 

About the Authors

Sarah Lee, CPA

Director, Assurance
slee@cohencpa.com
330.315.4169

Sign Up for Our Emails & Events

Receive insights from our specialists in a variety of areas and timely information on upcoming events directly to your inbox as they go live in our online Knowledge Center.

Subscribe Today
Subscribe to our newsletter
About Contact Submit RFP Privacy Policy
LinkedIn Twitter Facebook
© 2023 Cohen & Company