Community colleges receiving federal funds should be well aware of the Uniform Grant Guidance (UGG) which went into effect on December 26, 2014. The most significant changes, relating to “Procurement Requirements” became effective on January 1, 2017, however, after a two year delay in required implementation.
Guidance with respect to UGG is extensive. It is noteworthy that UGG specifically requires policies and procedures over procurement in order to ensure that purchases are necessary and reasonable; open to competition; adhere to Conflict of Interest policies and are substantiated contemporaneously with proper documentation. The UGG also requires classification of purchases into 5 categories: micro-purchases (under $3,500), small purchases (under $150,000), procurement by sealed bids (over $150,000), competitive proposals (RFPs must be publicized, with responses from an adequate number of qualified sources) and non-competitive proposals (sole source).
From a practical perspective, starting on January 1, 2017, the purchase of any goods or services in excess of $3,500 with federal funds MUST be made in accordance with the new procurement rules. If your college has not formally implemented these new procedures, you should do so immediately. Your external auditors will be required to test compliance with these new rules in fiscal 2017 and it is likely that this area will be receiving increased scrutiny from the regulatory agencies, given that the procurement regulations have been publicly available for more than two years.
Gerald Archibald is a partner serving both of our Rochester, NY, and New York City offices.
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