By Kurt Schlicker
March 27, 2018
For all governmental, nonprofit and nonprofit health care entities that receive federal funding, the deferred period allowed under Uniform Guidance has either ended or is very near. If you recall, the Uniform Guidance procurement standards were allowed to be deferred for three fiscal years after December 26, 2014. As such, the effective date for implementation will start for fiscal years beginning Jan. 1, 2018, and later.
Many of you may have already started updating your policies or are in the process of doing so. As you continue to develop and refine your policies, refer to the recap below, which provides an overview of the essential key items that your procurement policy must entail.
Review Your Procurement Policies
The above requirements apply not only to the costs reimbursed by the federal program, but also to any costs claimed to meet matching requirements. We encourage you to do a thorough review of the general procurement standards in 2 CFR Part 200 (§200.317 - §200.326) and ensure your entity’s procurement policies are updated to reflect the provisions under Uniform Guidance. For entities subject to Single Audit requirements, testing will be required to ensure that purchases are made in accordance with the procurement policy provisions the entity adopts. If you have any questions or concerns regarding the requirements, please contact an Eide Bailly team member for assistance.