Purchasing Changes
2 CFR 200.318-320
OSU Grants & Contracts Financial Administration
Considerations
• Is the purchase grant-related?
OSU Grants & Contracts Financial Administration
General Standards
• Documented Policies
• Necessary Purchase
• Redundant
• Appropriate
• Dollar Amount
• Full and Open Competition
• Conflict of Interest
• Documentation
• Cost/Price Analysis
• Proper Selection Process in vendor Choice
OSU Grants & Contracts Financial Administration
Necessary/Grant-Appropriate/Redundant
• Is the purchase allowed
• Under federal standards
• Approved by Agency
• Budgeted
• Policies in place
• Preventing redundant purchases
• Lease vs. Purchase Cost Analysis
OSU Grants & Contracts Financial Administration
Federally-imposed hierarchy for Purchases made
in support of Federal Grants or Contracts
• < $3,000 Micro Purchases
• > $3,000 - $150,000 Small Purchases
• > $150,000 Large Purchases (Sealed Bids)
• > $150,000 Large Purchases (Competitive
Proposal)
• Noncompetitive Purchases (All levels)
OSU Grants & Contracts Financial Administration
Micro-Purchases for Federal Grants
• < $3,000—Simply Follow institutional Purchasing
Policies.
• For the Federal Government’s Benefit,
• No bid is required.
• No sole-source process is required.
OSU Grants & Contracts Financial Administration
Small Purchases
• Follow Institutional Policy, but
• For Purchases >$3,000 but < $150,000 in support of
a Federal Project
• Must be able to show that quotes were solicited
(more than one quote)
• Or, Prove strategic sourcing (institutional/state
contracts)
• Or, justify the rationale for any sole-source
OSU Grants & Contracts Financial Administration
Large Purchases
• > $150,000
• Competitive Proposals
• RFP with Evaluation Methods
• Fixed Price or Cost Reimbursement
• Sealed bid
• Construction Projects
• Price is a major factor
OSU Grants & Contracts Financial Administration
Sole Source
• What are institutional rules?
• Unique?
• Public Emergency, or
• Authorized by Funding Agency?
OSU Grants & Contracts Financial Administration
Construction Purchases with Grant Funds
• > $2,000 must be bid
• Follow Davis-Bacon
OSU Grants & Contracts Financial Administration
Things to Watch
• Split purchases
• Reallocation of Costs (from Institutional account to Grant Account)
• Documentation after-the-fact
• Charges to cost-share accounts
OSU Grants & Contracts Financial Administration
Conflict of Interest (CFR 200.318)
• Written Standards of Conduct
• Precludes participation if “Real or Apparent” conflict of interest.
• Familial relationships
• Financial relationships
• Tangible Benefits
• Avoiding solicitation of gifts, favors, or gratuities
• Provides for Disciplinary action in cases of violation.
OSU Grants & Contracts Financial Administration
Performance and Financial
Monitoring and Reporting
2 CFR 200.327-329
OSU Grants & Contracts Financial Administration
Timing of Financial Reports
• Federal agencies may request financial data specifically limited to the
OMB-approved, Government-wide data elements
• At least annually
• No more than quarterly, except
• Unusual circumstances may require more frequent reporting
• Requiring closer monitoring
• Specifically to improve program outcomes, or
• To coordinate performance reporting
OSU Grants & Contracts Financial Administration
Program Performance
• Non-federal entities are responsible for monitoring program
performance (including pass-through/subcontractors/sub-recipients)
• Assuring compliance with Federal requirements
• Performance expectations are fulfilled
• How do you monitor this now?
• How will you monitor it in the future?
OSU Grants & Contracts Financial Administration
Progress Reports
• Performance reports are Progress Reports
• Provided by Principal Investigator
• Must be submitted/formatted in accordance with OMB and Agency requirements
• Compares accomplishments to stated objectives.
• If applicable—why goals were not met.
• Explanations of Cost-overruns, significant developments or problems
• Actions taken to correct
• Filed at least annually (within 90 days of reporting period)
• no more than quarterly (or more frequently in usual circumstances (within 30 days of
reporting period.
• Before the anniversary date of a multi-year program, and
• Within 90 days after the program’s end date (extension of the due date is at the discretion of
the awarding agency.
• Remember – government wide data elements must be included in reports
OSU Grants & Contracts Financial Administration
Construction Performance Grants
• In addition
• The non Federal Entity must also provide:
• Onsite technical inspections
• Certified percentage of Completion data
• Information on significant developments
OSU Grants & Contracts Financial Administration
Federal Agency Prerogatives
• Site Visits
• Waive any performance reporting
OSU Grants & Contracts Financial Administration
Reporting on Real Property
• If the non federal entity is responsible for real property in which the
Federal Government retains an interest:
• An annual status report is required (if the interest is less than 15 years)
• If 15 years or greater and the Federal Agency agrees• the status report may be in multi-year increments not greater than 5 years in length.
• Or Annually for the first 3 years of the award and 5 years thereafter
OSU Grants & Contracts Financial Administration
Record Retention and Access (2 CFR 200.333)
• Records must be available for at least three years
• Following the date of submission of the final report, or
• The time required for any litigation, claim, or audit---up until final resolution—started prior
to the end of the three year period from the date of the final report, OR
• When the non-federal entity is notified in writing by the federal agency to extend the
retention period.
• Program Income Accounts
• Retains records for 3 years from the end of the fiscal year in which program income was
earned
• Real Property/Equipment
• Retains records for 3 years after the final disposition of the asset.
• IDC Proposals
• 3 years from the date of submission for negotiation
• If not submitted for negotiation, 3 years from the end of the fiscal year covered by the
proposal
OSU Grants & Contracts Financial Administration
CASH MANAGEMENT
2 CFR 200.305
OSU Grants & Contracts Financial Administration
Written Cash Management 2 CFR 200.305
• Written procedures must describe whether non-federal entity uses:
• Advance Payments (preferred)
• Limited to minimum amounts needed to meet immediate cash needs
• Reimbursement
• Pass through must make payment within 30 calendar days after receipt of the billing
• Working Capital Advance
• The pass through determines that the nonfederal entity lacks sufficient working capital.
Allows advance payment to cover estimated disbursement needs for initial period
OSU Grants & Contracts Financial Administration
Written Cash Management 2 CFR 200.305
Continued
• Advances must be maintained in insured accounts
• Pass-through cannot require separate depository accounts
• Accounts must be interest bearing unless:
• Aggregate federal awards under $120K
• Account no expected to earn in excess of $500 per year
• Bank require minimum balance so high account would not be feasible
OSU Grants & Contracts Financial Administration
Written Cash Management 2 CFR 200.305
Continued
NEW
Interest amounts up to $500 per year may be retained
Increases amount by $400 for State and local Gov’ts
Increases amount by $250 for IHE’s and Non-profits
SAME with exception of $500 administrative increase
Interest earned above $500 must be remitted annually to HHS
OSU Grants & Contracts Financial Administration
CASH MANAGEMENT
• Related to Financial Statements
• Entities on a cash basis vs. accrual
• Payment for expenses with state funds until the federal award arrives
• All addressed in the FAQ’s found here:
• https://cfo.gov/wp-content/uploads/2014/11/2014-11-26-Frequently-AskedQuestions.pdf
OSU Grants & Contracts Financial Administration
NEW CERTIFICATION 2 CFR 200.415
• Official authorized to legally bind the non-federal entity
• must certify on annual and final fiscal reports or
• vouchers requesting payment
• “By signing this report, I certify to the best of my knowledge and belief that
the report is true, complete and accurate and the expenditures,
disbursements and cash receipts are for the purposes and objectives set forth
in the terms and conditions of the federal award. I am aware that any false,
fictitious, or fraudulent information or the omission of any material fact, may
subject me to criminal civil or administrative penalties for fraud, false
statements, false claims, or otherwise.”
OSU Grants & Contracts Financial Administration
200.201(b)(3) (New) Certification of completion at
end of fixed price award or subaward
• The non-Federal entity must certify in writing to the Federal awarding
agency or pass-through entity at the end of the Federal award that
the project or activity was completed or the level of effort was
expended. If the required level of activity or effort was not carried
out, the amount of the Federal award must be adjusted.
• Consistent with section 200.308(c)(3), a reduction of more than 25% of the
level of effort must be reported to the Federal awarding agency and would
require an adjustment.
• Adjustments would be necessary if the work wasn’t completed or actual costs
are significantly lower than budgeted
OSU Grants & Contracts Financial Administration