University of Minnesota
Uniform Guidance Recommendation
Primary Work Group: Uniform Guidance Implementation Group
Secondary Work Group: Property Work Group – Capital Equipment
Subpart D Post Federal Award Requirements 200.320 Methods of Procurement To Be
Followed (regarding fabrication of capital equipment)
Contact(s):
Creation
Date
Name: (Required)
07/16/2014 Jay Delaney
Kieran Dhital
Amy Hagen
Kamala Upadhyaya
Sarah Waldemar
Angela Zellmer
Phone #
Comments
X4-7265
X5-5514
X4-0754
X4-2014
X4-8349
X6-3580
Approved By:
Approval
Date
Name: (Required)
Phone #
Signature
Uniform Guidance states:
The non-Federal entity must use one of the following methods of procurement.
(a) Procurement by micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services,
the aggregate dollar amount of which does not exceed $3,000 (or $2,000 in the case of acquisitions for
construction subject to the Davis-Bacon Act). To the extent practicable, the non-Federal entity must distribute
micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting
competitive quotations if the non-Federal entity considers the price to be reasonable.
(b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and
informal procurement methods for securing services, supplies, or other property that do not cost more than the
Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be
obtained from an adequate number of qualified sources.
(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited and a firm fixed price contract
(lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms
and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for
procuring construction …
(d) Procurement by competitive proposals. The technique of competitive proposals is normally conducted with
more than one source submitting an offer, and either a fixed price or cost reimbursement type contract is
awarded. It is generally used when conditions are not appropriate for the use of sealed bids. …
(e) [Reserved]
(f) Procurement by noncompetitive proposals. Procurement by noncompetitive proposals is procurement through
solicitation of a proposal from only one source and may be used only when one or more of the following
circumstances apply:
(1) The item is available only from a single source;
University of Minnesota
Uniform Guidance Recommendation
Primary Work Group: Uniform Guidance Implementation Group
Secondary Work Group: Property Work Group – Capital Equipment
Subpart D Post Federal Award Requirements 200.320 Methods of Procurement To Be
Followed (regarding fabrication of capital equipment)
(2) The public exigency or emergency for the requirement will not permit a delay resulting from competitive
solicitation;
(3) The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in
response to a written request from the non-Federal entity; or
(4) After solicitation of a number of sources, competition is determined inadequate
Cross Reference:
A-110, C.44
Open Item:
Yes
Assessment & Next Steps:
Institutions must use one of the five procurement methods as listed in this section (note: (a) thru (f) are listed, (e)
has been excluded as an apparent typo error). These five methods are much more detailed and prescriptive in
comparison to the requirements in A-110.
Method (a) specifies the category of micropurchase (defined in Subpart A Definitions, 200.67) for grants and
cooperative agreements. Per 200.67, this method allows the non-Federal entity to use a “subset of a non-Federal
entity’s small purchase procedures … in order to expedite the completion of its lowest dollar small purchase
transactions and minimize the associated administrative burden and cost.” The category of micro-purchase is
common to the Federal Acquisition Regulation (FAR), and per 200.67, the “threshold is set by the Federal
Acquisition Regulation at 48 CFR Subpart 2.1 (Definitions).”
Method (b) specifies the category of “small purchases” that do not exceed the Simplified Acquisition Threshold
(as defined in Subpart A Definitions, 200.88). Per the definition in 200.88, “the non-Federal entity may purchase
property or services using small purchase methods … to expedite the purchase of items costing less than the
simplified acquisition threshold … set by the [FAR] at 48 CFR Subpart 2.1 (Definitions) and in accordance with 41
U.S.C. 1908. As of the publication of this Part, the simplified acquisition threshold is $150,000, but this threshold
is periodically adjusted for inflation.”
Methods (c) and (d) include detailed requirements associated with sealed bids (c) and competitive proposals (d).
Method (f) specifies the requirements for a sole source procurement and the circumstances (at least one of four)
that should be applicable in order to use the sole source method.
COGR is seeking clarification on expectations of the appropriate documentation and institutional practices that will
support the use of methods (a), (b), and/or (f). This includes clarification on documentation to support “small
purchases” ($3,001 to $150,000) per (b) and documentation to justify the use of “sole source” per (f). COGR, in
partnership with the FDP, may accumulate data to show the difference in the timeliness of procurement actions
between sole source versus other methods of procurement, and the resulting impact on research productivity. As
appropriate, we will share this data with federal officials.
COGR will review Agency implementation plans and comment, as appropriate. Upon implementation, COGR will
recommend that institutions document impact on procurement card policies, the increases in time/burden to
complete a procurement action, and any impact on research productivity.
University of Minnesota
Uniform Guidance Recommendation
Primary Work Group: Uniform Guidance Implementation Group
Secondary Work Group: Property Work Group – Capital Equipment
Subpart D Post Federal Award Requirements 200.320 Methods of Procurement To Be
Followed (regarding fabrication of capital equipment)
Specification
Background Existing
Regulation and
how we handle it
now (Citation and
brief description of
process)
Consultation
Required - list
specific groups
Recommendation
and detail (if
applicable)
Any other
alternatives
considered or
other information
you care to
provide?
Is a workaround
necessary? Why?
Are there any
agency specific
deviations or
special
provisions?
Are there any
dependencies on
other
recommendations,
systems, etc.
The University’s procurement structure is setup to use U-wide Contracts, ISOs, UMarket, price comparison at $10K, bidding at $50K, and exception to bid. The Property
work group feels the U has procedures in place to cover most purchasing transactions
and any changes to the current procedure would be applied to all purchase, not just
purchases related to sponsored projects.
___
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_X_
_X_
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_X_
_X_
SRC (Senate Research Committee)
CRAD (Council of Research Associate Deans)
GMUNAC (Grants Management User Network Advisory Committee)
CAAC (Certified Approvers Advisory Committee)
RRC Managers
FSUN (Financial System Users Network)
Policy Owner
Others (name) Purchasing Services_____________________________________
Extensive education and form revisions.
If the Price Comparison level is lowered to $3000, is there potential for the University to
lower the dollar threshold for which bids are required and to what level?
University of Minnesota
Uniform Guidance Recommendation
Primary Work Group: Uniform Guidance Implementation Group
Secondary Work Group: Property Work Group – Capital Equipment
Subpart D Post Federal Award Requirements 200.320 Methods of Procurement To Be
Followed (regarding fabrication of capital equipment)
Priority – High
(need by 12/26/14),
Medium (need
within 6 months
after 12/26/14), Low
(institutional choice
to implement)
What is the
significance of the
change? High
(impacts the entire
University), Medium
(impacts <200
employees), Low
(impacts >200
employees)
Overall complexity
of change? Very
complex (all)
complex (all except
system), not
complex (any 2)
(Base on how many
components of
change are
necessary; system,
policy, procedure,
training)
Who is directly
impacted by the
change? What
audiences? (i.e. all
PIs with
equipment)?
What is the
frequency of the
impact? Does it
depend on
audience?
High.



Communication and announcements
Education requirements
Form revisions
High.
Very complex. Assessment of thresholds and approval requirements, including CA
approvals.
Requesters, Preparers, PIs, Approvers
Frequency of impact depends on the audience of researchers that fabricate capital
equipment. There is potential for impact on researchers who purchase more readily
constructed capital equipment should they add components to modify or enhance the
capabilities of the equipment.
University of Minnesota
Uniform Guidance Recommendation
Primary Work Group: Uniform Guidance Implementation Group
Secondary Work Group: Property Work Group – Capital Equipment
Subpart D Post Federal Award Requirements 200.320 Methods of Procurement To Be
Followed (regarding fabrication of capital equipment)
Are there out-ofpocket costs
anticipated for the
institution to
implement the
required change?
Potential of out-of-pocket expenses for:
 Communication
 Education / Training
 Updating Training Materials… i.e. Create Reqs manual.
 Form revisions
 Potential system changes… i.e. lower threshold in routing for CA approval.
Are there any open
issues?
Preferred timeline
recommendation –
prior to UG, by UG
implementation or
post UG
By UG implementation.
List of Policies & Changes
Administrative Policy
Title
Purchasing Goods &
Services
Using the University’s
Procurement Card
Policy Owner
Tim Bray
Tim Bray
Extent of Change – minimal, moderate, or major as well
as a brief description of the anticipated change(s)
Major change. Price comparison threshold lowered to
$3000 to $49,999
Minimal to Moderate… for capital (fabrication) equipment
components purchased on pcards due to vendor(s) not
accepting POs.
List of Procedures & Changes
Administrative
Procedure Title
Purchasing Goods &
Services
Is a new procedure
needed?
No, just edit the
procedure to reflect
the new threshold.
Extent of Change – minimal, moderate, or major as
well as a brief description of the anticipated change (s)
Major change. Price comparison threshold lowered to
$3000
University of Minnesota
Uniform Guidance Recommendation
Primary Work Group: Uniform Guidance Implementation Group
Secondary Work Group: Property Work Group – Capital Equipment
Subpart D Post Federal Award Requirements 200.320 Methods of Procurement To Be
Followed (regarding fabrication of capital equipment)
List of Policy-Related Documents and Changes
Appendix or FAQ
Price Comparison
Are new documents
needed?
No
Dept Request for Except No
To Brd of Regents Policy
Extent of Change – minimal, moderate, or major as well
as a brief description of the anticipated change(s)
Minimal. Edit the threshold for new Price Comparison
threshold.
Minimal. But more heavily used to document support for
sole sourcing.
List of Training Courses & Changes
Update the Create Requisitions manual in reference to Price Comparison levels.
System & Business Process Impacts
What systems are
impacted and what
changes are
proposed?
What interfaces are
impacted?
Are other business
processes impacted?
How?
Will business
processes be
impacted in such a
way that data will look
different?
Impacts to
UMReports?
EFS routing changes; increased volume of transactions to be reviewed by CAs.
Assumptions
Assumption
Expectation is that this would affect institutional wide non-sponsored and sponsored purchasing activity.
University of Minnesota
Uniform Guidance Recommendation
Primary Work Group: Uniform Guidance Implementation Group
Secondary Work Group: Property Work Group – Capital Equipment
Subpart D Post Federal Award Requirements 200.320 Methods of Procurement To Be
Followed (regarding fabrication of capital equipment)
Communication recommendation
Target Audience
Timeframe
Summary of Message
Requesters, Preparers, PIs,
Approvers
Issues Documentation
The following Issues were defined during Review/Design/Preparation.
Raised By
Issue
Date Needed
Resolution/Answer
Date
Team
Reviewers
Name
Date
Completed
Resolved By