Step 2: Following Procurement Regulations
On December 26, 2014, the Office of Management and Budget's Uniform Administrative Requirements, Cost Principles, and Audit Requirement's for Federal Awards (2 CFR Part 200) became effective for new or continuation awards issued on or after December 26, 2014. The new regulations still provide States flexibility with procurement standards but have become more restrictive for all other non-Federal entities. According to 2CFR Part 200.69, a "non-Federal entity means a state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organizations that carries out a Federal award as a recipient or subrecipient." The procurement regulations' goal is for non-Federal entities to design a procurement blueprint that encourages multiple vendors to bid in open, equal, and fair competition for contractual grant services.
2 CFR Part 200.318(a) states that the "non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided the procurements conform to applicable Federal law and the standards identified in [2 CFR Part 200.318]." In addition to establishing documented procurement procedures, 2 CFR Part 200.318(c)(1) further states that the "non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest." If the non-Federal entity discovers a conflict of interest, 2 CFR Part 200.112 requires that this information is disclosed to the Federal awarding agency or pass-through entity. The grantee is required to provide equal treatment to all vendors and will usually select the most qualified and experienced vendor at the best price. Detailed procurement procedures are outlined in 2 CFR Part 200.320.
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