In 2014, the Office of Management and Budget (OMB) combined several federal circulars outlining rules and requirements for Federal awards into a single guiding document referred to as Uniform Guidance (2 CFR 200). The purpose of the UG was to update and streamline regulations in order to reduce administrative budget on award recipients and to guard against waste and misuse of Federal funds. The new regulations became effective December 26, 2014, except for changes to purchasing regulations which became effective July 1, 2018.

Procurement guidance now in effect is found in sections 200.317 – 326 of the Uniform Guidance and focuses on increased competition and transparency in the procurement process. More specifically, purchasing compliance in UG focuses on the main areas outlined below. Detailed under each is CSU-specific guidance and impact given the new requirements.

1. Micro-purchase Threshold

No changes for CSU for purchasing goods under $10,000. Purchases up to $10,000 occur via Automatic Purchase Order (APO). See CSU Procurement guidance on methods of procurement by funding source for various purchasing thresholds.

2. Sole Source Procurement

UG limited the use of sole source to four justifications:

• Product/service is only available from a single source;
• Public emergency procurement;
• Federal Awarding Agency Authorization; and
• Inadequate competition after multiple attempted solicitations.

The greatest impact to the CSU grant community is that “continuity of research” is no longer a valid justification for sole source. Instead, every sole source will require a price/cost justification. If you are uncertain as to what constitutes a sole source, consult the CSU Procurement FAQs on requesting a sole source.

3.Consulting Services

Naming and including information on a consultant in a grant proposal is no longer sufficient justification for a sole source under the UG.  Requests for consulting services, based on a sole source justification, will result in a more thorough screening of these services. 

The good news is existing consulting agreements under existing awards do not have to be re-sole sourced. New regulations apply to new consultants and new awards and competitive renewals as of July 1, 2018.

4.Conflict of Interest

There are new requirements for conflicts of interest within a procurement action and how institutions must handle them.  As such, sole source justifications may require statements assuring no financial relationship exists with potential vendors.

Before you buy, review information on Procurement Services’ website and contact Procurement staff early in the process to avoid delays in purchasing.