Key Points on Federal Grant Funding Procurement Compliance
Understand the importance of adhering to Federal Uniform Guidance (UG) when procuring goods or services with federal grant funding. Learn about subrecipient-contractor distinctions, consequences of noncompliance, top 10 UG procurement standards, and conflicts of interest policies for handling federal grants.
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Presentation Transcript
Uniform Guidance Procurement of Goods or Services with Federal Grant Funding Slide 1
When purchasing goods or services, especially with federal funds, the purchase is subject to the Federal Uniform Guidance (UG) and University procurement procedures. Slide 2
Subrecipient-Contractor Determination A procurement is used to purchase goods or services for the benefit of an award. A subaward/subcontract/subagreement is used when FSU passes through a portion of an award (received by FSU) to a third party entity who becomes responsible for the programmatic effort of conducting a portion of the project. The federal rules related to a procurement and a subaward differ greatly. Slide 3
Why Is This Important? Noncompliance with state and federal requirements has serious consequences. Slide 4
Contracts funded with federal grant funds must be procured in a manner that conforms with all applicable Federal laws, policies, and standards. Slide 6
General UG Procurement Standards Slide 7
General UG Procurement Standards Slide 8
UG Conflicts of Interest Policy As part of the OMB s Uniform Guidance, there are new requirements for conflicts of interest and how the University must handle them. The regulation states: 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. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. Slide 9
General UG Procurement Standards Slide 10
General UG Procurement Standards Slide 11
General UG Procurement Standards Slide 12
Contract Provisions Slide 13
UG Contract Provisions: Contracts must contain certain boilerplate provisions Must have provisions in writing in some form Requirements vary depending on cost of the contract Can include in standard T&Cs Can include in bid specs for suppliers to certify contract when submitting bids Slide 14
Contract Provisions Cont. Others: 1. Changes and modifications to contract 2. Access to records 3. Compliance with federal law, regulations, and executive orders 4. Federal government hold-harmless 5. Fraud and False Statements Slide 15
UG Requires Contract Provisions On: 1. Remedies for breach 2. Termination for cause and convenience 3. EEO 4. Bacon-Davis wage requirements 5. Work Hours and Safety Standards Slide 16
UG Requires Contract Provisions On: 6. Clean Air Act and Federal Water Pollution Control Act 7. Debarment and Suspension 8. Byrd Anti-Lobbying 9. Recovered Materials 10. Rights to Inventions Made Under a Contract or Agreement Slide 17
This is where we need your help Procurement will need to work closely with General Counsel when procurements are federally funded to ensure required clauses are applied to contracts. Slide 18
Contract Provisions listed in Appendix II to Part 200 2CFR Procurement Standards Or https://www.ecfr.gov/cgi-bin/ECFR?page=browse Slide 19
Questions? Slide 20
