Time is up! Written procurement procedures that comply with Uniform Guidance must be implemented for 2018 single audits

By Alisha Shaw, Program Manager – Team Pullman

Estimated reading time: 2 minutes

As communicated during audits and conferences in the past three years, local governments must fully comply with the Uniform Guidance general procurement standards found in 2 CFR 200.318 by the following dates:

• January 1, 2018 for entities using a December 31 fiscal year-end
• July 1, 2018 for entities using a June 30 fiscal year-end
• September 1, 2018 for entities using an August 31 fiscal year-end

Failing to comply with these standards may result in a higher level of reporting during the 2018 single audits.

These standards require local governments to use their own documented (written) procurement procedures, which reflect applicable State, local, and tribal laws and regulations, provided that the procurements comply with applicable federal laws and standards.

The standards also require local governments to maintain written standards of conduct covering conflicts of interest and governing the actions of employees engaged in the selection, award and administration of contracts.

The requirement for procurement and standards of conduct procedures is not new and was previously addressed in the Office of Management and Budget (OMB) Circular A-102 and Circular A-110. However, the Uniform Guidance explicitly required documented procedures by updating the requirement for procedures from “will” to “must” and adding the word “documented.”

OMB allowed for a grace period of three full fiscal years after the effective date of Uniform Guidance (December 26, 2014) for local governments to bring its procurement and standards of conduct procedures into compliance with Uniform Guidance procurement standards. This grace period allowed local governments to use their current procedures until changes could be implemented, as long as the entities documented which standards they were following.

The 2019 OMB Compliance Supplement states: “Auditors will review procurement policies and procedures based on the documented standard. Once the grace period ends, all [local governments] will be required to comply fully with the procurement standards in the uniform guidance.” To test compliance, auditors must obtain the entities' procurement and standards of conduct policies and procedures effective for the period under audit and verify they comply with general procurement standards.

If you have any questions about compliance with single audit requirements, please submit a HelpDesk request at SAO Online Services.

Resources

General Procurement Standards – Title 2 U.S. Code of Federal Regulations Part 200, Section 318

2019 Compliance Supplement – Part 3 – Compliance requirements (3.2–I, Procurement); Part 6 – Internal Control

Procurement Policy Guidelines – Municipal Research and Services Center (MRSC)