Guidance Uniform Procurement Leadership Council New

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Guidance Uniform Procurement Leadership Council New

Central Christian College of the Bible, US has reference to this Academic Journal, Procurement Leadership Council New Uniform Guidance Update & Discussion 9/2/14Presented By: Jacob GodfreyUCSB Chief Procurement Officer in addition to Materiel ManagerUniform Guidance Uniform Administrative Requirements, Cost Principles, in addition to Audit Requirements in consideration of Federal Awards supersedes in addition to streamlines the following eight existing OMB Circulars:A-21 Cost Principles in consideration of Educational InstitutionsA-87 Cost Principles in consideration of State, Local in addition to Indian Tribal GovernmentsA-122 Cost Principles in consideration of Non-Profit OrganizationsA-110 Uniform Administrative Requirements in consideration of Grants in addition to Other Agreements alongside Institutions of Higher Education, Hospitals in addition to Other Non-Profit OrganizationsA-102 Grants in addition to Cooperative Agreements With State in addition to Local GovernmentsA-133 Audits of States, Local Governments in addition to Non-Profit OrganizationsA-50 Audit Follow-upA-89 Catalog of Federal Domestic AssistanceThis is a major reform of how the federal government provides assistance awards (e.g., grants in addition to cooperative agreements) alongside the goal of increasing accountability in addition to transparency while reducing the administrative burden on non-federal entities receiving federal awards.Effective DateWhen does the Uniform Guidance become effective?? Federal agencies must implement the requirements so that be effective by December 26, 2014.? Administrative requirements in addition to cost principles will apply so that new awards in addition to so that funding increments, in cases where the Federal agency considers funding increments so that be an opportunity so that modify the terms in addition to conditions of the Federal award, so that existing awards made on or after Dec 26, 2014.? Existing Federal awards that do not receive incremental funding alongside new terms in addition to conditions will continue so that be governed by the terms in addition to conditions of the Federal award

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Effective Date in addition to ProcurementThe Federal government will provide a grace period of one full fiscal year after the effective date of the Uniform Guidance (December 26, 2014 ) in consideration of non-Federal entities so that comply alongside the procurement standards in the Uniform Guidance.However, in light of the new procurement standards, in consideration of procurement policies in addition to procedures the non-Federal entity must document whether it is in compliance alongside the old or new standard, in addition to must meet the documented standard.For example, the first full fiscal year in consideration of a non-Federal entity alongside a June 30th year end would be the year ending June 30, 2016. The Single Audit Compliance Supplement will instruct auditors so that review procurement policies in addition to procedures based on the documented standard. For future fiscal years, all non-Federal entities will be required so that comply fully alongside the uniform guidance Impact on Strategic Sourcing200.318 (d) & (e)Explicitly encourages non-federal entities so that build into their procurement policies practices that consolidate procurements where appropriate so that make efficient use of Federal funds.Procurement Claw (Sections200.320 & 200.317-326)

Impact on FARS/DFARS Fundamentally unchanged in consideration of acquisition of commercial items under federal contacts alongside FARS flow down provisionsUG = Grants FARS = ContractsMicro vs. Small vs. Over ThresholdConflict of Interest200.112 The federal awarding agency must establish conflict of interest policies in consideration of Federal awards 200.318 The non-Federal entity must also maintain written standards of conduct covering organizational conflicts of interests

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200.90 State Definition – Warning200.90 State means any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, in addition to any agency or instrumentality thereof exclusive of local governments.This issue is being examined by UC OGC ? impact TBD Subrecipient in addition to Contractor Determination 200.330, 200.22, & 200.92 It is the substance of the award that determines how it should be treated, even if the pass-through entity or non-Federal entity receiving the award may call it by a different name.Action ItemsUC Location so that document compliance under old or new standards in consideration of the period 7/1/15 -6/30/16Consider ?adequate # quotes? in addition to ?method of solicitation? policyConsider policy on Conflict of InterestConsider forming workgroup so that develop standard policy/procedures/wf

Additional ResourcesUCOP: ucop /research-policy-analysis-coordination/research-sponsors-agreements/federal-government/uniform-guidance/index.htmlUCSB: bfs.ucsb /omb/omb-uniform-guidance

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