Procurements Made Under Grants and Cooperative Agreements
Uniform Guidance contains prescriptive standards with which all Federal grant recipients are required to comply when acquiring property or services with Federal funds. These requirements, termed the “Procurement Standards,” are codified in 2 CFR 200.317 through 200.326 and their intent is to facilitate competition in the procurement process. The Office of Management and Budget (OMB) announced in the Federal Register on May 17, 2017, that the grace period for implementation of the Procurement Standards was to be extended one additional fiscal year for Federal grantees. This update extended the grace period through December 25, 2017 meaning all Federal grantees must have a compliant procurement system in operation for fiscal years beginning on or after December 26 as shown in the table below:
|2 CFR 200
|Fiscal Year End
Nonprofit organizations, institutions of higher education, and other Federal grantees that were formerly subject to OMB Circular A-110 will need to make significant changes to their procurement practices in order to remain compliant. In a number of ways, the new requirements are very similar to the procurement standards required of companies performing on contracts subject the Federal Acquisition Regulation (FAR). They are designed to ensure that all grantees meet very basic standards of integrity in the procurement processes, including the same basic elements of competition and transparency that apply to procurements by governmental entities.
Capital Edge Consulting is using its extensive expertise in Federal procurement compliance to support Federal grantees all over the county in achieving Procurement System compliance. Our industry experts will provide you with the necessary knowledge and tools needed to achieve and maintain compliance with the new Procurement Standards.
Indirect Cost Recovery for Grantees
Uniform Guidance introduced sweeping changes to administrative requirements, cost principles, and audit requirements for Federal awards to non-Federal entities. These changes brought new responsibilities and opportunities to non-Federal entities. Unfortunately, most publicly available guidance focuses primarily on helping non-Federal entities cope with the added responsibilities, leaving little consideration to the new opportunities that are now available. The most overlooked of these opportunities is the ability, but more importantly the right, to Indirect Cost Recovery.
Prior to Uniform Guidance the ability to apply for and be awarded a negotiate indirect cost rate agreement (NICRA) was heavily dependent on the Federal awarding agency. Since December of 2014, non-Federal entities have to option to submit an indirect cost rate proposal and negotiate a rate based on the prior years cost information. Organizations owe it to their mission and to their stakeholders to take full advantage of and recover every dollar of funding that is available. As budgets become tighter and meetings become more difficult due to reductions in funding, organizations may find relief by recovering more indirect costs on their Federal grants.
If your organization has never had a Federally negotiated indirect cost rate or if you have elected to use the “de minimis” rate, please provide us the opportunity to show you how much money you could be recovering for your organization. Capital Edge Consulting is actively working with Federal grantees all over the country to develop and negotiate Federal indirect cost rate agreements. Our industry experts will guide you through the calculation, proposal, and negotiation of indirect cost rates