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Focus on Public Sector, Not-For-Profit and Colleges & Universities: Extension of Grace Period for Uniform Guidance Procurement Rules

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On May 17, 2017, the Office of Management and Budget (OMB) published a notice in the Federal Register which provides an additional one-year extension of the grace period permitting recipients of federal funds to delay implementation of the procurement requirements found in the OMB’s Uniform Guidance.
May 17, 2017

On May 17, 2017, the Office of Management and Budget (OMB) published a notice in the Federal Register which provides an additional one-year extension of the grace period permitting recipients of federal funds to delay implementation of the procurement requirements found in the OMB’s Uniform Guidance.

Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), became effective for federal agencies and recipients of federal awards on December 26, 2014.  The Uniform Guidance sets forth the requirements that recipients of federal funds must adhere to when administering and spending these funds.  Paragraphs 200.317 through 200.326 of the Uniform Guidance address the procurement standards that recipients of federal funds must follow.

Since these new procurement standards may represent a significant departure from the procurement standards previously followed by recipients of federal funds, the OMB previously had granted a 2-year grace period before implementation of the procurement standards was required to allow entities time to plan for the implementation of the new standards.  With the additional extension established by the OMB on May 17th, that grace period is now 3 years.

Recipients of federal funds will now be required to follow the new procurement standards in the Uniform Guidance starting with fiscal years beginning on or after December 26, 2017.  For entities with December 31 fiscal year ends, this means the new standards will be effective for fiscal years ending December 31, 2018; for June 30 fiscal year ends, the new standards will be effective for fiscal years ending June 30, 2019.

If a non-federal recipient of federal funds wishes to take advantage of this grace period, the entity must document this decision in its internal procurement policies.  During the grace period, the entity should continue to comply with the procurement standards in OMB guidance predating the Uniform Guidance.

The Federal Register notice may be found here.

 

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