The Uniform Guidance (2 CFR 200) has been in effect since December 26, 2014. Recently, the procurement portion of Uniform Guidance went into effect July 1, 2018, 2 CFR 200.318, 200.320, and 200.88.
What is Uniform Guidance?
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards collectively known as "Uniform Guidance" (2 CFR 200) are the federal regulations governing the administration of federal funds by non-federal entities.
Proposals with planned purchases between $10,000 and $25,000 using federal funds need to be mindful of the Uniform Guidance. The only exception to this is purchases made on Duck Depot. Departments may use Duck Depot for any amount because the suppliers have already been through a competitive process that meets the new federal requirements.
Proposals for federal funding with one or more Consultants and/or Vendors specifically named in the proposal, if funded, and the purchase will be over $10,000 but under $25,000 need to be mindful of the information below.
- At the proposal stage, where Consultants and/or Vendors are named in the proposal (in the proposal budget, budget justification, or elsewhere in the proposal), UO PIs and departments are strongly encouraged to collect and submit to their Pre-Award Sponsored Projects Administrator, three quotes for purchases over $10,000 and less than $25,000 unless those planned purchases will be made via Duck Depot, or an exemption from competition (see below) applies. See the link below for more information:
Purchasing and Contracting Services - Uniform Guidance: https://pcs.uoregon.edu/uniform-guidance
Please note that by naming the proposed Consultant(s) and/or Vendor(s) in the proposal alone is not sufficient justification for processing a procurement contract through Purchasing and Contracting Services.*
- At the proposal stage, PIs and UO departments will need to be mindful that if the proposal is funded, when conducting RFPs, APs, or a sole source, purchases valued over $10,000, UO will develop a cost and price analysis as part of award review.
- At the Award stage, exemptions from competition will be granted only under the following circumstances:
- The granting federal agency has expressly waived a competitive procurement requirement
- The goods or services to be purchased are from a true sole source
- There is an emergency giving rise to the need for the purchase
- UO has conducted a procurement and only received one, or no responses
- At the Award stage, for each purchase over $10,000 made with federal funds, the UO will record the following:
- Rationale for the method of procurement;
- Rationale for the type of contract used;
- Basis for contractor selection or rejection;
- Basis for the contract price for each transaction funded by a federal grant.
Proposals for federal funding with one or more Consultants and/or Vendors not specifically known or named (TBA, or TBD) in the proposal, if the proposal is awarded, and the purchase will be over $10,000 but under $25,000, need to be mindful the competitive procurement process (three quotes as outlined above) or an approved exemption as outlined above will apply to the award as outlined above.
Purchases over $25,000 must still follow standard UO procurement processes.*
*Purchasing and Contracting Services (PCS) is the UO office for final review, processing, and signature approval of procurement contracts subject to the uniform guidance and UO PCS guidance as noted above.