This series highlights important standards in federal grant management. Grantees should expect that compliance requirements may vary across federal agencies, and we encourage every organization to consult their notice of award along with the program’s specific award conditions, notice of funding opportunity, and the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), codified at 2 C.F.R. Part 200. Grantees should secure appropriate legal counsel, accounting assistance and any other professional services in making grant management decisions and implementing appropriate policies.

Written Procurement Policy

In general, recipients of federal grants must have written procedures for procurement transactions (2 C.F.R. §§ 200.318(a) and 200.319(d)). Grantees must follow their written procurement policy in all of their federally funded transactions.

• Set thresholds for micropurchases (generally $10,000) and a simplified acquisition threshold (generally $250,000)
• Describe the compatible process used at each threshold level (with higher value tiers using more formal competitive mechanisms)
• Address conflicts of interest or cross-reference conflict of interest policies established elsewhere
• Require certain contract terms as applicable (see 2 CFR Part 200, Appendix II)

For questions concerning our Grants Practice Shorts series, please contact Phillip A. Escoriaza, Senior Counsel, at 202.466.8960 or pescoriaza@feldesman.com.