Welcome to Feldesman’s Grants Practice Shorts series where we discuss helpful tips and strategies in common areas of federal grant management. Be sure to check out our other installments on our Grants Practice Shorts page.

Procurement File

Each federally funded procurement transaction should be thoroughly documented. Federal grant management regulations state, at 2 CFR 200.318(i), “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.”

As a practical matter, this means your best practice is for your file to include, at a minimum:

• Solicitation;
• Documentation of offers/quotes/bids received;
• Evidence you checked SAM.gov for suspension/debarment for transactions over the micro-purchase threshold (MPT);
• The resulting contract; and
• Evidence you evaluated the proposed price to be fair and reasonable.

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