We have all seen the the procurement bear claw poster that summarizes the five procurement methods and five overarching standards required for organizations purchasing goods and services with federal funds. Honestly I can't remember who originally came up with this brilliant visual!

And although the "paw" remains intact, OMB Uniform Guidance is getting an update that will impact how you handle procurement for federal grants as of October 1, 2024. Below are our highlights of the key changes and how they tie into the five approved Uniform Guidance procurement methods outlined in 2 CFR 200.320. 

Get Ready for Change!

Welcome Veteran-Owned Businesses (VOBs): ([OMB Uniform Guidance Section](relates to) 200.321)

Applies to: Primarily micro-purchases, small purchases, and potentially competitive proposals.

The Change:  The Guidance encourages including VOBs alongside established categories.

What it Means:  Expand your vendor pool for smaller procurements and potentially larger projects through competitive proposals.

Go Green with Executive Order No. 14057: ([OMB Uniform Guidance Section](relates to) New language incorporated throughout)

Applies to: All procurement methods (consideration throughout the process).

The Change:  The Guidance incorporates sustainability efforts.

What it Means:  Prioritize environmentally friendly options in all your procurement decisions, regardless of method.

Goodbye Threshold, Hello Flexibility for Subawards: ([OMB Uniform Guidance Section](relates to) 200.333)

Applies to: Primarily sealed bids and competitive proposals for subawards.

The Change:  The $250,000 simplified acquisition threshold for fixed-amount subawards is eliminated.

What it Means:  Recipients have more flexibility to set their own award-specific thresholds with agency approval for subawards, potentially impacting competition for sealed bids and proposals.

Streamlining Profit Negotiations (Maybe) & Considering Workforce Impacts: ([OMB Uniform Guidance Section](relates to) Public comment sought regarding potential changes to 2 CFR 200.324 & New language incorporated into 200.324)

Applies to: Primarily competitive proposals and potentially noncompetitive proposals.

The Change:  Potential removal of separate profit negotiation requirement and consideration of workforce impacts during procurement analysis.

What it Means:  The procurement process might be streamlined (depending on final decision), but consider potential workforce displacement when evaluating proposals.

Question about making a smooth transition? Join our peer-to-peer group to see how others are navigating these changes. Or, reach out to us to schedule a consultation!