Uniform Guidance & Grant Procurement

Uniform Guidance & Grant Procurement

Uniform Guidance & Grant Procurement 

Uniform Guidance (UG), is the set of rules and regulations that governs the administration of federally funded projects during its lifespan. The bulk of Uniform Guidance came into effect on December 26, 2014, but much of the guidelines that impact University Procurement Services were delayed. As a result, Rowan became compliant with UG standards by July 1, 2018, a requirement in order to remain eligible to receive federal funds.

Uniform Guidance guidelines is meant to combine, update, and supersede the OMB Circulars and federal guidelines, including A-21, A-110, and A-133. The standards are laid out in sections 200.317-200.326 of the CFR Title 2, Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. All expenditures utilizing federal award funds are allowable in accordance with 45 CFR Part 75 (Uniform Administrative Requirements, Cost Principles and Audit Requirements for HHS Awards).

Procedures & Thresholds

Because Rowan is a body corporate and politic of the State, we are required to include New Jersey Procurement regulations, as well as our internal requirements while complying with UG. The Office of Contracting & Procurement (OC&P) has implemented University Procurement policies and procedures to align with UG, and has created checklists based on purchase amount to assist units with UG compliance and University requirements.

Non-Public Works Thresholds

< $19,999.99 Three quotes are encouraged, but not required.
$20,000.00 - $99,999.99 Small Purchase / Simplified Acquisition Threshold - see guidelines
> $100,000.00 Large Purchase - see guidelines
> $250,000 Special Considerations (outlined below)

Prevailing Wage (Public Works) Thresholds

< $7,879.99 Three quotes are encouraged, but not required.
$7,880.00 - $39,399.99 Three quotes are required, unless an exception applies.
>$39,400.00 Public bid is required

For additional procurement and compliance requirements, please visit the general procurement page here.

Pre-Procurement for All Purchases:

  • Whenever possible Rowan University must take all necessary affirmative steps to assure that minority businesses, women’s business enterprises and labor surplus area firms are used. For a list of vetted suppliers, please contact supplierdiversity@rowan.edu.
  • Federal Excess & Surplus the OC&P encourages the use of Federal excess and surplus property in lieu of purchasing new equipment and property whenever such use is feasible and reduces project costs. (Account Code 7645)

Special Considerations for Federal Award Purchases $250,000 (+) 

OC&P is responsible for conducting the Formal Bid process for all single purchases over the current bid threshold and greater, including federal award purchases; however, if your purchase potentially exceeds $250,000 there are additional requirements.

Option 1: Pre-procurement and Independent Price Analysis: (quotes from three or more vendors) or cost analysis (instructions below) prior to bid solicitation for federal awards resulting in purchases $250,000 (+), to comply with one of the UG requirements. The estimate should be attached to the requisition as an internal attachment.

Option 2: Cost Analysis: 

A cost analysis should be done if an independent price analysis cannot be done. UG requires that for federal awards $250,000 (+) with no price competition, e.g., sole source, emergency, you will not need to obtain an independent price analysis, but you will be required to perform a cost analysis with profit evaluation. The analysis should be uploaded into the portal as an internal attachment.

To assist the units with this requirement, OC&P has created a template and accompanying instruction:

Tracking Deliverables: 

After the purchase, you are responsible for ensuring that the goods, services, deliverables, and supplier payments are consistent with the requirements set forth in the related contract or purchase order. You are not required to submit tracking information to OC&P. 

To assist the units with this requirement, we have created a template and accompanying instruction:

Required Forms for Grantee (PI)

Approval Portal

Grant Purchase Approval Portal

For a complete list of frequently asked questions, please view UG FAQs.

Where Can I find the Uniform Guidance Policies (UG)?

The UG policies can be found at the Electronic Code of Federal Regulations.

How do I ensure UG compliance?

The Rowan community can help ensure compliance to UG by adhering to OC&P's redefined policies and procedures, and by following the instructions and templates outlined above.

What happens if my funding was issued prior to July 1, 2018?

As of July 1, 2018 all federally funded awards will follow UG regardless of the date of issue.

Do the redefined procurement standard guidelines apply to federally and non-federally funded sources?

No, the standards only apply to federally funded sources.  

What are the repercussions of non-compliance?

Rowan will be audited and could potentially have any federal awards reduced or suspended.