Uniform Guidance

Uniform Guidance

Uniform Guidance

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 an entity 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.

Procurement Thresholds
$0.01-$3,339.99 One quote 
$3,440.00 - $9,999.99 Micro Purchases - quotes or state exception - determind by OC&P
$10,000 - $34,439.99 Small Purchases / Simplified Aquisition Threshold - see guidelines
$34,440.00 (+) Large Purchase - see guidelines
$150,000 (+) Special Considerations (outlined below) *Increases to $250,000 on Nov 12
Compliance Thresholds (in aggregate over fiscal year)
$5,140.00 (+) NJ Business Registration Certificate
$17,500.00 (+) Eo117 / Ch51
$25,000.00 (+) SAM (Suspension Debarment)

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.

Special Considerations for Federal Award Purchases $150,000(+) *Increases to $250,000 on November 12th. 

OC&P is responsible for conducting the Formal Bid process for all single purchases $34,440 and greater, including federal award purchases; however, if your purchase potentially exceeds $150,000 (Increases to $250,000 on November 12th) there are additional requirements.

Option 1: Preprocurement 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 $150,000(+) (Increases to $250,000 on November 12th), 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 $150,000 (Increases to $250,000 on November 12th) and greater 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.

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

Required Forms for All Procurements

 Approval Portals 

Grant Small Purchase Approval Portal Grant Large Purchase Approval Portal

 * Large Purchase portal is for procurements over $150,000

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 UniverOC&P's redefined policies and procedures, and by following the insructionns 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.