Sneak Preview: Emphasis on Procurement Accountability Greater Now

June 18, 2015 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) The procurement of goods and services with federal funds is a major challenge for recipients and a growing concern for auditors, as grant recipients struggle to strengthen not only their procurement policies under the uniform guidance, but also related policies governing conflicts of interest and mandatory disclosures to address the growing emphasis on accountability.

During its spring forum in Washington, D.C., a partner with the Washington, D.C., law firm of Brustein and Manasevit, PLLC, explained what the uniform grant guidance means for recipients’ procurement practices and identified sections in the guidance where the new language deviates from the Office of Management and Budget’s (OMB’s) prior circulars to impose a higher degree of accountability.

The full implementation of the OMB’s uniform grant guidance at the end of last year heightened the accountability requirements associated with procurement, especially for those provisions that deviated from the prior OMB circulars. This is particularly important for nonfederal entities who previously followed OMB Circular A-110. As a result, Tiffany Winters, Esq., a partner with Brustein and Manasevit, advised federal funding recipients to update their written procurement policies and develop an internal control system that both “prevents good people from doing bad things,” and detects intentional wrongdoing before it develops into a long-term pattern.

Procurement “is a really great area to focus on because it’s the number one area where we see fraud, waste and abuse,” Winters said during her firm’s spring forum.

The uniform guidance consolidated eight prior OMB grant circulars into one set of provisions to reduce administrative burden and to reduce waste, fraud and abuse. In doing so, the uniform guidance seeks to increase accountability and performance. According to Winters, the overarching objective of strengthening accountability is evident in its procurement standards (§§200.317-.326). The procurement provisions under the uniform guidance more closely follow the requirements from prior OMB Circular A-102, which applied to state, local and tribal governments. This means that institutions of higher education, nonprofits and hospitals that previously followed the less-stringent requirements in prior OMB Circular A-110 now are subject to a more-restrictive set of procurement rules, Winters said.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site).


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