1. WHOI Procurement Uniform Guidance 2018
December 2017
Navigating UG 2 CFR §

2. Introductions
WHOI Finance Dana Fernandez – Controller Laurie Murphy – Dir. Treasury Ops Michael Pinnetti – Manager AR & RC Matt Agnese - Manager Procurement

3. What is Uniform Guidance?
On December 26, 2013, the Office of Management and Budget (OMB) issued the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards," a/k/a the Uniform Guidance. Requirement for "procurement standards" compliance has been repeatedly postponed. New implementation date is January 1, 2018.
While Uniform Guidance was due to go into effect in 2014, a series of delays have created a holiday from compliance. 
WHOI is currently due to be compliant December 31, 2017

4. Procurement
Uniform Guidance requires that Institutions receiving government and non-government funding use consistent documented procurement processes when purchases are made using federal funds.
Consistent documented procurement process is mentioned throughout the rules. Our present operations manage the requisites for record keeping

5. § 200.320 Methods of procurement to be followed
The non-Federal entity must use one of the following methods of procurement.
Procurement by micro-purchases.
Procurement by small-purchase procedures.
Procurement by sealed bids (formal advertising).
Procurement by competitive proposals.
Procurement by noncompetitive proposals.
Micro - Purchase
~No cost or price analysis is required
~No solicitations or quotes are required
~Basic Review only
Small - Purchase
Quotes can be in writing, orally, from a website or found via online search engines.
We will need to document the analysis or sole source documentation.
Large/SAT - Purchase
Sealed Bids
Competitive proposals
Non Competitive / Sole Source

6. Methods of Procurement
Micro Purchases
Small Purchases
Simplified Acquisition Threshold Purchases
<$10,000
$10,000 - $149,999
> or = $150,000
Micro Purchases may be awarded without soliciting competitive quotations if the non- Federal entity considers the price to be reasonable.
If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.
Procurement by sealed bids (formal advertising)
Procurement by competitive proposals
Procurement by noncompetitive proposals
Micro
No cost or price analysis is required
No solicitations or quotes are required
Basic Review only
Small
Quotes can be in writing, orally, from a website or found via online search engines.
We will need to document the analysis or sole source documentation.
Large
Sealed Bids
Competitive proposals
Non Competitive / Sole Source

7. Simplified Acquisition Threshold Purchases
Current State
Micro Purchases
Small Purchases
Simplified Acquisition Threshold Purchases
<$10,000
$10,000 - $149,999
> or = $150,000
Micro Purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable.
If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.
Procurement by sealed bids (formal advertising)
Procurement by competitive proposals
Procurement by noncompetitive proposals
Current Status / Compliance with UG
Compliant
Non-Compliant

8. Procurement Suggestions
Early Engagement with WHOI Procurement for SAT procurements
Procurement will assist with Vendors
Consortium Option (competitively awarded contracts)
Leverage existing Contractual Agreements
Collaborative Opportunities
Engagement for Public offering / RFP
Options
Assistance
Guidance

9. WHOI Procurement helps you!
When Procurement receives an SAT procurement we will assist in compliance
We will advertise the opportunity on the “Bid-Page”
We will actively seek other options for the procurement
Group Purchasing and Consortium Contracts
Alternative Vendor search

10. SAT Procurements Procurement by sealed bids (formal advertising)
Procurement by competitive proposals
Procurement by noncompetitive proposals
The item is available only from a single source
The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation;
The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or
After solicitation of a number of sources, competition is determined inadequate.

11. Procurement by non-competitive proposals “Sole – Source”
Procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply:
The item is available only from a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation;
The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or
After solicitation of a number of sources, competition is determined inadequate.

12. Auditor Q & A Sole Source Option
At time of proposal WHOI to submit the Sole Source with expanded justification.
Make it crystal clear WHOI is sole sourcing this vendor
Valid scientific reason to use this vendor, “PI doesn’t want to introduce other variables”
Perform an appropriate analysis – some vendors are “unique” and yes maybe only one source
It’s all in the documentation (there are multiple vendors) – have supportable reasoning why this sole source is the answer

13. Questions?