Purchasing Goods or Services with Federal Grant Funding
When purchasing goods or services with grant funds, the purchase is subject to the Federal Uniform Guidance (UG) and University purchasing procedures. It is important to note that the UG only applies to federal grants (financial assistance) and not federal contracts.
The UG procurement standards identifies three thresholds:
- Micro-Purchase: $10,000 or less
- Small Purchase: $10,000.01 - $250,000
- Competitive Proposal: $250,000.01 or more
Micro-Purchase Threshold ($10,000 or less)
Purchases under the Micro-Purchase Threshold can be awarded “without soliciting competitive quotations” if the price is reasonable. For purchases under $10,000, following University guidelines should be sufficient.
Small Purchase Threshold ($10,000.01 t0 $250,000)
Purchases in the Small Purchase Threshold, between $10,000.01 and $250,000, require “relatively simple and informal procurement methods.” Purchases within this UG threshold cross two thresholds under University purchasing policies requiring different involvement by the Purchasing Services Department.
$10,000.01 - $50,000
- Departments may use the Request for Quote (RFQ) template to solicit competitive bids and submit the documentation with your requisition through the PantherExpress System.
$50,000.01 - $250,000
- Contact your procurement specialist for assistance with preparing a formal Request for Proposals (RFP)
Use of University-wide Contracted Suppliers
- Most contracts with University-wide suppliers are “negotiated agreements” and do not sufficiently meet competitive bidding requirements under the UG.
- Suppliers marked as "Yes" under in the Uniform Guidance column on our University-wide Contracted Supplier Directory have competitively bid contracts that satisfy the UG.
- As such, competitive bidding must be done for nearly all purchases using federal grant funding over $10,000.
Competitive Proposal Threshold ($250,000.01 or more)
Purchases that exceed the Competitive Proposal Threshold, $250,000.01 or more, are subject to strict procurement requirements. In order to comply with federal requirements it is essential that purchasers plan significantly in advance of purchase as the RFP process can take 8-12 weeks.
- Obtain independent estimates before receiving proposals such as:
- Previous contracts or publicly available contracts such as those published by a government or public university
- Publish Requests for Proposals (RFP)
- Your procurement specialist will ensure it is posted on our website
- The UG does not define a time limit, the University recommends 7-14 days
- Identify all evaluation criteria and their relative importance
- Relative importance is meant to indicate that they are in a rank or ordered format
- You do not need to supply a weighted criteria for this
- Solicit from an “adequate” number of qualified sources
- A minimum of two returned proposals is necessary to make a comparison
- Have a written method for conducting technical evaluations of the proposals and selecting recipients
- Award the contract through price analysis to a responsible firm whose proposal is most advantageous
- Price and other factors should be considered, not just low-bid
All purchases over $10,000 have a competitive bidding requirement under the UG. Regardless of whether the supplier is a University-wide Contracted Supplier, you must submit a Directed or Sole Source Justification Form* (DSSJ) for all sole-source purchases with federal grant funds that are $10,000.01 or greater.
Situations which are allowable* for sole source procurement include:
- Available only from a single source; for sole source Research is expressly permitted in the UG
- Awarding agency expressly authorizes noncompetitive proposals in response to a written request from the University
- Include this when submitting the DSSJ
- Public exigency
- After an RFP process, competition is deemed inadequate
*Under the new UG Procurement Standards, any sole source purchase over $250,000 must be accompanied by a cost analysis that includes all costs that lead to the quoted price. As this cost analysis would need to include line items for overhead and profit, it is highly unlikely that a supplier would provide this information. However, if you are able to acquire this, include it with the DSSJ. The procurement specialist will need to conduct a cost analysis of the “reasonableness of each cost element." Purchases that are $250,000 or less do not require a cost analysis with the sole source justification.
Exceptions to Competitive Bidding and Sole Source Requirements
The UG allows for “piggybacking” off of existing contracts that were competitively bid. You should ask the supplier you are working with whether they have public contracts, such as those with a government (federal, state, county, city, etc.) or a co-operative entity (E&I, U.S. Communities, NJPA, NASPO Valuepoint etc.).
Uniform Guidance Presentation, May 2018
Two presentations about changes as a result of the UG were provided in May 2018 to University research adminstrators. A PDF copy of the slides related to Uniform Guidance is available for download. For information about competitive bidding, please review this page.