Uniform Guidance Updates for Purchases with Federal Funds


In 2013, a new set of federal guidance (referred to as Uniform Guidance) was issued by the Office of Management and Budget (OMB) that is intended to simplify requirements associated with federal funds.  The procurement section of the guidance was given additional time for implementation.

Beginning July 1, 2018, the procurement requirements for Uniform Guidance are effective at the University of Iowa when federal funds are used.  The University has been allowed by the federal government to utilize our normal bid threshold of $50,000 which minimizes the impacts to our procurements.  A summary of the impacts of Uniform Guidance General Procurement Standards for University of Iowa purchases are as follows:

  1. Conflict of Interest
    1. When Federal funds are used, the following conflict of interest language applies:  No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. The officers, employees, and agents of the non-Federal entity may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts. However, non-Federal entities may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value. The standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-Federal entity.
      1. University employees involved in the bidding process and in making purchases are considered to have a conflict of interest when members of their immediate family are employed/have a financial interest in the selected firm and federal funds are used.
  2. An adequate number of qualified sources must be identified and given the opportunity to participate in bids to ensure maximum open and free competition.
  3. Use of Federal Excess and Surplus Property – the Principal Investigator (PI) is responsible for ensuring this is considered.
  4. Geographical preferences cannot be applied in the evaluation of bids or proposals.
  5. Firms involved in developing or drafting specifications, requirements, statements of work, or RFPs cannot participate in a subsequent competitive bid associated with the procurement.
  6. Micro-purchases ($50,000 or less) do not require a formal competitive bid.
  7. Procurements that exceed the Simplified Acquisition Threshold (SAT) of $250,000 must perform cost or price analysis prior to bidding (at least an Independent Estimate).
  8. The University must negotiate profit as a separate element of price when there is no price competition (purchases with an SSJ) and in all cases where cost analysis is performed (purchases exceeding the SAT).
  9. Payment must be made within 30 Days of the invoice date unless it is reasonably believed to be improper.