Single Audit Update: Extension of Procurement Grace Period

Summary

The Office of Management and Budget (OMB) has issued an amendment to the Uniform Guidance impacting organizations that file a Single Audit. This amendment allows for a grace period of one additional fiscal year for the implementation of changes to organizations’ policies and procedures in accordance with the procurement standards outlined in 2 CFR 200.317 through 200.326 in the Uniform Guidance. The new implementation date for the procurement standards will start for fiscal years beginning on or after December 26, 2017 for those organizations that would like to take advantage of the extension. This will be the final grace period for organizations that have not yet implemented the new procurement standards.

What is the New Timeline for Implementation?

For organizations that are required to file a Single Audit that have not implemented the new procurement standards, these new standards must be implemented by the following deadlines:

-For organizations with a fiscal year ending December 31^st, the new standards should be implemented beginning January 1, 2018.
-For organizations with a fiscal year ending June 30^th, the new standards should be implemented beginning July 1, 2018.

How Should Your Organization Prepare?

Maher Duessel has a detailed reference article we encourage you to read regarding the new procurement standards and how your organization should prepare for these changes.

In Summary:

-Read the new procurement standards in the Uniform Guidance and ensure all “musts” in the Uniform Guidance are followed.
-Update your procurement policies.
-Update your standard contract wording.
-Identify conflicts of interest among employees with contract or procurement responsibilities.
-Devote resources to the training and hiring of employees who are procurement specialists.
-Utilize pre-qualified bidder lists.

Please note this summary of recommendations is not meant to substitute for reading the new procurement standards in the Uniform Guidance.