Uniform Guidance

Uniform Guidance has been in effect since December 26, 2014. Recently, the procurement portion of Uniform Guidance went into effect July 1, 2018.

What is Uniform Guidance?

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards collectively known as "Uniform Guidance" is a new set of federal regulations governing the administration of federal funds by non-federal entities.

While the University's procurement methods and procedures for purchases over $25,000 meet the new federal requirements, purchases between $10,000 - $25,000 using ANY federal funds will need to be mindful of uniform guidance. The only exception to this is purchases made on Duck Depot. Departments may use Duck Depot for any amount because the suppliers have already been through a competitive process that meets the new federal requirements.

I am using federal funds and my purchase is over $10,000 but under $25,000. What do I need to know?

  • For purchases funded by grant contracts executed (or most recently renewed or amended by written agreement) on or after July 1, 2021, departments will be required to collect and submit 3 quotes for purchases over $10,000 and less than $25,000, unless those purchases are made via Duck Depot
  • When conducting RFPs, APs, or a sole source, purchases valued over $10,000, UO will develop a cost and price analysis as part of award review.
  • Exemptions from competition will be granted only under the following circumstances: 
    • The granting federal agency has expressly waived a competitive procurement requirement
    • The goods or services to be purchased are from a true sole source
    • There is an emergency giving rise to the need for the purchase
    • UO has conducted a procurement and only received one, or no responses
  • For each purchase over $10,000 made with federal funds, the UO will record the following:
    • Rationale for the method of procurement;
    • Rationale for the type of contract used;
    • Basis for contractor selection or rejection;
    • Basis for the contract price for each transaction funded by a federal grant. 

Any funding received from the federal government, or from another agency where the funding originated from the federal government.   

Duck Depot catalog purchases are not exempt. However, their contracts are the result of competitive cooperative procurement activity that complies with Uniform Guidance.  

This is dependent on the good or service being purchased. Informal quotes coming from emails or internet search are acceptable, so long as the quote is for the same or similar goods or trade services. 

 A true sole source is where only one vendor in the world can provide the good or service. Some examples could be licenses to Intellectual Property, rental of real estate etc. 

 Doing so would be a fraudulent attempt to avoid federal rules, subjecting UO to significant penalties, and possible denial of grants.   

The federal government performs periodic audits of purchases made by the UO to ensure compliance with federal law, including the Uniform Guidance.  Auditors look at purchases over a period of time, not at single purchases.  Attempts to circumvent rules are seen as fraud and could be cause for removal of ALL federal funding towards the university. 

We're in the middle of a multiyear grant and we've used the same equipment for the first half of the study. The PI has no intention of changing equipment and ruining his research. What do I do?

 The best option would be to request in writing that the awarding agency grant an exemption. Contact SPS for help.   

What if the first part of my purchase from the vendor was before June 30, 2018, and the balance after June 30th on a 2nd PO and the total price goes up to $20K (or within the limits)? How far back/forward will the federal government go when looking at our purchase history?

 Any purchase after July 1, 2018 is subject to Uniform Guidance.   

Has PCS updated its processes to account for Uniform Guidance?

Yes, the PCS purchasing portal is set up to prompt departments to provide any additional information and/or record justifications.

How do I learn more?

Contact PCS at 541-346-2419 or SPS at 541-346-5131

Help! I am stuck, who do I contact?

Contact PCS at 541-346-2419 or SPS 541-346-5131