Uniform Grants Guidance Procurement Standards: More Than Just Finding a Good Bargain
by Elizabeth “Issie” Karan

When buying goods or materials, Hemophilia Treatment Centers (HTCs) may not first think to check federal regulations for grantees. However, the Uniform Grants Guidance (UGG) contains requirements for procurements conducted by federal grantees. These requirements were changed significantly when the UGG was updated in 2014. After the revised UGG went into effect, the government gave grantees a grace period to implement the new procurement standards. However, that grace period ended. The Hemophilia Alliance recommends reviewing internal policies and procedures related to procurement to ensure they comply with the UGG’s standards. Below we summarize major components of the standards but also are available to answer any questions HTCs might have.

As often is the case with compliance, the UGG focuses on the content, maintenance, and execution of written policies and procedures (P&Ps) for procurement. Generally, any procurement process must provide for full and open competition. The P&Ps must incorporate the procurement methods described in the UGG and outlined below. For every procurement action involving purchases in excess of the simplified acquisition threshold ($250,000), the UGG requires that a cost or price analysis be performed and documented. The UGG requires that federal grantees take necessary affirmative steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Finally, the organization must maintain written standards of conduct covering internal and external conflicts of interest.

The UGG identifies five methods for procurement depending on the type of project and dollar amount.