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Two-Year Procurement Grace Period Enacted in OMB's Uniform Guidance

October 8, 2015

The Office of Management and Budget (OMB) has issued a Federal Register notice that includes technical corrections to the Uniform Guidance.The biggest change affecting tribal governments is a revision to the Uniform Guidance that now allows a grace period of two fiscal years to implement changes to procurement policies and procedures (§§200.317-200.326). 

Previously, the Uniform Guidance did not include tribal governments in the option to delay the implementation of new procurement rules. NAFOA's Financial Management Advisory Committee submitted comments in February requesting that tribes be included in the delayed one-year grace period. The comments recommended that the OMB consider broadening the scope of delaying the procurement policies to include tribal governments. 

The two-year grace period option is a win for Indian Country since many tribes may not have been in compliance because they relied on conflicting information in the FAQ document.The option was only available to nonprofit organizations and institutions of higher education in the guidance, although the November 2014 FAQ document stated it was available to all non-federal entities.

The Council on Financial Assistance Reform has also released a new FAQ document. The fourth version of the FAQ document includes 23 new questions and revised answers for three previous questions - many related to indirect costs and audits.

For questions or comments please contact Jennifer Parisien at Jennifer@nafoa.org  or (202) 558-8040. 

Resources:

*2 CFR 200 - Uniform Guidance

FAQ Document - September 2015

Uniform Guidance Crosswalk for Federal Agency Exceptions and Additions

NAFOA's Webinar on Procurement

*Note: the CFR will be updated to reflect the technical corrections and changes to agency regulations after the December 26th effective date.

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