Uniform Guidance - An update from the field: More questions answered!

Baker Tilly provided an update on the current regulatory landscape with a focus on what higher institutions are doing to address the Uniform Guidance requirements during a recent webinar partnered with ACUA. During this webinar, Baker Tilly higher education specialists shared key initiatives institutions are undertaking to achieve compliance. Continue reading to learn more about Uniform Guidance: an update from the field and see the answers to your questions.

If my institution has established preferred purchasing relationships with vendors as part of a strategic sourcing initiative, will these be considered to meet the Uniform Guidance’s procurement requirements?

It will depend on the dollar amount of the purchase, but typically a preferred vendor relationship would be appropriate under the Uniform Guidance. Preferred vendor relationships usually include price comparison/competition when establishing the initial relationship (and related prices), especially when performed as part of a strategic sourcing initiative. Assuming that items purchased through these agreements are below the Simplified Acquisition Threshold ($150,000), an institution should be able to consider the process followed to establish these relationships as its competitive method for “procurement by small purchase procedures.” Additionally, since items purchased through preferred vendor relationships are typically for commercial goods, an institution could always alleviate concerns by comparing prices from preferred vendor agreements with published prices from other vendors of similar goods.

For purchases below the micro-purchase threshold ($3,000), the Uniform Guidance does encourage organizations to distribute purchases equitably among qualified suppliers “to the extent practicable.” If your institution requires purchases from only preferred suppliers, the organization should be able to justify the benefit of using the preferred supplier (e.g., lower cost charged) rather than distributing purchases.

How does the Uniform Guidance define “adequate”?

Section 200.320 of the Uniform Guidance states: