Uniform Guidance

Uniform Guidance (UG), is the set of rules and regulations that governs the administration of federally funded projects during its lifespan. The bulk of Uniform Guidance came into effect on December 26, 2014, but much of the guidelines that impact University Procurement Services were delayed. As a result, Rutgers became compliant with UG standards by July 1, 2018, a requirement in order to remain eligible to receive federal funds.

Uniform Guidance guidelines is meant to combine, update, and supersede the OMB Circulars and federal guidelines, including A-21, A-110, and A-133. The standards are laid out in sections 200.317-200.326 of the CFR Title 2, Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

 

Checklists and Procedures

Rutgers has implemented University Procurement Services written policies and procedures to align with UG, and has created checklists based on purchase amount to assist units with UG compliance and University requirements. For any purchase $10,000 and greater, the applicable forms and accompanying documents MUST be attached as an internal document to the requisition.
 

Checklists:

 

Special Considerations for federal award Purchases $150,000 and Greater

 

Formal Bids

We are responsible for conducting the Formal Bid process for all single purchases $150,000 and greater, including federal award purchases, however there are some areas that will be your responsibility, including items in the RFX Intake Form.

You will need to do an independent price/cost estimate prior to bid solicitation for federal awards, to comply with one of the UG requirements. The estimate should be attached to the requisition as an internal attachment.

Acceptable methods include:

  • Price/market catalog
  • Comparison to in-house estimate
  • Comparable customer’s invoice
  • Comparable to price sold to federal government
  • Award specifically identifies item/person and price
  • Historical pricing
  • Comparison to similar Items

You should contact University Procurement Services Help Desk if there is any question.

 

Waiver of Bids

UG requires that for federal awards $150,000 and greater with no price competition, you will need to do a cost analysis with profit evaluation. 

A price analysis should be considered first by either:

  • Price/market catalog
  • Comparison to in-house estimate
  • Comparable customer’s invoice
  • Comparable to price sold to federal government
  • Historical pricing
  • Comparison to similar Items
  • Award specifically identifies item/person and price

The analysis should be attached to the requisition as an internal attachment.

A cost analysis should be done if a price analysis cannot be done.

To assist the units with this requirement, University Procurement Services has created a template and accompanying instruction:

 

The analysis should be attached to the requisition as an internal attachment.

You should contact University Procurement Services Help Desk if there is any question.

 

Tracking Deliverables

After the purchase, you are responsible for ensuring that the goods, services, deliverables, and supplier payments are consistent with the requirements set forth in the related procurement contract.

To assist the units with this requirement, we have created a template and accompanying instruction, both of which are in the Contract Management section of the Forms Repository:

 

For a complete list of frequently asked questions, please view UG FAQs.

Where Can I find the Uniform Guidance Policies (UG)?

The Uniform Guidance policies can be found at the Electronic Code of Federal Regulations.

How do I ensure UG compliance?

The Rutgers community can help ensure compliance to Uniform Guidance by adhering to University Procurement Services’ redefined policies and procedures, and by following the checklists outlined above.

What happens if my funding was issued prior to July 1, 2018?

As of July 1, 2018 all federally funded awards will follow Uniform Guidance, regardless of the date of issue.

Do the redefined procurement standard guidelines apply to federally and non-federally funded sources?

No, the standards only apply to federally funded sources.  

What are the repercussions of non-compliance?

The units and the University could be audited and could potentially have any federal awards reduced or suspended.