Requirements for Procuring Goods and Services With Federal Education Grant Funds MISSISSIPPI DEPARTMENT OF EDUCATION OFFICE OF SCHOOL RECOVERY OCTOBER 28, 2010
EDGAR PART 80 – UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL GOVERNMENTS (AUTHORITY: 20 U. S. C. 3474; CIRCULAR A 102)
OMB CIRCULAR A-87 GENERAL PRINCIPLES FOR DETERMINING ALLOWABLE COST
ADDITIONAL REQUIREMENT OF ARRA
ARRA – ADDITIONAL ACCOUNTABILITY AND TRANSPARENCY REQUIREMENTS SEC. 1554 - Special Contracting Provisions. To the maximum extent possible, contracts funded under this Act shall be awarded as fixed-price contracts through the use of competitive procedures. A summary of any contract awarded with such funds that is not fixed-price and not awarded using competitive procedures shall be posted in a special section of the website established in section 1526.
ARRA– ADDITIONAL ACCOUNTABILITY AND TRANSPARENCY REQUIREMENTS Sec. 1604 – Limit on Funds Sec. 1605 – Buy American – Use of American Iron, Steel, and Manufactured Goods Sec. 1606 – Wage Rate Requirements
ARRA– ADDITIONAL ACCOUNTABILITY AND TRANSPARENCY REQUIREMENTS Job Posting – Must follow procedures in DFA’s Memo 14 regarding posting of recruitment.
ARRA awards considered high risk under A-133. TREATMENT OF ARRA FUNDS
COMMONLY IDENTIFIED PROCUREMENT WEAKNESSES AND DEFICIENCIES
COMMON PROCUREMENT WEAKNESSES • Lack of Contract File Documentation
COMMON PROCUREMENT WEAKNESSES • Lack of Contract File Documentation • Lack of Approvals
COMMON PROCUREMENT WEAKNESSES • Lack of Contract File Documentation • Lack of Approvals • Failure to Follow Existing Procurement Procedures
COMMON PROCUREMENT WEAKNESSES • Lack of Contract File Documentation • Lack of Approvals • Failure to Follow Existing Procurement Procedures • Split Purchases
COMMON PROCUREMENT WEAKNESSES • Lack of Contract File Documentation • Lack of Approvals • Failure to Follow Existing Procurement Procedures • Split Purchases • Lack of Competition in Small Purchase Procurement
COMMON PROCUREMENT WEAKNESSES • Lack of Contract File Documentation • Lack of Approvals • Failure to Follow Existing Procurement Procedures • Split Purchases • Lack of Competition in Small Purchase Procurement • Unauthorized Commitments to Vendors
COMMON PROCUREMENT WEAKNESSES • Lack of Contract File Documentation • Lack of Approvals • Failure to Follow Existing Procurement Procedures • Split Purchases • Lack of Competition in Small Purchase Procurement • Unauthorized Commitments to Vendors • Lack of documentation regarding suspension and debarment Grantees fail to document that vendors were checked against the ‘Excluded Parties List’.
GSA EXCLUDED PARTIES LIST SYSTEM www. epls. gov