OMB Further Extends the Effective Date for the Procurement Standards of the Uniform Guidance
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AAFCPAs would like to make clients aware that on May 17, 2017, the U.S. Office of Management and Budget (OMB) issued a correcting amendment extending the effective/applicability date of the procurement standards under the Uniform Guidance (UG).
The procurement standards were one of the areas of significant change under the UG, and nonprofits receiving federal grants and contracts may welcome the OMB’s announcement that they have provided for a grace period for non-federal entities to comply. The grace period allows an extension for implementation of the new procurement rules for three additional full fiscal years after the effective date of the UG.
For December 31 year ends, non-federal entities must fully implement the UG procurement standards by January 1, 2018 (fiscal year 2018).
For June 30 year ends, non-federal entities must fully implement the UG procurement standards by July 1, 2018 (fiscal year 2019).
Nonprofit entities that decide to elect the three-year grace period must document the decision in your internal procurement policies.
AAFCPAs provides guidance on how to comply with the procurement standards under the UG, including key components of your written procurement policy. We advise clients receiving federal funding to review the new standards, determine the impact on your organization, and develop a plan now for compliance. AAFCPAs is available to provide guidance on how your audit may be affected by the new UG, as well as to provide recommendations regarding best practices for grant compliance.
If you have questions regarding your procurement procedures, or need additional information regarding grant compliance, please contact your AAFCPAs Partner or Robin Kelley at 774.512.4011, rkelley@nullaafcpa.com.
Robin brings a wealth of experience to AAFCPAs’ clients in the areas of System & Organization Control (SOC) Reporting, Agreed-Upon Procedures, and special attestations.
Robin has specialized expertise performing quality control reviews of user entity SOC reports, including SOC 1 (SSAE 18), SOC 2, SOC 2+ and 3 attestation reporting. She has extensive experience developing SOC reports for service organizations and has a deep understanding of internal controls from a design, implementation, and testing perspective. This allows …
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