Uniform Guidance for Federally Funded Research

Procurement Process Changes (effective July 1, 2018) due to Uniform Guidance implementation

Uniform Guidance Overview

Uniform Guidance (“UG”) is a set of regulations (located at 2 CFR 200) that consolidates federal guidelines impacting research administration. Per the OMB website, this guidance “supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in 2 C.F.R. Parts 220, 225, 215, and 230); Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.”

Goals of Uniform Guidance

UG significantly reforms federal grant making to focus resources on improving performance and outcomes. The intent is to reduce administrative burdens for grant applicants and recipients and reduce the risk of waste, fraud, and abuse.

Procurement guidance is specifically located in sections 200.317-200.326. This guidance focuses on increased competition and transparency in the procurement process.

Implications for the GW Research Community

Since GW's procurement practices are substantially in compliance with UG, changes to procurement practices should be minimal under new regulations. The most significant change to how GW contracts for Sponsored Research is in sole source procurements. Procurement Services has partnered with the Office of Sponsored Research to collaboratively communicate and coordinate the execution of the new requirements as outlined below.

UG 200.320 Methods of procurement to be followed - has limited the use of sole sources to four distinct justifications. Those are:

1. Product/service is only available from a single source;
2. Public Emergency Procurement;
3. Federal Awarding Agency Authorization (the awarding agency specifically authorizes a non-competitive procurement after a written request from the Non-federal entity);
4. Inadequate competition after multiple attempted solicitations