Ask NASCA › 319 procument policies/procedures?
- This topic has 8 replies, 1 voice, and was last updated 8 years, 2 months ago by Colleen Meredith.
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Brian Farkas
Question 1: Does anyone have any in house procurement policies relating to the federal grant programs such as 319? If so, would you please share any forms, policy, links, etc.
Question 2: If you don’t have an in house policy for federal grant programs, what do you use? A state purchasing process? Other?
Thanks.
Mark QuilterI use what ever the federal agency requires. For salinity Reclamation or NRCS provides funded projects. For the Specialty Crop Block Grants from USDA, USDA provides guidance and templates for the application and selection process.
Brent DykesGeorgia uses the state purchasing process.
Cynthia BeardenWe (Arkansas) use the state procurement policy. It’s the same for grant receiptants unless they have developed their own policy equal or “in addition to” the state policy.
Laurie ZellerIn Montana, we were spending a lot of time helping conservation districts with contracting questions. There were many gray areas and the answers changed depending on the funding sources. So, during the last legislative session, we passed a law that applied specifically to conservation districts. Now no matter the funding source, if funding is passed through a CD, the CD procurement law will be used. It is much easier now. CDs may have to add some additional advertising to meet the federal requirements, but that is about it. You can find the new law at http://leg.mt.gov/bills/mca_toc/76_15_10.htm.
Jim BowcuttIn Utah, the Federal 319 grant is awarded to the Division of Water Quality. If the Division of Water Quality decides to fund a project submitted to us from another agency or entity we then make them a sub-recipient of the grant. This comes with increased reporting requirements for that entity, and a plan of work must be submitted to DWQ along with additional terms and conditions. The only time that we do a sole source agreement is if we have another entity providing administrative services for conservation districts that do not have a large amount of funding in their bank accounts to cover the costs often incurred during the payment process.
Marc CribbSC uses the State Procurement Policy for Federal grants.
Betsy DakeRhode Island uses state procurement requirements. Municipal sub-grantees may use their own procurement procedures IF they are at least as or more stringent than state procedures. Conservation districts follow state procurement requirements.
We also require a 10% Minority/Women-owned Business Fair Share for all state and federally funded grant projects (of the total project cost, not just the grant cost). The NPS Section 319 Grant Manager (i.e., me) coordinates this with the local grantee through the Minority Business Enterprise Compliance Office in our Department of Administration. (This is also a requirement for all Clean Water Act grants, but it’s a state requirement as well).
Colleen MeredithQuestion#1:
Since MoDNR is a state pass-through agency, the OMB Circulars states “When procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-federal funds”. (2 CFR Part 22.317) However, states have to include clauses for contracts that are required and listed under 2 CFR 200.326, which we do. So Missouri uses our state procurement policies since much of it is in state regulations or statutes (Code of State Regulations). Usually state statutes will supersede and we may defer to federal requirements if not in statute for federal awards. This is why our Subgrant General Terms and Condition to entities to whom we pass-through federal funding contain a combination of both state and federal requirements.For all other non-state entities, the Code of Federal Regulations states “All other non-Federal entities, including subrecipients of a state, will follow §§200.318 general procurement standards through 200.326 contract provisions”, which outlines specifics needed for procurement. See links below. The first link takes you to the overall CFR and the second link is to 200-318 General Procurement Standards for non-federal entities. Anyone developing their procurement policies and procedures, especially if they routinely receive federal funding, would benefit from including in their policies and procedures the steps outlined in these sections of the federal OMB circular sections on Procurement.
http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl
http://www.ecfr.gov/cgi-bin/text-idx?SID=24b08031501c6bcd3a93362b4b55e112&mc=true&node=se2.1.200_1318&rgn=div8These are not specific to any one particular federal grant like 319 – but to ALL federal grants.
Question #2
From the non-federal and state entities our 319 Program has funded, they typically have their own procurement policies and procedures which include any state or local laws/regulations and they build in federal policies based on these CFR requirements to cover themselves for if and when they acquire federal funding. -
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