FISCAL GUIDANCE

 

GENERAL FISCAL GUIDANCE

General Fiscal Guidelines apply to all federal grants that DPI administers and as such, all finance officers and program directors should be familiar with them. The following document was designed to assist LEAs and other subgrantees in administering their federal grants.

General Fiscal Guidance
(pdf, 323kb)

 

PROVISIONS AND ASSURANCES

Depending on the federal grant program, various provisions and assurances may apply. Currently, each DPI program office incorporates an assurances document into the grant application.

 

FEDERAL REGULATIONS

EDUCATION DEPARTMENT GENERAL ADMINISTRATIVE REGULATIONS

Title 34 of the Code of Federal Regulations (34 CFR), known as the Education Department General Administrative Regulations (EDGAR), pertains to federal grants administered by DPI. For a complete description of the federal regulations that apply to federal education grant awards, visit the U.S. Department of Education's EDGAR website.

UNIFORM GUIDANCE

The Federal Uniform Grant Guidance (2 CFR, Part 200) is a government-wide framework for grants management provided to assist in complying with regulations issued by the Office of Management and Budget, which pertain to federal grants. The Uniform Guidance was implemented in December 2014 and supersedes guidance from earlier OMB Circulars. Click here to access the full Uniform Guidance and here to see the Uniform Guidance Technical Assistance for Grantees.

INTERNAL CONTROLS

Uniform Guidance and EDGAR require all subrecipients of Federal funds to document certain grant procedures to help meet compliance by outlining the steps necessary to ensure allowable grant costs and methods such as general procurement standards. Pursuant to UG and EDGAR, policies and procedures that MUST be in writing include:

 

Required Internal Control Authorizing Citation

Procurement

Cash Management

Allowable Costs

Conflict of Interest

Equipment Management

Compensation – Personal Services

Travel

Segregation of Duties

2 CFR §200.319(c)

2 CFR §200.302(b)(6), §200.305

2 CFR §200.302(b)(7)

2 CFR §200.318(c)

2 CFR §200.313(d)

2 CFR §200.430(a)(1)

2 CFR §200.474(b)

2 CFR §200.303(a)

 

The following documents are provided as a resource to assist LEA and other subgrantees in developing compliant policies and procedures for federal grants:

  • LEA Fiscal Policies and Procedures Template
    (pdf, 379kb)
  • LEA Fiscal Policy and Procedure Checklist
    (pdf, 145kb)

UG ALLOWABLE COSTS

The Uniform Guidance identifies 55 "items of cost" that receive clarification regarding the allowability, in general, for using Federal funds (2 CFR, Subpart E - Cost Principles). In addition, this section of the regulations provides guidance on "basic considerations" to apply to all costs, listed or not listed.

The Allowable Costs Checklist is provided as a resource to assist LEAs and other subgrantees in administering their grants:

  • Allowable Costs Under Federal Grants Checklist
    (pdf, 94kb)

UG PROCUREMENT

One of the areas of significant change under the UG are the procurement standards, a component of Subpart D, Post-Award Requirements, contained in Sections 200.317 through 200.326. These sections include the applicable procurement standards, methods of procurements to be followed, and details of specific items that must be included within contracts under federal awards. UG procurement standards focus on increased competition, documentation, and maintaining a consistent procurement process.

UG requirements related to procurement took effect July 1, 2018 for non-federal entities. On June 20, 2018, the Office of Management and Budget (OMB) issued a Memorandum (M-18-18) to announce updates for procurements made under federal financial assistance awards. The threshold for micro-purchases for grants and cooperative agreements raised from $3,500 to $10,000, and the threshold for simplified acquisitions increased to $250,000 for all recipients.

OMB memo M-18-18, is available at https://www.whitehouse.gov/wp-content/uploads/2018/06/M-18-18.pdf.

Local Educational Agencies (LEAs) should revise their internal procurement policies to implement the new thresholds to help ensure they have sufficient documentation to show appropriate internal controls and compliance with federal requirements. The Code of Federal Regulations (CFR) §200.318(i) states the nonfederal entity "must maintain records sufficient to detail the history of procurement," which include "rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price."

The following guidance documents are provided to assist grantees in administering their grants:

UG Procurement Methods

Micro-Purchases (< $10,000)

A micro-purchase is a purchase of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the micro-purchase threshold. The LEA can use micro-purchases to expedite the completion of its lowest-dollar small purchase transactions and minimize the associated administrative burden and cost. The micro-purchase threshold was previously $3,500 but has now been increased to $10,000, effective July 1, 2018. Please note that the threshold of $10,000 must be considered in the aggregate over the entire period of applicable federal grants. Therefore, the cost of items purchased using the micro-purchase method is cumulative across the grant year and cannot exceed a total of $10,000.

Small Purchase Acquisition ($10,000 - < $250,000)

Procurement by small purchase procedures uses a relatively simple and informal method of procuring services, supplies, or other property that do not cost more than the simplified acquisition threshold. The small purchase procedures require price or rate quotations from an adequate number of qualified sources. Although EDGAR does not define how many price quotations are considered an adequate number, School Business recommends at least three price quotations. As of July 1, 2018, the simplified acquisition threshold was increased from $150,000 to $250,000. The threshold should be considered as an aggregate amount within the grant period of the applicable grant.

However, North Carolina General Statute requires competitive procurement methods be used for purchases valued at $90,000 or more. If an item costs less than $90,000, state rules allow an LEA to utilize price quotations to stimulate competition and to attempt to receive the most favorable pricing. Therefore, since State law is more restrictive than the EDGAR procurement rules, the simplified acquisition threshold under EDGAR does not apply to purchases of goods made with federal funds costing $90,000 or more.

Simplified Acquisition (> =$250,000)

Sealed Bids

Provide complete descriptions and realistic specifications to three (3) or more sources that are willing and able to provide goods or services. A fixed-price contract will be awarded, and vendor can be selected on price or other factors.

Competitive Proposals

A request for proposal (RFP) must be issued. Evaluation factors and importance must be identified. The LEA must issue RFPs to three (3) or more entities and have a written method of evaluation prepared in advance.

Noncompetitive Procurement Proposals

  • Federal Funds Noncompetitive Procurement Request
    (pdf, 101kb)

Procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply:

  1. The item is available only from a single source;
  2. The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation;
  3. The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or
  4. After solicitation of a number of sources, competition is determined inadequate.

As the pass-through entity for programs authorized under ESSA, IDEA, CTE, et al, the North Carolina Department of Public Instruction may waive competitive procurement requirements in accordance with 2 CFR §200.320(f)(3). A request for noncompetitive procurement must include the vendor, funding source (federal program and PRC), scope of work/deliverables, total cost and a detailed justification. School Business will communicate with appropriate federal program staff to determine final approval.

To submit a noncompetitive procurement proposal please download the above form. Complete the form in its entirety, ensuring all questions are answered. Submit the completed form via email to LeighAnn.Kerr@dpi.nc.gov and attach any additional documentation. The email, form, and additional documentation will be your official 'request' for a noncompetitive procurement waiver. One request must be submitted for each individual issue (e.g., one email / request per vendor); they cannot be combined.

* LEA may have different "simplified acquisition threshold" (e.g., $10,000 maximum for micro-purchases or maximum $250,000 for small purchases). If LEA has a lower simplified acquisition threshold, the LEA must use its simplified acquisition threshold for the above purchase methods.

The following table (as developed by the UNC School of Government) outlines procurement requirements when using federal funds for services and goods. The LEA must comply with the more restrictive of federal, state, and LEA requirements.

 

Procurement Method Goods Services

Micro-Purchase - No required quotes. However, must consider price as reasonable, and, to the extent practical, distribute equitably among suppliers.

$10,000 or less

Must use more restrictive
$10,000 federal threshold.

$10,000 or less

Small Purchase Procedures (Informal) – Obtain/document quotes from a reasonable number of qualified sources (at least three).

$10,000.01 - $90,000

Must use more restrictive
$75,000 state threshold instead of
$250,000 federal threshold.

$10,000.01 - $250,000

Service contracts not subject to state competitive bidding requirements.
LEAs utilize UG process (or local if more restrictive.)

Sealed Bids / Competitive Bids (Formal)

$90,000.01 or more

Must use more restrictive
$90,000 state threshold instead of
$250,000 federal threshold

$250,000 or more

Service contracts subject to state competitive bidding requirements.
LEAs must utilize UG process (or local if more restrictive.)

Noncompetitive proposals

Appropriate only when:

  • Available only from a single source (sole source)
  • Public emergency
  • Expressly authorized by awarding or pass-through agency in response to written request from district
  • After soliciting a number of sources, competition is deemed inadequate.

 

UNC School of Government (SOG) Uniform Guidance Procurement microsite

 

OTHER EXTERNAL RESOURCES

 

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