Effective May 17, 2017, for all non-Federal entities, there is an additional one-year grace period for implementation of the procurement standards set forth in the Uniform Guidance (2 CFR 200.317 through 200.326).  This extends the grace period through 2017, and the implementation date will be for entities with fiscal years beginning on or after December 26, 2017.

As previously stated in 2 CFR 200.110, any application of previous procurement standards before the adoption of the Uniform Guidance standards during this grace period must be documented within internal procurement policies.

It has been communicated by those within the Office of Management and Budget that this will be the final grace period related to procurement.

What this means for you:

If your entity has already implemented the new procurement standards, then nothing will significantly change, and your audits will be testing the procurement policy that has been implemented and its appropriateness in regards to the Uniform Guidance.

If your entity has not already implemented the new procurement standards, then it would be a good idea to review the procurement changes and determine if electing the grace period instead of implementing the new standards is appropriate.  Should you elect to defer the implementation, this process should follow your internal control procedures already in place, and the deferral should be documented in your procurement policy.  Audits performed for calendar 2016 and 2017 and fiscal 2018 will test your existing policy and the correct application of the deferral.  The first audit with the new procurement standards will be the calendar 2018 audit or the fiscal 2019 audit, unless the entity elects to implement the procurement standards before those year ends.

For more information or questions regarding this, please contact: Audit Senior Manager, Michaela Kay at 206.973.0132 or Audit Manager, Veronica Cook at 206.382.7790.

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