2 CFR 200 Procurement Checklist: Buying With Federal Grant Money

This 2 CFR 200 procurement checklist covers the Uniform Guidance rules for grant-funded purchases.

By Dr. Shirley Ayangbah, Founder and Lead Strategist, Global Economic Research Consulting (GERC)

When a city, county or district spends federal grant money on goods, services or construction, it must follow the procurement standards in the federal Uniform Guidance, 2 CFR 200.317–200.327, plus any extra terms in the grant agreement. Procurement findings are among the most common issues in single audits, and in serious cases costs can be disallowed.

This checklist is a starting point. Always read your award terms, and ask your grant manager or counsel about specific cases.

Before you buy

• Written procurement standards (200.318). Your agency must have documented procedures consistent with federal, state and local law.
• Conflict of interest standards (200.318(c)). Written standards covering employees and officers involved in selecting, awarding or administering contracts.
• Full and open competition (200.319). Avoid requirements that restrict competition, such as unnecessary experience rules, brand-name-only specifications or letting a consultant who wrote the specifications bid.
• Choose the right method (200.320). Micro-purchase, informal (small purchase), sealed bids, proposals or, in limited cases, noncompetitive procurement. Your thresholds must follow the federal rules and your own policy, whichever is stricter.

Required 2 CFR 200 procurement steps

• Small, minority and women’s businesses (200.321). Take the affirmative steps: put these firms on solicitation lists, divide work where possible and encourage primes to subcontract to them.
• Domestic preferences (200.322), where applicable.
• Cost or price analysis (200.324) for procurements above the simplified acquisition threshold, including contract modifications.
• Qualifications-based selection for architectural and engineering services, where price is not a selection factor.
• Check exclusions (200.214). Confirm contractors are not suspended or debarred in SAM.gov.

Contract terms

Include the contract provisions required by Appendix II to Part 200 as they apply, for example termination, equal employment opportunity, Davis-Bacon for construction where required, Clean Air and Water Acts, debarment, the Byrd anti-lobbying amendment and procurement of recovered materials.

Keep the record

Document the history of each procurement: the method, the reasons for contract type, how the contractor was selected or rejected, and the basis for price (200.318(i)). If it is not in the file, auditors will treat it as not done.

How GERC helps

We review grant-funded solicitations against 2 CFR 200 before release, prepare cost and price analyses, and set up small business outreach. See procurement support for cities and infrastructure grant writing.

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About the author

Dr. Shirley Ayangbah is the founder of Global Economic Research Consulting, a woman-owned, California-certified Small Business (Micro) and SB-PW firm in San Bernardino (Certification ID 2045992). She holds a PhD in International Economic and Financial Law and an MA in Economics, and leads GERC’s procurement, grant and economic analysis work for public agencies, prime contractors and small businesses. Call (909) 454-7076 or book a consultation.