May 31, 2018:  Update - Uniform Guidance (UG) Micro-Purchase/Direct Purchase Threshold

Currently, OSU has a micro-purchase/direct purchase threshold of $25,000 (the dollar threshold where competition is not required if price is determined reasonable.)  OSU has submitted a request to continue with the current direct purchase/micro-purchase threshold of $25,000 to OSU’s relevant executive agency pursuant to the National Defense Authorization Act (NDAA) of 2016.

The NDAA allows institutions of higher education a micro-purchase/direct purchase threshold of A) $10,000; or B) such higher threshold as determined appropriate by the head of the relevant executive agency and consistent with clean audit findings under 5 chapter 75 of title 31, internal institutional risk assessment or state law.  A team of representatives from Business Affairs, Procurement, General Counsel and Research conducted a risk assessment and provided a written justification for OSU to continue to utilize the current micro-purchase/direct purchase threshold of $25,000.   The Vice President for Finance and Administration and the Vice President for Research supported this justification.

Procurement has updated the OSU Standards for Procurement to incorporate the Uniform Guidance and the Standards are now under review with the Policy Advisory Group.  Procurement policies are also being updated.

Communication and training about how the Uniform Guidance and drafted Procurement Standards impact purchasing at OSU will occur in June.

July 13, 2017:  Update - OSU has delayed the implementation of the Uniform Guidance Procurement Standards until July 1, 2018 as provided by the waiver of the procurement rules stated in the Office of Management and Budget May 17, 2017 update.

June 29, 2017:  Implementation of the Uniform Guidance Procurement Standards, 200.317 through 200.326 has been extended for another year.  OSU will continue to delay the implementation of the Uniform Guidance Procurement Standards and follow guidance under the old standards until September 1, 2017 when OSU intends to implement the Uniform Guidance Procurement Standards.

October 27, 2015: Implementation of the Procurement Standards, 200.317 through 200.326 has been extended for one year. For OSU this means that the effective date will be July 1, 2017. During this grace period it is anticipated that the Institutes of Higher Education will engage with OMB to address issues such as the micropurchase level.

July 16, 2015: The Uniform Guidance Procurement Committee met for the first time on July 14th. There was a review of those areas of the Uniform Guidance Procurement Standards that impact OSU Procurement Standards and/or Policies. There was also discussion on decisions that will need to be made regarding the application of the Uniform Guidance on all types of procurements which would allow one set of procurement rules or just federally funded procurements which would require two sets of procurement rules. There was a presentation that guided the discussion.

May 4, 2015: A plan has been formulated to change the OSU Standards that pertain to Procurement so that OSU will be in compliance with the new Uniform Guidance. There will be an advisory committee chaired by the Chief Procurement Officer and comprised of representatives from Faculty, Capital Planning, Internal Audit, Compliance, General Counsel, Business Affairs, Procurement, Business Centers, Sponsored Programs, and Office of Post Award. The advisory committee will be tasked with the following:

  • Developing an impact assessment review
  • Giving input on key decision points
  • Providing feedback as the OSU Standards are updated to be in compliance with the Uniform Guidance
  • Gaining review and approval of the finalized proposed changes to the OSU Standards from the Executive Standards Review Committee
  • Advising on changes to OSU procurement policies
  • Providing input on training OSU staff
  • Providing advice on ongoing communication about the changes

The Faculty Senate Executive Committee is being consulted with regard to how best to communicate to the faculty community who are potentially impacted by the Uniform Guidance as it applies to purchases at OSU.

 February 11, 2015:  As PaCS Policy, Oregon State University is delaying implementation of the Uniform Guidance pertaining to procurement as provided by waiver of procurement rules stated in COFAR FAQ, Section 110-6.  The University will implement the new procurement rules July 1, 2016 and in the interim will follow the guidance under the old standards.

On December 26, 2013, the Office of Management and Budget (OMB) released its final guidance on the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” This guidance has been called the “Omni-Guidance” or “Supercircular” and supersedes previous OMB circulars. The area of Procurement is of particular concern to many impacted Universities as it requires significant changes to current university procurement policies and processes and is scheduled to become effective June 30, 2016. We will be reviewing the changes and how they impact current OSU Standards pertaining to Procurement as well as OSU Procurement policies.