The U.S. Office of Management and Budget (OMB) has issued another grace period for nonfederal entities that haven’t implemented the procurement standards of the Uniform Guidance. According to the Federal Register amendment, the effective date has been revised to allow a grace period of one additional fiscal year to allow nonfederal entities to implement changes to their procurement policies and procedures in accordance with guidance on procurement standards. The grace period has been extended through December 25, 2017, and the implementation date for the procurement standards will start for fiscal years beginning on or after December 26, 2017.
However, this is expected to be the final grace period for nonfederal entities that haven’t implemented the Uniform Guidance procurement standards. Entities shouldn’t wait to start preparing for implementation prior to the extended implementation date. For example, an entity with a fiscal year ending December 31, 2018, should be ready to implement the Uniform Guidance procurement standards at the beginning of that fiscal year, i.e., January 1, 2018.
As a reminder, 2 CFR 200.110 requires nonfederal entities to document their decision to choose to use the previous procurement standards during the extension period.
If you have any questions, contact your BKD advisor.