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Procurement under OMB’s Super Circular


The Office of Management and Budget's "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards," popularly known as the “Super Circular,” became effective in December 2014. If you’re responsible for making contracting or purchasing decisions for your program or tribe, you need to understand practical steps for following the Super Circular’s procurement guidelines. In this this uniquely tailored, hands-on class, we’ll use facilitated discussions to walk you through how to set and implement practical and effective procurement policies for day-to-day use at your tribe.

We’ll be sure to cover the key issues relating to procurement guidelines, including all the important changes you should be aware of in the new guidance, such as what the questioned costs threshold is, what type of oversight you need to perform to ensure the contractors you work with are meeting Federal specifications, and how to handle new record-keeping requirements relating to history of performance. Plus we’ll discuss how to conduct either a cost or price analysis to help ensure your organization pays a fair price. We also will review requirements for standards of conduct and tips for stopping purchasing fraud.

This important one-day class will help you make sure you’re following proper procurement standards, so your tribe can keep all of the Federal funding it is entitled to!

T O P I C S   I N C L U D E

Standards of Conduct

  • Required by Circular
  • No conflicts of interest—real or apparent
  • No gratuities
  • Officials not to benefit
Indian Preference
  • P.L. 93-638, 7A, B & C
  • What funding this applies to
  • Competition requirements
  • Price comparison
Reducing Fraud
  • Segregation of duties
  • Public opening of bids
  • Vendor background checks
  • Documenting receipt of goods
Ensuring Competition
  • Requirements in Circular
  • Dollar thresholds
  • When competition is not required
  • How to document when you do sole source

Allowable Methods of Purchasing

  • Micro purchasing
  • Small purchasing procedures
  • Negotiated procurement
  • Sealed bids
OMB Requirements
  • Cost analysis
  • Price analysis
  • Advertising
  • Following Davis Bacon Act

*Topics subject to change.

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