FAQs: Uniform Guidance Procurement Standards
When is the new purchasing policy in effect?
Uniform Guidance procurement standards went into effect on July 1, 2018. As a recipient of federal research funding, MIT must procure goods and services in compliance with the Office of Management and Budget’s (OMB) Uniform Guidance. As sound guidance and practice, VPF is adopting this framework as its purchasing policy for all purchases made at the Institute.
What is Uniform Guidance?
Uniform Guidance is a set of federal rules and requirements for federal awards. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Guidance") of the Office of Management and Budget (OMB) replaces guidance from the earlier OMB circulars—such as the A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements).
Do the new purchasing rules apply to sponsored and non-sponsored project?
Yes. The policy updates impact purchasing related to both sponsored and non-sponsored projects.
What is changing?
The table below provides an overview of the current purchasing rules and the rules that are in effect under Uniform Guidance beginning on July 1, 2018.
Note: Using MIT Preferred Suppliers satisfies all competition requirements and does not require documentation of competition or a Selection of Source Form in your B2P requisition. See below.
What other changes can I expect?
There is a new, online Selection of Source form to better guide you through the process of documenting the steps you took to select the chosen supplier and ensure that you meet specific requirements for competition. Relevant sections of the VPF website—including the Supplier Selection and Sourcing policy (6.0) and Shopping for Goods and Services page—have been updated to reflect this policy.
I plan to make a large purchase (greater than $250,000) on or soon after July 1. Is there anything I should do in advance of the policy change taking effect at that time?
Yes, reach out to a member of VPF’s Strategic Sourcing team at strategic-sourcing@mit.edu to discuss steps that can be taken in June to expedite the process in July.
Why is it beneficial to use MIT Preferred Suppliers?
In short, it could save you time and money.
Time: If you use a preferred supplier, you do not have to complete a Selection of Source form. This will expedite the purchasing process.
Money: You will immediately receive MIT’s discounted rate and other negotiated terms for your purchase.
All procurement transactions must be conducted in a manner reflecting full and open competition to the maximum practicable extent. MIT Preferred Suppliers have been selected through a formal sourcing process and meet MIT’s competition requirements. Use of MIT Preferred Suppliers satisfies these competition requirements, and purchases do not require documentation of competition or a Selection of Source form in your B2P requisition. In addition, these suppliers have multi-year contracts in place with MIT that feature negotiated pricing, and other terms and conditions.
Note: Although Preferred Suppliers provide negotiated pricing for most items within their commodity, some goods and/or services may be excluded and a Selection of Source form would then be required. Review the individual suppliers’ page on VPF Supplier Search for a list of exclusions.
What is a sole source or non-competitive procurement?
Sole source procurements are conducted by obtaining a price or rate quote or soliciting a proposal from only one source. Sole source procurements may only be used in place of competitive procurement methods when approved circumstances exist—for example, if an item is only available from a single source and no other suppliers can satisfy the unique technical requirements. Cost or price analysis is required to establish a reasonable price. To document the sole source justification and cost or price analysis, a completed Selection of Source Form and all supporting documentation must be submitted to VPF.
Where can I learn more about this change?
VPF hosted several information sessions in June and July to help the purchasing community better understand these changes.
If you were unable to attend an in-person session, please reference the online overview, which includes a summary of the new requirements and a tour of the new Selection of Source Form.