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Tribal Financial Management Center
Procurement Methods
Procurement Methods
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StepLesson 1of 5Procurement Methods
Description
Common Procurement Methods
There are a variety of procurement methods used when goods and services are purchased with federal grant funds. Grantees are required to have procurement policies which follow the guidelines in 2 CFR 200 to set standards and processes for each procurement method. The dollar value of the individual item usually determines the procurement method to be used. However, the availability of the item in the marketplace or unique type of service required can also drive the type of method used. All goods and services procured must be for allowable costs outlined in the federal guidelines.
These are the commonly used methods used to obtain goods and services for your tribal entity using federal funds:
Micro-Purchases
Small Purchases
Competitive Bids: Sealed and Negotiated
Non-Competitive Awards (Source Awards)
Commonly Used Methods
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Micro-purchase is one type of procurement method used for the day-to-day items required to do routine activities and operations. This method is appropriate when the total cost is less than $10,000. Micro-purchases may be awarded without asking for competitive quotes when grantees consider the price to be reasonable. These types of purchases should be made equally from a variety of qualified vendors and contractors. It is important to be transparent about the total costs of purchases to avoid the appearance of trying to get around the dollar threshold. Price comparison is not required; however, the prices from different vendors should not be too far apart. An example of micro-purchasing toilet paper in bulk for a shelter facility is provided below. These are two methods which could be used for the procurement:
Toilet paper could be purchased from Store A, Store B, and Store C at the same time. The total of the purchases cannot exceed $10,000.
Toilet paper could be purchased all from Store A (for $10,000 or less). The next time bulk toilet paper is needed, the purchase would be made from Store B. The third time a bulk toilet paper purchases is needed, the purchase would be made at Store C. The time between purchases should be long enough that an independent reviewer would have no doubt all the toilet paper was used in between purchases.
Small purchases are those with a cost less than $250,000. This is the current (2019) amount below which a grantee may purchase goods, services, and property using simplified purchasing methods. The dollar amount is adjusted from time-to-time. It is a good idea to check the current “simplified acquisition threshold" at 2 CFR 200 guidelines. A grantee may also set its own dollar threshold for small purchases below the federal level. For example, a grantee’s procurement policy might set the small purchase limit to costs less than $75,000. The procurement policy would set the guidelines for the number and type of price or rate quotation required before making the purchasing decision. For example, a grantee’s policy might require three or more telephone or online bids to support the best purchase decision.
Competitive bid methods are used when the purchases are greater than $250,000 (or the current Simplified Acquisition Threshold). There are two types of competitive bids.
Open Competition – This is the preferred method when qualifications are important. The bidders submit proposals in response to a request made by the purchaser. The payment method is cost reimbursement for time and materials or a fixed price of a fair and reasonable compensation. The award is made to the bidder which results in the best purchase decision based on price and qualifications.
Sealed Bids – For this method, public advertising is used to solicit a reasonable number of suppliers who meet the minimum specified qualifications. The payment method is a fixed-price contract. The award is made to the lowest bid submitted in writing.
The procurement specifications should be made so unreasonable requirements are not placed on bidder, such as:
Unnecessary experience
Excessive bonding
Demanding name brands only instead of comparable brands
Non-relevant geographic preferences
A sole source award is usually only allowable when it is pre-authorized by the federal funding agency. The non-competitive (Sole Source Award) method is not common. It is used when:
Specialty goods or services are only available through one source
An open competition is held and the response is deemed inadequate
An emergency situation prohibits a competition
Tribal Sovereignty
One important consideration is to keep in mind tribal sovereign immunity. For a detailed review about the implications of this, please visit this resource.
The OVC Tribal Financial Management Center (TFMC) provides training, technical assistance, and resources to support American Indian and Alaska Native communities as they successfully manage the financial aspects of their federal awards. OVC TFMC also offers support via our Virtual Support Center (VSC) to Office of Victims of Crime (OVC) grantees and those seeking federal funding from OVC for the first time. Email questions or requests for grant financial management technical assistance to [email protected]. Visit OVCTFMC.org for additional resources and information.