Federal Grant and Purchase Contracts

The University of Rochester receives Federal funding from various government sources (federal grants, contracts and programs including Medicare, Medicaid and Federal Health Care Programs) and is considered a contractor to the United States Government. As such, we are subject to Federal procurement standards. There are two principal sources of law regulating procurement made by universities and other non-profits from funds provided in their federal grants and contracts: (1) 2 CFR 200 and (2) the FAR or Federal Acquisitions Regulations. Another source of law regulating UR procurement is the federal common rule on debarment and suspension. The major source of requirements applicable to institutions of higher education, hospitals and other non-profit organizations is 2 CFR 200, superseding OMB Circular A-110 which is being phased out.

The University of Rochester has begun revising certain of its procurement standards to align with 2 CFR Part 200 as legacy document OMB Circular A-110 is being phased out. Full incorporation of 2 CFR 200 requirements must be achieved no later than July 1, 2018.

 

Purchasing and Supply Chain and department staff, faculty, administrators and students involved in purchasing and/or administering federal funds should be familiar with the following:

2 CFR 200: https://www.ecfr.gov/cgi-bin/text-idx?SID=6214841a79953f26c5c230d72d6b70a1&tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl

(Specifically §§200.314 through 200.327) Procurement Standards for Grants

Federal Acquisitions Regulations (FAR) Link: http://acquisition.gov/far/index.html

Federal Contract Sub-Contracting Requirements

When the University submits a request or receives a Federal Contract Award (vs. a Federal Grant) that exceeds $650,000, we are required to establish a Small Business Sub-Contracting Plan (Plan) with the government agency who issues the Contract. In the Plan, we establish and agree to specific small business goals for purchases/contracts we issue against funds from that Contract.

While the basis for contract goals are established based on the small business opportunities identified in the contract budget submittal, most Federal Agencies who award grants and contracts have the following SBA Goals:

  • 23% Small Business
  • 5% Small Disadvantaged Business (SBD)
  • 5% Woman Owned Small Business (WOSB)
  • 3% Veteran Owned Small Business
  • 3% Service Disabled Veteran Owned Small Business
  • 3% Historically Underutilized Business (HUB)

All contracts require submission of periodic performance reports on Standard Forms 294 and 295 in order to monitor performance against established goals.

Note: Any contract or PO we award to a supplier other than a small business that may exceed $650,000 ($1 Million Construction) in payment of Federal Contract funds require that we obtain a sub-contracting plan from our awarded supplier as outlined in the Small Business Act.