Additionally, on May 16th, the Office of Management and Budget (OMB) issued a federal register notice to further extend the grace period of implementing the procurement requirements under the Uniform Guidance to three years. The link to the federal register notice is below. This means that 12/31 year ends now have until 1/1/2018 to implement the new requirements, and 6/30 year ends have until 7/1/2018.
Important things to remember:
If an Organizations elects to use any part of the 3 year grace period, they are required to document the decision.
When testing procurement for a client that has a grant under the Uniform Guidance, and who has elected to use the grace period, we should be using the following workpapers:
- 2016 Procurement Testing (old regs) template
- 8130.02 OMB UG 2016 Compliance Supplement Part 3.2 (UG) for all areas except I. Procurement
- 8130.01 OMB UG 2016 Compliance Supplement Part 3.1 (old regs) for the I. Procurement tab.