The Office of Management and Budget (OMB) has updated the guidance of procurement policies available to non-federal entities. Under 2 CFR 200.317 – 200.326, the two year grace period of the procurement requirement has been extended to an additional grace period of one year OMB Alert – May 17, 2017.
With this update, the requirement for the procurement standards will start for entities who elect to defer the implementation of the standard and utilize the grace period in order to implement the new procurement requirements for fiscal years beginning on or after December 26, 2017. Those would be for the December 31, 2018 and June 30, 2019 year-end audits.
The OMB staff has communicated this is the final grace period for non-federal entitles who have yet to implement the Uniform Guidance procurement standards. These entities should begin to prepare for the implementation prior to an additional extension, and should be ready to implement the Uniform Guidance procurement standard at the beginning of the fiscal year, for which the standard is applicable (January 1, 2018 and July 1, 2018). As a reminder, non-federal entities need to document their decision to use the extension period, usually through some board action documented in board or committee minutes.