HomeMy WebLinkAboutMINUTES - 12082015 - HA C.01RECOMMENDATIONS
ADOPT Resolution No. 5196 approving amendments to HACCC's Procurement Policy for the expenditure of goods
and services.
BACKGROUND
The U.S. Office of Management and Budget (OMB) and the Federal award-making agencies (including the U.S.
Department of Housing and Urban Development, or HUD) recently updated the procurement requirements for
recipients of Federal financial assistance. OMB also made technical corrections to the relevant regulations in the
Code of Federal Regulations (CFR) (2 CFR part 200). The purpose of these changes is to streamline the Federal
government’s guidance on administrative requirements, cost principles, and audit requirements to more effectively
focus Federal resources on improving performance and outcomes, while ensuring the financial integrity of taxpayer
dollars in partnership with non-Federal stakeholders. The uniform guidance supersedes, consolidates and streamlines
requirements from eight OMB Circulars:
· A-21, Cost Principles for Educational Institutions ,
· A-87, Cost Principles for State, Local and Indian Tribal Governments,
· A-89, Catalog of Federal Domestic Assistance,
· A-102, Grants and Cooperative Agreements With State and Local Governments,
· A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher
Education, Hospitals and Other Non-Profit Organizations ,
Action of Board On: 12/08/2015 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF
COMMISSIONERS
Contact: 925-957-8028
I hereby certify that this is a true and correct copy of an action taken and entered on the minutes of the Board of
Supervisors on the date shown.
ATTESTED: December 8, 2015
Joseph Villarreal, Executive Director
By: , Deputy
cc:
C.1
To:Contra Costa County Housing Authority Board of Commissioners
From:Joseph Villarreal, Housing Authority
Date:December 8, 2015
Contra
Costa
County
Subject:Amendment to the Housing Authority's Procurement Policy as required by HUD
BACKGROUND (CONT'D)
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· A-122, Cost Principles for Non-Profit Organizations,
· A-133, Audits of States, Local Governments, and Non-Profit Organizations, and
· The guidance in OMB Circular A-50, Audit Followup, on Single Audit Act follow-up.
In addition to the consolidation of the OMB Circulars, the new regulations raise existing limits in several areas.
The Single Audit threshold is raised from $500,000 to $750,000. Along with that change, the questioned cost limit
in Single Audits is now raised from $10,000 to $25,000. HACCC's policy will reflect the new micro purchase
level under federal contracts of $3,000. This was raised from $2,000. HACCC's policy also uses the new small
purchase level of $150,000, up from $100,000.
Non-federal agencies are required to implement the new regulations within two full fiscal years after the effective
date of the Uniform Guidance which was December 26, 2014. For HACCC, the deadline is by March 31, 2016.
Federal awards made prior to December 26, 2014, will continue to be governed by federal procurement rules in
effect under parts 84 or 85 as codified in the 2013 edition of the CFR, or as provided under the terms of the
Federal award.
HACCC"s proposed procurement policy is attached and is based on the HUD-recommend Policy format located
within Appendix No. 1 of the HUD Procurement Handbook 7460.8 REV 2.
FISCAL IMPACT
HUD's new regulations increase the micro purchase level under federal contracts from $2,000 to $3,000. The
small purchase level under federal contracts is increased from $100,000 to $150,000.
CONSEQUENCE OF NEGATIVE ACTION
Should the Board of Commissioners elect not to adopt Resolution No. 5196, HACCC would not be in compliance
with recently updated HUD requirements concerning the purchasing of services and goods.
CLERK'S ADDENDUM
ATTACHMENTS
Resolution 5196
Procurement Policy