The document, authored by the Council on Governmental Relations (COGR) and addressed to the Office of Federal Financial Management within the White House Office of Management and Budget (OMB), presents a formal request for revisions to the federal procurement standards under the Uniform Guidance (2 CFR Part 200) and an extension to the grace period for their implementation. COGR, representing research universities and nonprofit research organizations (NROs), expresses concern about unresolved issues and insufficient lead time to adequately implement sections 200.317 through 200.326 by the scheduled FY2017 deadline. The organization requests that institutions of higher education (IHEs) and NROs receive the same exemption from these procurement requirements as States, citing the effectiveness and integrity of their current systems and a lack of evidence for fraud, waste, or abuse under those systems.
COGR outlines several key areas needing attention prior to implementation, including raising the Micropurchase Threshold to $10,000, creating mechanisms for institutions to apply for higher thresholds based on risk assessment, preventing negative impacts on faculty research productivity, revising problematic sections of the regulations, avoiding increased administrative burdens, and incorporating relevant frequently asked questions into the procurement standards. The document concludes by proposing a three-part solution: extending the grace period for implementation to FY2018 (and including section 200.112, Conflict of Interest), establishing a working group to review and improve the regulations with diverse stakeholders, and completing necessary regulatory revisions by Spring 2016. COGR emphasizes their ongoing commitment to collaboration and expresses appreciation for OMB’s responsiveness, while underscoring the urgency and importance of the requested changes for the research community.
