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Guidance on How UG Procurement Standards Affect Charter Schools

AAFCPAs’ John Buckley, CPA, CGMA discussed challenges and opportunities facing Charter Schools while attending and presenting at this year’s National Charter School’s Conference in Austin, TX. In conversations, John learned that many schools have yet to formally update their procurement policies to reflect the Uniform Guidance (UG) procurement standards. As a reminder, the grace period for non-federal entities to comply with these standards concluded on July 1, 2018. If you have not already, AAFCPAs strongly urges schools to not delay further in developing and implementing a written procurement policy.

What Are the Procurement Standards Under the Uniform Guidance?

In December 2013, the Office of Management and Budget (OMB) issued the new Uniform Guidance (UG), which includes comprehensive reform rules affecting all organizations receiving federal grants and contracts. One of the areas of significant change under the UG are the procurement standards, a component of Subpart D, Post-Award Requirements, contained in Sections 200.317 through 200.326. These sections describe the applicable procurement standards, the methods of procurements to be followed, and details of specific items that must be included within contracts under federal awards. In a blog published in August 2016, AAFCPAs outlines the major changes included in the procurement standards, and provides Guidance on How to Comply with Procurement Standards Under the Uniform Guidance.

What Does This Mean For Charter Schools?

Many of the components of the updated UG procurement standards were developed from OMB Circular A-102, under which charter schools are already required to comply.  As a result, charter schools should be in compliance with most of these standards.  AAFCPAs has provided for your convenience a summary of requirements outside of OMB Circular A-102 that charter school clients should be aware of:

  • Requests for Transfers of Records: This requirement is expanded under the new UG procurement standards to include that access to review of the true name of victims of a crime is only allowable under extraordinary and rare circumstances, and does not include routine transactions. Appropriate steps to protect this sensitive information must be taken by both the non-Federal entity and the Federal awarding agency.
  • Termination of a Federal Award: This requirement is further defined to include components such as termination by the Federal Awarding Agency for cause, written notice by the non-Federal awardee for cause, etc.
  • Remedies for Non Compliance: This requirement is expanded to include initiation of suspension and debarment proceedings.

AAFCPAs is available to provide guidance on how your audit may be affected by these new standards, as well as to provide recommendations regarding best practices for grant compliance.
If you have questions, please contact: Emily McGinnis, CPA at 774.512.4056, emcginnis@nullaafcpa.comJohn R. Buckley, CPA, CGMA at 774.512.4039,, or your AAFCPAs Partner.

About the Authors

Emily McGinnis
Emily has been serving AAF clients since 2004, and is responsible for planning and executing financial statement audits for sophisticated nonprofit organizations, as well as tax and informational form preparation for for-profit and non-profit entities. She is a leader in AAFCPAs’ Educational Services practice, providing services to independent schools, charter schools, higher education institutions, and other education services organizations. She also has extensive experience serving research and development organizations, membership organizations, nature preservation organizations, early education and care providers, and housing & community development investing & lending institutions. Emily develops a deep understanding of the client's business by examining operations and processes from the inside out; this enables her to view control issues and concerns from the perspective of the Audit Committee and Senior Management.
John Buckley CPA
John has been successfully serving AAF clients for over 20 years. He has extensive experience with the audits of diverse associations, educational institutions, and other community-based agencies. John specializes in working with nonprofit organizations that are subject to federal, state, and other regulatory requirements. John is AAF’s Educational Services Division Leader, which includes services to independent schools, charter schools and Charter Management Organizations (CMOs), colleges, education services organizations, Chapter 766 schools, and other educational institutions. He has extensive experience with these types of organizations, including working with capital campaigns, financing agreements, and charter school replication.