National Grants Management
Association
Uniform Grant Guidance
“Procurement Policy:
Preventing Waste, Fraud, & Abuse”
Jesse Buggs, Director
Office of Grant Development & Administration
City of Bowie, MD
November 2015
Procurement Standards
Procurement (General)
Greatest Area of Waste, Fraud, &
Abuse
Poor/Weak Policies
Major Ambiguities and
Inconsistencies
Decentralized Oversight
Weak Enforcement
Limited Accountability
Objectives of Uniform
Grant Guidance
To deliver on the promise of a 21stCentury government that is more
efficient, effective and transparent.
To streamline the federal
government’s guidance on
Administrative Requirements, Cost
Principles, and Audit Requirements
for federal awards.
The UGG
and
Procurement Standards
Sections
200.317: Procurement by States
200.318: General Procurement Standards
200.319: Competition
200.320: Methods of Procurement to be
Followed
200.321: Contracting with Minority/Women
Businesses
200.322: Procurement of Recovered
Materials
The UGG
and
Procurement Standards
Sections
200.323: Contract Cost and
Price
200.324: Federal Awarding
Agency
200.325: Bonding
Requirements
200.326: Contract Provisions
The UGG
and
Procurement Standards
Major Provisions
Written Policies & Procedures
Recipient Oversight and Monitoring
Conflict of Interest Standards
Full and Open Competition
Adequate Internal Controls
Compliance Reviews
Due Diligence
Audits and Risk Assessments
Policies and Procedures
Policies
“What You Will Do”
Procedures
“How You Will Do It”
Elements of Good Policies
Well Written
Approved by Management
Consistent with Internal Practices
Clear and Concise
Subject Matter Specific
Widely Distributed
Periodically Reviewed and Updated
Elements of Good Procedures
Well Written
Enforced Evenly by Management
Doable/Achievable
Define Timeliness
Delineate Roles & Responsibilities
Specify Consequences for Lack of
Compliance
Contain Some Flexibility
Process for Review and Revision
Changing Existing Practices
“Nothing in this world can take the place of
persistence.
Talent will not; nothing is more common than
unsuccessful men with talent.
Genius will not; unrewarded genius is almost a
proverb.
Education will not; the world is full of educated
failures.
Persistence and determination alone are
omnipotent.” Calvin Coolidge
Solution?
Accountability?
Solution?
Big Stick?
Solution?
Education and Training?
Solution?
Collaboration?
Solution?
Reinforcement?
Solution?
All of the Above!!!!!!!!!!!!
Accountability
Education and Training
Collaboration
Reinforcement
Big Stick (Effective Reminders!)
Persistence
Increased Scrutiny and
Limited Funds
Fraud
Waste
New Systems and
Requirements
GAO
OMB
Reduce the risk of waste, fraud and
abuse through well written, effective
policies and procedures.
Update Policies and
Procedures
• Federal agencies must update
agency regulations to reflect
uniform grant guidance
• Nonfederal recipient entities must
update internal policies and
controls to adequately reflect new
uniform grant guidance
Uniform Grant Guidance
Sound Procurement
Policies and Procedures
• Integrity for All
 Nonfederal
Recipient Integrity
 Subrecipient Integrity
 Auditor Integrity
 Federal Agency Integrity
 Reduced Waste, Fraud, and Abuse
Jesse Buggs
Director, Office of Grant Development &
Administration
City of Bowie
Chair, Metropolitan Washington Council of
Governments, Housing Directors Advisory
Committee
Grants Editorial Advisory Board
Thompson Information Services