Retirement and Insurance Contributions

Block Grant Funds

Education Department General Administrative Regulations (EDGAR)

Note: For information regarding procurement under state law, see the CH policy series regarding Purchasing and Acquisition and the CV series regarding Facilities Construction.

Uniform Guidance (2 C.F.R. 200)

Note: The Uniform Guidance applies to all new grant awards and non-competing continuations (NCCs) made on or after December 26, 2014 (see 2 C.F.R. 200.110).

General Compliance



Procurement Standards

District Procedures
Conflicts of Interest

Financial Management

Internal Controls
  1. Establish and maintain effective internal control over the federal award that provides reasonable assurance that the district is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
  2. Comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the award.
  3. Evaluate and monitor the district's compliance with statutes, regulations and the terms and conditions of federal awards.
  4. Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.
  5. Take reasonable measures to safeguard protected personally identifiable information and other information the federal awarding agency or pass-through entity designates as sensitive or the district considers sensitive consistent with applicable federal, state, local, and tribal laws regarding privacy and responsibility over confidentiality.
  1. Effectiveness and efficiency of operations;
  2. Reliability of reporting for internal and external use; and
  3. Compliance with applicable laws and regulations.


Procurement Methods

Informal Procurement Methods
Micro-Purchase Distribution
Micro-Purchase Awards
Micro-Purchase Thresholds
  1. A qualification as a low-risk auditee, in accordance with the criteria in 2 C.F.R. 200.520 for the most recent audit.
  2. An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
  3. For public institutions, a higher threshold consistent with state law.
Small Purchases—Procedures
Small Purchases—Simplified Acquisition Thresholds
Formal Procurement Methods
Sealed Bids
  1. A complete, adequate, and realistic specification or purchase description is available.
  2. Two or more responsible bidders are willing and able to compete effectively for the business; and
  3. The procurement lends itself to a firm fixed price contract and the selection of the successful bidder can be made principally on the basis of price.
  1. Bids must be solicited from an adequate number of qualified sources, providing them sufficient response time prior to the date set for opening the bids, for local governments, the invitation for bids must be publicly advertised;
  2. The invitation for bids, which will include any specifications and pertinent attachments, must define the items or services in order for the bidder to properly respond;
  3. All bids will be opened at the time and place prescribed in the invitation for bids, and for local governments, the bids must be opened publicly.
  4. A firm fixed price contract award will be made in writing to the lowest responsive and responsible bidder. Where specified in bidding documents, factors such as discounts, transportation cost, and life cycle costs must be considered in determining which bid is lowest. Payment discounts will only be used to determine the low bid when prior experience indicates that such discounts are usually taken advantage of; and
  5. Any or all bids may be rejected if there is a sound documented reason.
  1. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical;
  2. The district must have a written method for conducting technical evaluations of the proposals received and making selections;
  3. Contracts must be awarded to the responsible offeror whose proposal is most advantageous to the district, with price and other factors considered; and
  4. The district may use competitive proposal procedures for qualifications-based procurement of architectural/engineering (A/E) professional services whereby offeror's qualifications are evaluated and the most qualified offeror is selected, subject to negotiation of fair and reasonable compensation. The method, where price is not used as a selection factor, can only be used in procurement of A/E professional services. It cannot be used to purchase other types of services though A/E firms are a potential source to perform the proposed effort.
Noncompetitive Procurement
  1. The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold;
  2. The item is available only from a single source;
  3. The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation;
  4. The federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the district; or
  5. After solicitation of a number of sources, competition is determined inadequate.
Cooperative Purchasing

Minority, Small, and Women's Businesses

  1. Placing qualified small and minority businesses and women's business enterprises on solicitation lists;
  2. Assuring that small and minority businesses and women's business enterprises are solicited whenever they are potential sources;
  3. Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by small and minority businesses, and women's business enterprises;
  4. Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority businesses, and women's business enterprises;
  5. Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce; and
  6. Requiring the prime contractor, if subcontracts are to be let, to take the affirmative steps listed in items 1 through 5 above.

Domestic Preference

  1. "Produced in the United States" means, for iron and steel products, that all manufacturing processes, from the initial melting stage through the application of coatings, occurred in the United States.
  2. "Manufactured products" means items and construction materials composed in whole or in part of non-ferrous metals such as aluminum; plastics and polymer-based products such as polyvinyl chloride pipe; aggregates such as concrete; glass, including optical fiber; and lumber.

Pre-procurement Review

  1. The district's procurement procedures or operation fails to comply with the procurement standards in 2 C.F.R. Part 200;
  2. The procurement is expected to exceed the simplified acquisition threshold and is to be awarded without competition or only one bid or offer is received in response to a solicitation;
  3. The procurement, which is expected to exceed the simplified acquisition threshold, specifies a "brand name" product;
  4. The proposed contract is more than the simplified acquisition threshold and is to be awarded to other than the apparent low bidder under a sealed bid procurement; or
  5. A proposed contract modification changes the scope of a contract or increases the contract amount by more than the simplified acquisition threshold.

Contract Cost and Price

Contract Provisions

Suspension and Debarment

Remedies for Noncompliance

  1. Temporarily withhold cash payments pending correction of the deficiency by the district or more severe enforcement action by the federal awarding agency or pass-through entity.
  2. Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance.
  3. Wholly or partly suspend or terminate the federal award.
  4. Initiate suspension or debarment proceedings as authorized under 2 C.F.R. Part 180 and federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a federal awarding agency).
  5. Withhold further federal awards for the project or program.
  6. Take other remedies that may be legally available.

Travel Costs

Property Standards

Federally Owned Property
Property Trust Relationship
Real Property
  1. Retain title after compensating the federal awarding agency an amount determined under 2 C.F.R. 200.311(c)(1).
  2. Sell the property and compensate the federal awarding agency an amount determined under 2 C.F.R. 200.311(c)(2).
  3. Transfer title to the federal awarding agency or to a third party designated/approved by the federal awarding agency. The district is entitled to be paid an amount calculated by applying the district's percentage of participation in the purchase of the real property (and cost of any improvements) to the current fair market value of the property.
Title and Use
  1. Use the equipment for the authorized purposes of the project during the period of performance, or until the property is no longer needed for the purposes of the project.
  2. Not encumber the property without approval of the federal awarding agency or pass-through entity.
  3. Use and dispose of the property in accordance with the provisions below.
Intangible Property

Prohibition on Foreign Telecommunications Equipment

Direct Grant Programs

State-Administered Programs

General Education Provision Act

Northwest ISD



DATE ISSUED: 10/19/2021