Updates:

1. Threshold Increase for Purchases Without Competition,
2. Federal Acquisition Regulation (FAR) Threshold Increases, and
3. Timeline for the Implementation of New Requirements for Purchases above $150,000

Threshold Increase for Purchases Without Competition
Effective October 13, 2015, RCUH has raised the threshold for purchases that can be made without competition, from $3,000 to $3,500. This increase is being made in accordance with the recent Federal Acquisition Regulation (FAR) inflation adjustments. See http://www.gpo.gov/fdsys/pkg/FR-2015-07-02/pdf/2015-16206.pdf.

Federal Acquisition Regulation (FAR) Threshold Increases
The FAR inflation adjustments also resulted in increases to the (a) Cost or Pricing Data threshold (from $700,000 to $750,000), (b) Cost Accounting Standard threshold (from $700,000 to $750,000), and (c) Prime Contractor Subcontracting Plan (from $650,000 to $700,000). See http://www.gpo.gov/fdsys/pkg/FR-2015-07-02/pdf/2015-16206.pdf.

The above threshold increases only affect subcontracts/purchases made under federal prime contracts. Attachments 32(b), 32(c), and 32(d), reflect the above increases, which were made effective October 1, 2015.

Timeline for the Implementation of New Requirements for Purchases above $150,000
On October 29, 2014, RCUH made an announcement regarding the Federal Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Super Circular”). The announcement explained that the Super Circular (which became effective on December 26, 2014) allows for a grace period that defers the effective date of its new requirements for one full fiscal year, and that RCUH elected to take advantage of the grace period (which will end on June 30, 2016) with regard to certain requirements for purchases above $150,000.

It was recently announced in the Federal Register that a second year has been added to the grace period for certain requirements. Thus, the following will not be required until July 1, 2017:

1. Public Advertising: Under the Super Circular (2 CFR § 200.320), all IFBs and RFQs above $150,000 must be publicly advertised. The Super Circular does not define public advertising. RCUH will require that all IFBs/RFQs above $150,000 be posted on the State Procurement Office’s website. This is consistent with the existing practices of other state agencies, including UH. SuperQUOTE may still be utilized for solicitations, provided that the IFB/RFQ is posted on the State Procurement Office’s solicitation website and reference is made to the SuperQUOTE listing.
2. Sealed Bids/Quotes: Under the Super Circular (2 CFR § 200.320), all submitted bids and quotes above $150,000 must be kept sealed and confidential and must be opened publicly at the location/date/time indicated in the IFB or RFQ. Bids/quotes cannot be opened, even by project personnel, before the date/time specified in the solicitation. SuperQUOTE may still be utilized, provided that the bids/quotes obtained through SuperQUOTE are kept sealed and are not opened until the public opening date/time (we understand that UH and CommercePoint are working on this capability).
3. Independent Cost/Price Estimate: Under the Super Circular (2 CFR § 200.323), projects must make an independent cost/price estimate before going out for bid/quote for all purchases above $150,000. Documentation of this estimate must be kept in the procurement file. The estimate may take various forms, including (a) simple market research on similar goods or services, (b) comparison to previous or similar purchases, and (c) internally estimating the general range for the purchase price.

Questions may be directed to Erin H. Yoda at (808) 956-3969 or [email protected].