FIU Implementation of OMB Uniform Guidance for Federal Awards

The Federal Office of Management and Budget (OMB) issued final guidance on administrative requirements, cost principles, and audit requirements for Federal awards (which includes research grant awards) in the Federal Register, on December 26, 2013.

Per the OMB this guidance “will supersede requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in 2 C.F.R. Parts 220, 225, 215, and 230); Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.”

The Uniform Guidance is also known as the Omni-Guidance, Supercircular and 2 CFR 200.

This website has been created as the focal clearing house for information regarding FIU’s implementation plans to ensure compliance with the Uniform Guidance which went into effect on December 26, 2014.

A link to the Uniform Guidance is available online at

Please note below changes effective July 1, 2018 that have a direct impact on existing and new projects:

Changes to the Quote Threshold

The implementation of the Uniform Guidance* Procurement Standards, 2 CFR 200.317-326, which are to be effective July 1, 2018 changes the threshold in which “quotes must be obtained from an adequate number of qualified sources” for purchases greater than 10K. If you are using a vendor outside of those in which FIU has an existing competitively solicited contract (such as those vendors that are in the myFIUmarket) or piggybacking on an existing contract that was competitively solicited and meets federal guidelines, you must obtain the required number of quotes as detailed below.

Modification of FIU’s quote thresholds
Current Effective July 1, 2018
$ Threshold # of Quotes $ Threshold # of Quotes
Less than $15,000 1 Less than $10,000 1
Equal to or greater than $15,000 and less than $75,000 3 Equal to or greater than $10,000 and less than $75,000 2
Equal to or greater than $75,000 Competitive Solicitation Equal to or greater than $75,000 Competitive Solicitation

For sponsored funds, the only exceptions to the above will be if an item is a sub-award to an outside entity (as the prime contract’s term and conditions flow through to the sub-recipient) and handled through a separate process through ORED or meet the criteria set forth in federal regulations and approved in advance of the order/service (sole source, emergency (lack of planning does not constitute emergency), sponsor approved non-competitive proposals, or after solicitation of a number of sources, competition is determined inadequate).

For all other University funds, in addition to the sole source, the University will continue to use the exemptions allowable under statute and those designated through an annual sole source certification.

Please attach the required number of quotes to a requisition prior to submission for approval.

Also, if an expense item is later requested to be transferred, in addition to the current University guidance related to transfers, the original method of procurement must be in compliance for the type of funding receiving the charge for the transfer to be approved.

All sole source requests over $10,000 will need to utilize the new Sole Source Request Form located on the Controller’s Website and the completed form must be attached to the requisition.

If you have any questions please contact your post award administrator, Tonja Moore or Kelly Loll, Procurement Director.

*The set of regulations on federal grant administration from the Office of Management and Budget (OMB) implemented in 2014