As previously mentioned in the Disaster Recovery Group (DRG) April 5, 2024, publication OMB Soon to Release Updates to Uniform Grant Regulations, the Office of Management and Budget (OMB) announced the impending launch of its revised regulations at Title 2 of the U.S. Code of Federal Regulations (2 C.F.R.), which will be effective for awards made on disasters declared on or after October 1, 2024.
But how exactly does this affect your FEMA award? Here is the Quick Bite:
- Procurement by States and Indian Tribes;
- 2 CFR 200.317 – Indian Tribes must now follow their own policies and procedures, in addition to §§ 200.321, 200.322, 200.323, and 200.327, just like states have been under the prior version of the regulation.
- Geographic Preferences;
- 2 C.F.R. 200.319(c) – Removed prohibition on geographic preferences.
- Procurement Methods;
- 2 C.F.R. 200.320(a)(2) – Changed the name of the "small purchases" method of procurement to simplified acquisitions.
- Socioeconomic Contracting;
- 2 C.F. R. 200.321 – Added "veteran-owned business" to the list of disadvantaged firms; and
- Recovered Materials;
- 2 C.F.R. 200.323 – Encouraged to procure items that can be reused, refurbished, or recycled; contain recycled content, are biobased, or are energy and water efficient; and are sustainable.
FEMA offers its Purchasing Under a FEMA Award: 2024 OMB Revisions Fact Sheet for additional guidance applicable to the procurement standards.
Should you have any questions or would like to update your procurement policy to reflect the updated OMB standards, please reach out to any member of Baker Donelson's Disaster Recovery and Government Services Team.