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Written Procurement Policies <br />The subgrantee shall have written procurement procedures and may adopt by reference <br />procedural requirements of 2 CFR Part 200 or applicable federal law. <br />Procurement Guidelines <br />KTB, in reviewing subgrantee procurement procedures and policies, will determine <br />consistency with 2 CFR Part 200 or the applicable federal law regulating procurement. Stated <br />therein are the governing regulations and implementing guidelines for all procurement activity <br />undertaken with grant funds. Some of those items, with particular applicability to KTB grants, <br />are: <br />• Subgrantees will maintain a contract administration system which ensures that contractors <br />perform in accordance with the terms, conditions, and specifications of their contracts or <br />purchase orders. <br />• Procedures will allow for analysis of the most economical approach in purchasing, <br />including lease versus purchase alternatives. Each proposed procurement must be <br />reviewed to avoid the purchase of unnecessary or duplicative items. <br />• Subgrantees will make awards only to responsible contractors possessing the ability to <br />perform successfully under the terms and conditions of a proposed procurement. <br />Consideration will be given to such matters as contractor integrity, compliance with public <br />policy, record of past performance, and financial and technical resources. <br />• Subgrantees will maintain records sufficient to detail the significant history of procurement. <br />• These standards do not relieve the subgrantee of any contractual responsibilities under its <br />KTB contracts. The subgrantee is responsible, in accordance with good administrative <br />practice and sound business judgment, for the settlement of all contractual administrative <br />issues arising out of any procurement entered in support of a KTB grant. These include, <br />but are not limited to, source evaluation, protests, disputes, and claims. <br />Subgrantee Files <br />Each subgrantee must maintain adequate files to support any purchases made. A copy of the <br />quotes that were obtained (purchases between $3,000.00 and $150,000.00) or a copy of the <br />legal notice must also be on file to support the choice of lowest and/or best bid. The <br />subgrantee must provide adequate justification if the purchase is not awarded to lowest and/or <br />best bidder. <br />Method of Procurement' <br />All procurement transactions shall be made by one of the following methods. KTB reserves <br />the right to request any and all documentation, either in advance or upon completion of <br />procurement activities, as deemed necessary. <br />1. PROCUREMENT BY SMALL PURCHASE PROCEDURES <br />For procurement of services, supplies, or other property with an aggregate cost under <br />$150,0003, written price or rate quotations shall be obtained from at least two qualified <br />sources. The aggregate sum of all items being purchased is considered one purchase. <br />Purchases equal to or under $3,000- Purchases which do not involve the expenditure of <br />more than $3,000, exclusive of freight or shipping charges, may be made without <br />advertising or otherwise requesting competitive quotes; provided, however, that nothing <br />contained in this paragraph shall be construed to prohibit any agency or governing <br />2Explicit federal and State regulations apply to each procurement method. Subgrantees may proceed with procurement <br />activities only after careful study of the regulations reveals all requirements have been met. <br />3 This purchase threshold is to be utilized for subgrantee procurements with federal funds. Separate thresholds may be <br />permitted or required under state law for state funded grants. <br />Memorandum of Understanding Page <br />