The County signed an agreement with a sub-recipient (a municipality) to use CDBG funds to construct a recreation center. If the sub-recipient already has or is going to obtain the service of an architect to design and oversee the construction of this center and is using its own non-CDBG funds to pay for the architect's service, does CDBG procurement policy apply in the obtaining of this architect's service?
Date Published: May 2015
Grantees and subrecipients are required to follow the procurement standards at 24 CFR 85.36 and 84.40-48, respectively. Specifically, since the subrecipient is a unit of general local government, it is required to follow 24 CFR 85.36, which requires all procurement transactions to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Since this is a federally assisted CDBG activity, the procurement of the architectural services must meet the requirements at 24 CFR 85.36, even though a portion of the activity is paid from local funds. Additional information on federal procurement standards may be found in CPD Notice 96-05.