CDBG Entitlement FAQ

Are we able to piggyback on an existing contract for the purchase of equipment less than $100,000? City regulations allow piggybacking and the contract being piggybacked on has been procured through a competitive process which included federal procurement language.

Date Published: May 2015

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Piggybacking in this case refers to using the results of another CDBG grantee's procurement for equipment after-the-fact, rather than the City conducting its own procurement. A grantee may not piggyback another grantee's procurement of a contract for goods and services. HUD lays out the responsibilities that grantees must meet when conducting a procurement using federal funds in 24 CFR 85.36. While 85.36 encourages intergovernmental agreements for the procurement of common goods and services (defined as standard commercial equipment, materials, supplies and services readily obtainable on the open market through conventional commercial marketing channels), procurement activities by entitlement grantees must still be conducted in accordance with the requirements of 24 CFR 85.36(b). As States and units of general local government are subject to different procurement standards, there is no presumption that a state agency's or unit of government's procurement standards will conform to 85.36(b). The grantee must follow the procurement requirements, in accordance with 24 CFR 85.36(b), even if in the end the result is that the same contractor is selected.

Tags: CDBG Entitlement Program Procurement