When purchasing goods and services using Federal funds (see 2 CFR 200.318), recipients and subrecipients must have written policies and procedures to ensure these purchases are carried out in an effective manner and adhere to general procurement standards (see 2 CFR 200.318). Recipients and subrecipients must maintain written standards of conduct covering actual and perceived conflicts of interest regarding the decisions made during the procurement process.
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To ensure established procurement procedures are followed, recipients and subrecipients should routinely examine their internal controls and checks and balances to verify procurement rules are followed. For more guidance on procuring subcontractors and contractors, see SNAPS-Shots: Using Contractors in the ESG and CoC Programs.