Uniform Guidance FAQ

Uniform Guidance Procurement Policy FAQ

Occasionally contracting with an individual is necessary. Typically, this is NOT going to be a sole source because it is nearly impossible to justify that one person is the ONLY person in the world that can perform the requested service. Most of the time, the best that can be justified is that they are “best” qualified, which is not a legitimate sole source justification. However, if an individual is REQUIRED based on qualifications they have, a sole source may be justified. The key to a successful justification is to explain in detail the required qualifications – why we need someone with that specific qualification and how we know this is the only supplier with this qualification. Supporting they are the only supplier could include: LinkedIn searches, other professional websites, etc.

The procurement policy only applies to single purchases that exceed the threshold(s).

Example 1:
Professor X is fabricating a piece of equipment with three parts. Part A: $1,000 Part B: $3,500* Part C: $15,500. Even though the total amount of the equipment is >$10,000 and will be capitalized, only Part C is subject to the Small Purchase Threshold policy. Parts A and B do not require additional quotes but must be reasonable purchases.

Example 2:
Professor Y is fabricating a piece of equipment with three parts. Part A: $3,000* Part B: $4,000* Part C: $4,500*. Even through the total amount of the fabricated equipment is >$10,000 and will be capitalized, none of the parts are subject to the Small Purchase Threshold policy as the single purchases do not exceed $10,000.

Per review of sponsor websites it was determined seeking sponsor approval still required the University to support one of the other acceptable methods of sole source justification. Based on support provided to PSO for sole source jusification a determination will be made at that point if sponsor approval is required.

If the sponsor is requiring specific goods or services in order to receive the grant, this would be an acceptable sole source under UG. Below are examples of acceptable sole source justifications for this situation:

  1. Chris Consultant is needed to assist with my research, which must be completed within the next 6 months. He is familiar with this type of work and one of the best in the world. I have reached out to the 5 top experts in the field and Chris is the only one that can commit to providing their services within my allotted timeline.
  2. Chris Consultant is needed to assist with my research. He is world class in his field. He is also familiar with XYZ. Chris is the only world class expert who is familiar with the intersection of these two subjects. No other supplier has this unique combination of knowledge/skill set.

Provide supporting documentation showing the research done to support the claim.

No. Price is never a justification for a sole source. If under $250,000 you can obtain 2 other quotes, if the value is over $250,000 a formal RFP will need to be issued.

Assuming that a legitimate solicitation open to all potential vendors was attempted and documented that contained specifications/scope of work that were not considered “lockout” specs, this would be acceptable under Uniform Guidance.

The procurement office will review and retain all bids related to purchases on federal projects for the applicable record retention policy.

Not under Uniform Guidance. The Uniform Guidance exemption requires both (1) a written request by the grantee, and (2) for the funding agency to “expressly authorize” approval of that request. A simple approval of a proposal without any express allowance, and no mention of the non-competitive procurement in the original procurement does not fit those criteria.

Yes, RIT's list of preferred vendors, where price/bidding has already been performed by PSO can be utilized. If your vendor is not on the list, please contact PSO.