Management will implement enhanced procurement controls to strengthen competition, documentation, and justification for procurements to ensure compliance with 2 CFR 200 and internal policy. Actions include: 1. Effective January 1, 2026, Rebuilding Together adopted a revised Procurement Policy that u...
Management will implement enhanced procurement controls to strengthen competition, documentation, and justification for procurements to ensure compliance with 2 CFR 200 and internal policy. Actions include: 1. Effective January 1, 2026, Rebuilding Together adopted a revised Procurement Policy that updates procurement thresholds and outlined the standard for non-competitive procurement, requiring that sole-source determinations meet one of the specific allowable criteria under 2 CFR §200.320(c). 2. Rebuilding Together will further update the Procurement Policy to require that for noncompetitive procurements, management will prepare and retain contemporaneous written justification in the form of a sole-source justification memo demonstrating that the procurement meets one of the allowable criteria under 2 CFR §200.320(c), supported by appropriate documentation such as market research or evidence of exclusivity. The sole-source justification memo will be reviewed and approved by a manager senior to the staff member leading the procurement before the determination is finalized. 3. Rebuilding Together has developed standardized Micro-Purchase and Small-Purchase Procurement Memo templates that require documentation, at the time of procurement, of vendor selection rationale, price/cost reasonableness, competitive quotes obtained (as applicable), conflict-of-interest certification, and debarment/suspension verification. 4. Rebuilding Together is finalizing a Speaker Procurement SOP, which provides speaker-specific procurement guidance in accordance with 2 CFR 200. 5. Relevant staff (Development, Development Operations, Network Advancement, Communications, Grant Operations, and Finance) will receive training on the revised Procurement Policy and Speaker Procurement SOP. Anticipated Completion Date: The revised Procurement Policy became effective January 1, 2026. Additional edits to the Policy will be made implemented by September 15, 2026. Finalization of the Speaker Procurement SOP and related staff training are anticipated to be completed by December 31, 2026. Responsible Contact Person: Emma Weltzer, Director, Development Operations & Federal Grants