Chapter 6 › X.B Procurement and Contracting Requirements for Local Government Agencies and Private Nonprofit Organizations

What procurement rules do local governments and nonprofits have to follow?

FEMA term

Federal procurement standards (2 CFR 200.318–200.327)

Short answer

You must follow your own written procurement procedures, your state and local laws, and the federal rules in 2 CFR 200.318–200.327, using whichever is most restrictive. If you don’t comply, FEMA can deny all contract costs or pay only the portion it finds reasonable.

What FEMA requires

Full and open competition, using one of five methods: micro-purchase, small purchase, sealed bid, competitive proposal, or noncompetitive proposal.
A cost or price analysis for every procurement above the simplified acquisition threshold ($250,000 at publication), including modifications, with an independent estimate before receiving bids.
Steps to include small, minority, women-owned and veteran-owned businesses and labor surplus area firms.
Documented review of the contractor’s integrity, past performance and resources, and confirmation that it is not suspended or debarred.
Exclusion of contractors that helped write the specifications.
Records of the procurement history: method, contract type, selection or rejection, and the basis for the price.
Written standards of conduct covering conflicts of interest.

Documentation

Your procurement policy, solicitations, bids, selection documentation, cost or price analysis, contracts, change orders and invoices. Source: PAPPG Table 15.

Watch out · Govstar practitioner advice

A prequalified contractor list is not a contract. You still have to compete the work, and you can’t exclude firms that weren’t on the list.

Govstar summarizes FEMA’s Public Assistance Program and Policy Guide in plain language and links to the official text. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.