Procurement & Contracting

Review FEMA Public Assistance procurement and contracting requirements, including competition, procurement method, contract type, cost reasonableness, change orders, and required federal contract provisions.

Procurement & Contracting Subcategories

FEMA procurement compliance should be organized around the federal procurement standards, the FEMA Procurement Under Grants Policy Guide, the Public Assistance Program and Policy Guide, and the applicant’s own documented procurement procedures. This structure helps applicants connect competition, procurement method, contract type, cost reasonableness, required clauses, documentation, and audit defense before FEMA or OIG review.

Applicability & Entity Type

Determines which procurement rules apply based on whether the applicant is a state, Indian Tribe, local government, private nonprofit, institution, hospital, special district, or other eligible entity using FEMA financial assistance.

General Procurement Standards

Covers the baseline procurement controls, including documented procedures, oversight, written standards of conduct, gift restrictions, conflicts of interest, need determination, contractor responsibility, recordkeeping, and time-and-materials controls.

Competition & Conflict Controls

Addresses full and open competition, restrictive requirements, unfair competitive advantage, organizational conflicts of interest, double dipping, brand-name restrictions, prequalified lists, and actions that may improperly limit competition.

Methods of Procurement

Organizes the approved procurement methods, including micro-purchases, simplified acquisitions, sealed bidding, competitive proposals, and noncompetitive procurement when allowed under emergency, exigency, single-source, inadequate competition, or approval-based circumstances.

Contract Type, Cost & Price Analysis

Reviews contract payment structures, fixed-price contracts, cost-reimbursement contracts, time-and-materials contracts, ceiling-price requirements, price analysis, cost analysis, cost reasonableness, and prohibited cost-plus-percentage-of-cost arrangements.

Contracting Requirements & Required Provisions

Covers contract administration, remedies, termination clauses, suspension and debarment, access to records, federal contract provisions, bonding requirements, domestic preferences, telecommunications restrictions, and other clauses required for federally funded contracts.

Special Procurement Considerations

Addresses cooperative purchasing, piggybacking, joint procurements, prepositioned contracts, purchasing agents, mutual aid agreements, construction delivery methods, architecture and engineering services, Build America Buy America, and procurement of recovered materials.

Documentation, Audit Risk & Remedies

Focuses on the procurement file needed to defend FEMA funding, including rationale for the procurement method, contract type, contractor selection or rejection, price basis, modifications, oversight records, protests, disputes, closeout documentation, and remedies for noncompliance.