Updating your organization’s procurement policies is crucial for complying with the 2024 Uniform Guidance. However, crafting compliant policy language that’s easy to understand and actionable can be challenging.

In my 20+ years of writing policies, I’ve learned that effective policy writing is as much an art as a science. Below are six best practices I’ve learned over the years to help you create practical, clear, and compliant procurement policies.

1. Use Clear and Simple Language

A common pitfall in policy writing is using jargon and complex legal terms. While technical language might seem necessary, it often creates confusion and hinders compliance. Instead, use plain language that everyone in your organization can easily understand.

Example:

• Complex version: “Employees, officers, agents, and board members must refrain from engaging in any activity that could be perceived as an actual or potential conflict of interest, as outlined in Section 11, Part B, Paragraph 3, when procuring goods, services, or any other items from contractors whose professional interests may conflict with the organization's financial or reputational objectives.”
• Simplified version: “Employees, officers, agents, and board members must avoid any actions that could create a conflict of interest when procuring goods and services from contractors.”

2. Be Concise

Procurement policies should be as brief as possible while still conveying all necessary information. Lengthy, detailed policies are more likely to be skimmed or misunderstood. Focus on the essentials and cut out anything that may confuse or overwhelm the reader.

Example:

• Bloated version: “In the event that any employee, contractor, or other personnel engaged in the procurement process needs to submit a request for purchase, such a request must be made in accordance with the policies and procedures outlined in the procurement manual and must be submitted in writing and include all required supporting documentation.”
• Concise version: “Purchasers must submit purchase requests, in writing, with all required documentation as defined in the procurement manual.”

3. Organize Logically

A well-organized policy document is easier to follow. Use clear headings, subheadings, and bullet points to structure your content, allowing readers to find specific sections and follow the flow of information. Policies should also follow the natural flow of the procurement process and include a table of contents to help with navigation.

Example Table of Contents:

• Introduction
• Planning & Requirements Development
• Procurement Methods (Micro-purchases, Sealed Bids, RFPs)
• Due Diligence & Risk Assessment
• Contracting
• Ongoing Management & Performance Monitoring
• Termination & Offboarding

4. Include One-Sentence Definitions

Even with plain language, certain terms or acronyms may be necessary. Include a definitions section at the beginning of your policy document to ensure everyone is on the same page.

Example:

Contractor: Vendors, suppliers, independent contractors, and other third-party entities provide goods or services to the organization that are not considered subrecipients.

5. Socialize for Feedback

Before finalizing your policies, gather feedback from different areas of your organization to ensure the document is practical and user-friendly from multiple perspectives. Input from various departments can highlight areas for improvement and ensure alignment with cross-departmental policies.

Pro Tip: Form a policy review committee with representatives from departments such as finance, legal, and operations. This collaborative approach helps create well-rounded, practical policies that work across the organization.

6. Consult Your Auditors

The Uniform Guidance offers flexibility for organizations to tailor their policies to their specific needs. However, this can sometimes create ambiguity. A best practice is to consult with your external auditors during policy drafting. While they won’t make policy decisions for you, they can offer valuable insights into compliance expectations.

Pro Tip: Schedule a brief meeting with your auditors before finalizing major updates. Their feedback can help you avoid potential audit findings by ensuring your policies align with their expectations.

Final Thoughts

While it’s tempting to account for every possible scenario in your policies, it's best to keep them high-level and provide flexibility for handling nuances. This approach ensures your organization can adapt while maintaining the necessary controls.

By following these tips, you’ll create clear, concise, and compliant policies—keeping your organization on track with the 2024 Uniform Guidance.

Vendor Centric Makes Policy Development Easy

At Vendor Centric, we specialize in helping nonprofits navigate the complexities of the Uniform Guidance. Schedule a complimentary consultation with us today if you need assistance developing or refining your procurement policies.