In the 2024 updates to the Uniform Guidance, the OMB clarified a variety of documentation requirements while also adding some new ones. Some of the notable changes and clarifications regarding documentation include:

• Trafficking in persons: A compliance plan to prevent agents, subrecipients, contractors, or subcontractors from engaging in trafficking in persons must be maintained.
• Micro-purchases: Evidence that price reasonableness analysis was performed.
• Noncompetitive procurements: Written approval from a federal agency or pass-through entity when sole sourcing goods or services.
• Subrecipient monitoring: Evidence that corrective actions were taken on significant developments and that all issues were resolved.

These are in addition to the extensive list of existing documentation already required under the Uniform Guidance.

So What Should You Do?

Now is a great time to review your current documentation processes to ensure you comply with existing requirements and prepare for the new ones that roll out on October 1.Things you should be doing include:

• Map procedures: Map procedures to the updated requirements to you are capturing all required documentation, and clear roles have been established so employees know what is expected.
• Review forms & templates: Assess forms, templates, and questionnaires to ensure they capture all required information.
• Assess your technology: Assess procurement and grants management systems to update data capture and ensure you have audit-ready documentation.

How Vendor Centric Can Help.

Vendor Centric offers a comprehensive suite of software and services to streamline workflow and strengthen controls to ensure documentation compliance.

Schedule a call to discuss how we can help.