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Adopt Policies and Procedures

Required Policies and Procedures

Before applying for a Library Services and Technology Act (LSTA) grant, all grant applicants must comply with federal Uniform Administrative Requirements for grants (2 CFR §200.300 -  §200.345).

This means that all applicants must have written:

  1. Cash management procedures that establish LSTA fund controls and accountability, including written procedures for determining the allowability of costs under the terms and conditions of the LSTA award (2 CFR §200.302(b)(6), §200.302(b)(7), §200.305).
  2. Bid and procurement procedures that establish standards and controls for the purchase of all goods and services, including written procedures for the evaluation of the proposals received and for selecting awardees (2 CFR §200.319(c), §200.320(d)(3)).
  3. Conflict of interest policy that governs the actions of its employees and board members who engage in the selection, award, and administration of contracts, including disciplinary actions if the policy is violated (2 CFR §200.318(c)).
  4. Travel policy (2 CFR §200.474(b)).
  5. Compensation and fringe benefit policy if any federal funds are used for compensation and fringe benefits (2 CFR §200.430(a), §200.431(a), §200.464 [Relocation Costs of Employees]).
  6. Indirect cost rate development procedures if an indirect cost rate other than 10 percent has been negotiated directly with the federal government. (2 CFR §200.414, §200.331(a)(4), Appendices).

Sample Policies

These sample policies are presented for reference purposes and not as legal advice.  When faced with a question concerning appropriate policies or about Uniform Administrative Requirements, grant applicants should seek the advice of their own legal counsel.

What are Uniform Administrative Requirements?

The federal Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Grant Guidance" or UGG) were officially implemented in 2014.

The Uniform Guidance reforms aim to reduce the administrative burden on award recipients and guard against the risk of waste and misuse of federal funds.

Read the full text of the OMB Uniform Guidance