Grant Compliance

Common Mistake: Emergency Contracting

Detailed Discussion

Common Mistake: Emergency Contracting

A common mistake Applicants make in procurement and contracting is related to emergency contracting and noncompetitive procurement.

Common Mistakes

  • Engaging in noncompetitive procurement (i.e., sole-sourcing) without carefully documenting how the situation has created an urgent need to perform the work sooner than a competitive procurement process would allow
  • Continuing work under a sole-source contract after the urgent need has ended, instead of transitioning to a competitively procured contract
  • Piggybacking onto another jurisdiction's contract in a situation that does not allow noncompetitive procurement or where the other contract is materially different in terms of scope or requirements

Avoidance Strategy

State governors, Tribal officials and local officials cannot waive Federal procurement standards. Therefore, even during a governor-declared state of emergency, Recipients and Applicants must remember to follow Federal regulations regarding noncompetitive procurement. This includes ensuring exigent or emergency conditions are met and maintaining proper documentation. Failure to comply with Federal procurement standards may jeopardize grant funding.


Related Guidance Categories

This website  is intended as a national source of information about  the delivery of  financial recovery services. It includes resources on eligibility, procurement, grant management delivery, and issues related to various Federal Programs currently supporting FEMA  Public Assistance program  financial recovery for governments and non-profits. This website is not affiliated or endorsed or sponsored  by  FEMA  or any other Federal grant program. The information provided in various webpage documents is derived largely from Federal  published materials. In general, under section 105 of the Copyright Act, such works are not entitled to domestic copyright protection under U.S. law and are therefore in the public domain.  The goal is to help navigate the various Federal websites and summarize grant information and requirements. It does not constitute legal advice or grant management advise and is provided for general informational purposes only. Only the Federal Agency responsible for grants can make determinations on eligibility and grant amounts. You should consult with your professional services advisors and State and Federal Grant Coordinators for more detailed guidance on specific FEMA Public Assistance financial recovery issues.

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