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Document Code No.: CON-7-8-1-EP
Affected Agencies: All departments, offices and agencies of King County government
Sponsoring Agency: DES / FBOD / Procurement and Payables Section
Effective Date: April 3, 2018
Expiration Date: April 2, 2023
Type of Action: Supersedes CON 7-8 (AP), May 6, 1994

Signed document (PDF, 235KB)


  1. Purpose

    This policy provides the requirement to comply with federal regulations and federal grant guidelines regarding the use of federal funds in purchase orders/contracts to County vendor/contractors.

  2. Applicability and Audience

    This policy applies to
    all King County offices, departments, officials, employees, boards, commissions, committees, or similar entities as well as contractors and grantees.

  3. Definitions

    “Debarred Vendor” means a firm and/or an individual debarred and/or a contractor excluded from providing goods and/or services for federal award programs which are listed in the GSA Office of Acquisition Policy.

    “Federal Funds” means those federal grants, awards, or funds, provided to County agencies and/or subcontractors via federal indirect or direct awards.

    “Suspended and Debarred List” means those individuals and/or firms excluded from providing goods and/or services for any federal programs.

    “Covered Transaction” means a non-procurement or procurement transaction that is subject to the prohibitions outlines in Title 2, Code of Federal Regulations, Part 180.

  4. Background

    In 2014, the Federal Government implemented Uniform Guidance, also known as 2 CFR 200, which governs applying for, obtaining, sub-awarding, spending, monitoring and reporting of Federal Financial Assistance. This policy addresses the following procurement requirements for the use of Federal Funds:

    • Established thresholds for spending federal dollars – 2 CFR 200.317-326

    • Suspension and Debarment of Suppliers and sub grantees – 2 CFR 180

    • The Davis-Bacon Act in regards to Prevailing Wages - - 40 USC 3141-3144, 3146 and 3147

      Additional information regarding the use of federal funds can be found under Policies, Orders and Public Rules under FIN 16-1: Accounting, Reporting and Management of Grants and Other Financial Assistance.

  5. Policy

    1. Procurement thresholds if using Federal Dollars

      1.   County agencies (Grantee and or Subgrantee Agency) using federal funds to obtain goods or services will do so in compliance with federal grant guidelines and federal regulations. When applying thresholds to purchases made with federal funds, the more restrictive threshold (Federal, State or King County) applies.

      1. Micro Purchase- $3,500 or less ($2,000 Public Works). This threshold applies to supplies or services (aggregate amount). To the extent practicable, King County agencies must distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if King County considers the price to be reasonable. The Federal threshold is more restrictive than King County’s $10,000 threshold. Therefore, the Federal threshold will be used for Micro Purchases.

        This limit is established in 48 CFR Part 2.1 (Definitions) and is periodically adjusted for inflation. 

      2. Small Purchase/ 3 Quote Purchase- $150,000 or less. This threshold applies to services, supplies or other property. The procurement will require price or rate quotations.

        King County’s threshold for this procurement method is $50,000. As such, the King County threshold shall be used for small/three quote purchases.

      3. Sealed Bids- $150,000 or more. This threshold applies to services, supplies or other property as appropriate. The procurement uses a formal solicitation process with a firm fixed price contract awarded to responsive bidder.

        King County’s threshold for this procurement method begins at $50,000 and will be used for this process.

      4. Competitive Proposals for Services- $150,000 or more. This threshold applies when sealed bids are not appropriate, where price must be considered as a factor. This procurement process must have more than one source submitting an offer, and either a fixed price or cost-reimbursement type contract is awarded.

      5. Competitive Proposals for Architectural/Engineering (A/E) Services- No dollar threshold. A/E services are to be procured through a qualifications-based competitive proposal process where price is not a factor in determining award. This procurement method must have more than one source submitting an offer, and either a fixed price or cost-reimbursement type contract awarded.

      6. Sealed Bids for Construction - When federal funds finance more than $2,000 of a construction contract, in accordance with the Davis-Bacon and Related Acts, contractors and subcontractors must pay their laborers and mechanics employed under the contract no less than the locally prevailing wages and fringe benefits for corresponding work on similar projects in the area.  The Davis-Bacon Act applies to contractors and subcontractors performing work on federal contracts.

        In Washington State, public works projects are subject to state prevailing wages set by the Department of Labor and Industries (L & I). The higher of the two rates (state/federal) must be paid for each worker classification.

    2. Use of Federal Funds

      1.   County agencies awarded federal assistance shall ensure that their sub-grantees and subcontractors obtain goods and/or services with federal funds only in compliance with federal regulations.

      2.   County agencies utilizing Procurement & Payables (P&P) to obtain goods and/or services with federal funding shall inform P&P that federal funds will be used for the acquisition.

      3.   County agencies shall not procure goods or services from federally suspended or debarred vendors when using federal funds.

      4.   County agencies must abide by the procurement standards noted in 2 CFR 200 Sections 317- 324. 

    3. Suspension and Debarment

      1.   When Federal Funds are involved, county agencies may not contract with or make sub-awards under covered transactions to parties that are suspended or debarred.

      2.  Before entering into a covered transaction, county agencies must verify that the party involved is not excluded or disqualified by performing one of these procedures:

      1. Search the Suspended and Debarred List by using the Excluded Parties Lists System (EPLS) found at www.sam.gov and document findings, and

      2. Collect a certification from that person, or

      3. Add a clause or condition to the covered transaction with that person.

  6. Implementation Plan

    1. This policy became effective January 1, 2018. Uniform Guidance became effective for county agencies the fiscal year after it was adopted on December 26, 2014.A portion of the Uniform Guidance implementation was deferred as the federal government gave agencies an additional three fiscal years to adopt the procurement standards in 2 CFR 200.317-326. The Finance and Business Operations Division (FBOD) is responsible for implementation of this policy.

    2. FBOD is responsible for communicating this policy to the management structure within the respective agencies and other appropriate parties.

  7. Maintenance

    1. This policy will be maintained by FBOD, or its successor agency.

    2. This policy will automatically expire five (5) years after its effective date. A new,  revised, or renewed policy will be initiated by FBOD, or its successor agency prior to the expiration date.

  8. Consequences for Noncompliance

If a grantee agency has been found by an auditing authority to be in violation of federal procurement policies, the federal granting authority may no longer grant funds, to that agency and the agency may have to pay back all disallowed costs.


Appendices:

Procurement Guidelines for Federal Spending (see PDF scan of the policy).