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2026-010 - Adopting Procurement Policies and Procedures for Federal Grant Contracts
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2026-010 - Adopting Procurement Policies and Procedures for Federal Grant Contracts
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2/10/2026 9:24:04 AM
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2/10/2026 9:23:45 AM
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CITY CLERK
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EXHIBIT'A' <br />PROCUREMENT POLICY APPLICABLE TO ALL PROCUREMENTS MADE WITH <br />FEDERALFUNDS <br />FIMPT832111801AN-311 0M <br />THE CITY WILL USE DOCUMENTED PROCUREMENT PROCEDURES IN ACCORDANCE WITH ALL APPLICABLE FEDERAL, <br />STATE, AND LOCAL GOVERNMENT STATUTES AND REGULATIONS, INCLUDING THE UNIFORM ADMINISTRATIVE <br />REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, PER 2 CFR 200.318 <br />THROUGH 2 CFR 200.327. <br />PROCUREMENT STANDARDS FOR FEDERAL GRANT AWARDS <br />§ 200.318 General Procurement Standards. <br />(a) Documented procurement procedures. The city must maintain and use documented procedures for <br />procurement transactions under a federal award or subaward, including for acquisition of property <br />or services. These documented procurement procedures must be consistent with State, local, and <br />tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. <br />(b) Oversight of contractors. Recipients and subrecipients must maintain oversight to ensure that <br />contractors perform in accordance with the terms, conditions, and specifications of their contracts <br />or purchase orders. See also § 200.501(h). <br />(c) Conflicts of interest. <br />I. The city must maintain written standards of conduct covering conflicts of interest and <br />governing the actions of its employees engaged in the selection, award, and administration <br />of contracts. No employee, officer, agent, or board member with a real or apparent conflict <br />of interest may participate in the selection, award, or administration of a contract supported <br />by the Federal award. A conflict of interest includes when the employee, officer, agent, or <br />board member, any member of their immediate family, their partner, or an organization that <br />employs or is about to employ any of the parties indicated herein, has a financial or other <br />interest in or a tangible personal benefit from an entity considered for a contract. An <br />employee, officer, agent, and board member of the city may neither solicit nor accept <br />gratuities, favors, or anything of monetary value from contractors. <br />However, the city may set standards for situations where the financial interest is not <br />substantial, or a gift is an unsolicited item of nominal value. The recipient's or subrecipient's <br />standards of conduct must also provide for disciplinary actions to be applied for violations <br />by its employees, officers, agents, or board members. <br />2. If the city has a parent, affiliate, or subsidiary organization that is not a State, local <br />government, or Indian Tribe, the city must also maintain written standards of conduct <br />covering organizational conflicts of interest. Organizational conflicts of interest mean that <br />because of relationships with a parent company, affiliate, or subsidiary organization, the city <br />is unable or appears to be unable to be impartial in conducting a procurement action <br />involving a related organization. <br />(d) Avoidance of unnecessary or duplicative items. The recipient's or subrecipient's procedures must <br />avoid the acquisition of unnecessary or duplicative items. Consideration should be given to <br />consolidating or breaking out procurements to obtain a more economical purchase. When <br />appropriate, an analysis should be made between leasing and purchasing property or equipment to <br />determine the most economical approach. <br />(e) Procurement arrangements using strategic sourcing. When appropriate for the procurement or use <br />of common or shared goods and services, recipients and subrecipients are encouraged to enter into <br />State and local intergovernmental agreements or inter -entity agreements for procurement <br />
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