This sample procurement policy is intended to help Community Action Agencies (CAAs) comply with the federal rules and regulations related to procurement transactions. You should review this sample policy thoughtfully and modify it to meet the needs of your organization and to comply with any applicable laws and regulations. When using this sample to develop, review or update a procurement policy, CAPLAW strongly recommends that you consult with counsel familiar with your CAA’s operations and the laws of your state.

Every CAA operates differently, especially when it comes to procurement. The goals of this sample policy are:


  1. to provide a template that meets the basic requirements for a procurement policy under the Uniform Guidance, and
  2. to offer recommendations (referred to in the resource as Compliance Tips) for drafting and implementing a procurement policy that benefits, rather than burdens, CAA personnel and resources.

Related Resources:

2024 Final Uniform Guidance Revisions

2024 Final Uniform Guidance Revisions

On April 22, 2024, the federal Office of Management and Budget (OMB) published the final revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), 2 C.F.R. Part 200, in the Federal...

Final Uniform Guidance Revisions Issued

Final Uniform Guidance Revisions Issued

On April 4, 2024, the federal Office of Management and Budget (OMB) announced a draft version of the federal register notice releasing the final revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform...

Being Direct: Shared Cost Recovery through Direct Cost Allocation

Being Direct: Shared Cost Recovery through Direct Cost Allocation

When federally funded organizations incur shared costs that benefit multiple funding awards it can be difficult to determine how much to charge each award for those costs. Allowable methods of shared cost recovery vary, and organizations weigh factors such as size,...