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:

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,...

Final Uniform Guidance Revisions Issued

Build America, Buy America: How BABA Impacts CAA Programs

Federal grant recipients such as Community Action Agencies (CAAs) working on public infrastructure projects will now need to ensure the supplies and materials they purchase are primarily manufactured in the United States. The Build America, Buy America Act (BABA, or Buy America) was enacted…