In response to recent updates to the Uniform Guidance, including changes to procurement thresholds, and findings from recent audit reviews of HRI contracting procedures, HRI has initiated a comprehensive refresh of its policies and procedures governing Purchase Orders, Contracts, and Subrecipient Agreements.
The objective of this update is to ensure that staff responsible for the use of grant funding have a clear understanding of Uniform Guidance procurement requirements and appropriate transaction types. This update also seeks to reduce requests for alternative or non-standard bidding processes by clearly defining acceptable options for vendor and subrecipient selection under federal and institutional requirements.
We will be offering training sessions later this month to review these updates in more detail. In the interim, this memo is being shared in advance to outline the nature of the changes and to encourage distribution to principal administrative and procurement staff, as appropriate.
Effective June 1, 2026, HRI has adopted:
- A revised Procurement & Subrecipient Policy, and
- A new HRI Decision Guide to support consistent, compliant, and efficient execution of procurement and subrecipient activities across the organization.
What Changed:
The prior Procurement Policy (General Purchasing Guidelines, last revised June 2023) included detailed procedures and procurement thresholds within the policy itself. The revised approach transitions to a higher-level governance framework that establishes overarching organizational requirements.
Operational procedures, approval workflows, and procurement thresholds have been removed from the formal policy and incorporated into the separate HRI Decision Guide and related administrative procedures. This structure allows for more agile updates in response to regulatory changes, sponsor requirements, and internal operational needs without requiring formal policy revision.
The Decision Guide will function as a living administrative document and will be updated as needed to remain aligned with Uniform Guidance (2 CFR 200), sponsor requirements, and institutional practices. As an example, the Decision Guide provides procurement staff with the latest federal threshold for public advertisement of procurement opportunities under the Uniform Guidance. The Decision Guide also includes an Appendix with most purchased items and the required backup documentation for each.
Key Procedural Updates (Phase 1)
In this first release of updates, the notable changes focus primarily on subrecipient agreements and include the following:
- Improved classification guidance to support more consistent determination of transaction type (Purchase Order, Contract, or Subrecipient Agreement).
- New pre-approval requirements for subrecipient agreements, including completion of an updated vendor responsibility questionnaire. HRI will accept OSC’s questionnaire in lieu of a separate HRI form to reduce administrative burden.
- Standardized forms for Single/Sole Source and non-competitive contract approvals.
- A refreshed Request for Applications (RFA) template and related competitive procurement tools.
- Updated subrecipient vouchering guidance to ensure standardized documentation and completeness of supporting materials.
- Our recently updated Attachment A HRI Boilerplate agreement.
Subrecipient Monitoring Program Updates
HRI’s Subrecipient Monitoring Program has also been significantly updated. Over the next year, the Compliance Unit will:
- Discontinue final voucher reviews for contracts ending after March 31, 2026.
- Transition to a risk-based monitoring model, conducting full-support reviews only where warranted by risk assessment.
- Conduct full-support reviews of the first voucher for all new subrecipients, and for selected continuing subrecipients. Guidance on notification procedures for subrecipients and Principal Investigators is under development.
- Increase audit frequency, with the goal of reviewing each subrecipient at least once every three years.
- Expand targeted training and technical assistance for program teams and subrecipients to strengthen compliance and financial management practices.
In subsequent phases, HRI will focus on refined procedures for securing professional contracted services including a new RFP template. All of these updates are intended to strengthen compliance with federal requirements, improve consistency in procurement and contracting practices, and ensure appropriate documentation is maintained for audit purposes. Updated guidance materials, templates, and procedures will continue to be made available at our Workday Documentation site, alongside Workday job aids and related resources. Principal Investigators and staff involved in procurement or contracting activities are encouraged to review these materials and incorporate the updated forms into new requests.
For questions regarding these updates, please contact subcon@healthresearch.org .
Sincerely,
Elizabeth Wood
Executive Director
Health Research, Inc.
150 Broadway, Ste. 280
Menands, NY 12204
