OHS Clarifies Term of Prior Approval Waivers 

May 11, 2022

The Office of Head Start has issued a correction to ACF-IM-HS-21-01, which updated several fiscal and administrative flexibilities available to Head Start grantees under OMB M-21-20 Appendix 3 – Disaster Relief Flexibilities to Reduce Burden for Financial Assistance. ACF-IM-HS-21-01 previously indicated that the flexibilities would be in effect between January 1, 2021 and December 31, 2021, but the memorandum has been revised to reflect that the following flexibilities remain in effect until OMB memorandum M-21-20 expires or is rescinded: 

• Purchase of equipment (45 CFR §75.308(c)(1)(xi)). Grantees may purchase equipment needed to respond to COVID-19 with a value of up to $25,000 without prior ACF approval. 
• Budget modifications (45 CFR §75.308(e)). To allow grantees more flexibility to spend funds as needed to respond to COVID-19 and, when possible, quickly move to reopen closed centers, prior approval is waived for budget transfers between direct cost categories for an aggregate amount not to exceed $1 million. 
• Procurement by noncompetitive proposals (45 CFR §75.329(f)(2)). OHS recognizes that COVID-19 has created a public emergency for all grantees. Competitive solicitations may result in delays that impair a grantee's ability to respond to or recover from COVID-19. OHS is authorizing grantees to engage in sole-source purchasing to obtain goods and services needed for COVID-19 response and recovery. 

For more information on the other fiscal and administrative flexibilities discussed in ACF-IM-HS-21-01, which remain unchanged, see this CAPLAW enews brief. 

This news flash is part of the Community Services Block Grant (CSBG) Legal Training and Technical Assistance (T/TA) Center. It was created by Community Action Program Legal Services, Inc. (CAPLAW) in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services Cooperative Agreement – Award Number 90ET0467-03-C3. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.

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