The Region 6 Education Service Center (ESC6) is a Texas Education Service Center which operates EPIC6, a purchasing cooperative and department of the ESC6. The ESC6 and EPIC6 has made every effort to comply with the most restrictive requirements of 2 CFR 200, identified for educational purposes as the Education Department General Administrative Regulations (EDGAR). EPIC6 certifies that it procures all awarded agreements/contracts pursuant to § 44.031 of the Texas Education Code, or Texas Government Code § 2269, as applicable, the most restrictive procurement method, and performs the most restrictive procurement method required by law and regulation, including all of the necessary steps outlined in 2 CFR 200, except the Price or Cost Analysis for purchases of $250,000 and greater.
EPIC6 Information on Member Entities Purchasing Goods and Services using Federal Funds
EPIC6 is often asked if our agreements/contracts are compliant with the Code of Federal Regulations procurement requirements (2 CFR Part 200). These regulations are created by the federal government to regulate the procurement processes of federal agencies, the pass-through state agencies, and the individual local government entities receiving federal funds through the agencies responsible for the distribution of those funds for the benefit of the end-user entities. The funds are commonly granted to the local entities by the Cares Act and ESSER, US Dept. of Education, Housing and Urban Development, FEMA, US Dept. or Agriculture (school child nutrition) and other federal agencies. The funds are typically sent to the state agencies that act as pass-through agencies to distribute the funds to local governmental entities such as school districts (EDGAR), cities, counties, etc. and monitor the use of the funds for compliance with the federal regulations. When a school, city, county or other entity purchases goods and services with the respective funds, there are steps, certifications, contract clauses and other accountability issues that go into the proper use of the funds. EPIC6 can provide documentation of the awarded vendor’s responses to our solicitations that will provide evidence of the scope of the vendor’s agreement with the federal requirements included in the EPIC6 solicitation.
Multiple Regulations and Rules
The various federal agencies that grant and distribute funds to entities eligible to use EPIC6 vendor agreements all interpret the 2 CFR Part 200 differently and the federal agencies distributing the funds have the authority to add additional, more restrictive requirements, as they deem appropriate. Also, the pass-through state agencies that distribute and monitor the use of the funds may add additional, more restrictive rules, on the funds use and the processes that the end-user entity must follow when expending those funds. Then, the local EPIC6 Member entity may add their own additional more restrictive procurement rules or policies. Thus the rules for use quite literally, can be different for each end-user entity.