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πŸ“‹ Vendor Selection & Conflict of Interest

Extracted from Ohio EMA OSG Guidance, NSGP NOFO, and 2 CFR Part 200 β€” for grant procurement use

OSG (Ohio Security Grant) NSGP (NSGP-S & NSGP-NSS) πŸ“Š Procurement Process Guide
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Ohio Security Grant (OSG)

State-funded via Ohio EMA Β· Ohio Grants Partnership Β· ORC procurement rules apply

🎯 Vendor Selection Criteria
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OSG requires selecting the lowest responsible and responsive bidder for sealed bids, or the highest-scoring proposal when using an RFP with weighted criteria. Price alone is not always the deciding factor β€” qualifications and compliance matter.
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Total Price / Cost

Primary factor for sealed bids. For RFPs, price is weighted alongside technical criteria.

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Responsiveness to Specifications

Proposal must meet all minimum requirements in the RFP/RFQ. Non-responsive bids must be rejected.

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Vendor Experience & Qualifications

Demonstrated experience with similar security installations. References from comparable projects.

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Licenses & Certifications

Ohio contractor license, security systems license (ESA/NBFAA), relevant manufacturer certifications.

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Technical Approach

Proposed methodology, equipment quality, and installation plan match the scope of work.

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Timeline & Availability

Vendor can complete work within the grant performance period.

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Warranty & Service Terms

Equipment warranty (1–3 years minimum), ongoing maintenance/monitoring options.

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Insurance Coverage

General liability, workers' compensation, and bonding requirements verified.

Source: Ohio Grants Partnership Procurement Manual; Ohio Revised Code Β§153.012

🚫 Disqualifying Factors (Must Reject Bid)
  • Bid submitted after the stated deadline
  • Bid does not meet minimum technical specifications
  • Vendor is debarred or suspended from state/federal programs
  • Required certifications or insurance not provided
  • Bid is materially incomplete or unsigned
  • Vendor has an undisclosed conflict of interest with a decision-maker
βš–οΈ Conflict of Interest (COI) Requirements β€” OSG

⚠️ What Constitutes a Conflict of Interest

  • An employee, officer, or agent participates in selecting a vendor who employs or pays them personally
  • A decision-maker has a financial interest in a vendor (ownership stake, stock, profit-sharing)
  • A decision-maker or their immediate family member is employed by or owns the vendor
  • A vendor was involved in drafting the scope of work / specifications for the same procurement
  • A personal relationship that gives a vendor an unfair advantage in the evaluation
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Required Action: COI Certification All individuals involved in procurement decisions must sign a COI certification form. If a conflict is identified, the individual must be recused from all evaluation and award decisions β€” document the recusal in writing. Retain signed certifications in the grant file.
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NSGP β€” Federal Nonprofit Security Grant (NSGP-S & NSGP-NSS)

2 CFR Part 200 (Uniform Guidance) Β· NSGP-S via Ohio EMA  NSGP-NSS via FEMA GO

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NSGP-S and NSGP-NSS share identical vendor selection and COI requirements. Both are governed by 2 CFR Part 200. The only difference is the administrative channel: NSGP-S reimbursements and approvals go through Ohio EMA; NSGP-NSS goes directly through the FEMA GO system.
🎯 Vendor Selection Criteria β€” NSGP
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Per 2 CFR Β§200.318–200.327, all procurement must provide full and open competition. Selection must be based on documented, publicly stated criteria. Price is a primary factor.
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Price / Cost Reasonableness

Must determine price is reasonable. Competitive process establishes reasonableness by market comparison.

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Technical Responsiveness

Proposal must fully address all specifications. Non-responsive bids must be rejected per federal guidance.

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Vendor Responsibility

Financial stability, performance record, technical resources, and ability to meet the delivery schedule.

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Past Performance

References from similar projects. Government or nonprofit client experience preferred.

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Licenses & SAM.gov Eligibility

State licenses, bonding, insurance. Vendor must be active and not excluded in SAM.gov at time of award.

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Delivery / Performance Schedule

Work completable within grant performance period. EHP-related delays must be accounted for.

CriterionSuggested Weight (RFP)Sealed Bid
Total Price40–60%Primary (lowest wins)
Technical Approach & Specs Match20–30%Pass/Fail
Qualifications & Experience15–20%Pass/Fail
Timeline & Availability10–15%Pass/Fail
Warranty & Service5–10%Pass/Fail

Source: 2 CFR Β§200.318–200.327; FY2024 NSGP NOFO; Ohio EMA Subrecipient Procurement Guidelines

🚫 Prohibited Procurement Practices (Federal)
  • Restricting competition to a single vendor without adequate written justification
  • Using geographic preference as an evaluation criterion (e.g., "Ohio vendors only")
  • Awarding to a vendor on the federal debarment/suspension list (check SAM.gov)
  • Using a vendor who helped write the specifications (organizational conflict of interest)
  • Splitting purchases to stay below procurement thresholds (artificial splitting)
  • Procuring items not in the approved budget without prior EMA/FEMA approval
  • Beginning work before EHP approval is received in writing
βš–οΈ Conflict of Interest (COI) Requirements β€” NSGP
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Regulatory Basis: 2 CFR Β§200.318(c) "The non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts."

⚠️ Federal COI Definition

  • Any employee, officer, or agent participating in procurement has a real or apparent financial or personal interest in the award
  • A decision-maker or immediate family member holds an ownership interest (>5%) in a vendor being considered
  • A vendor offered, gave, or agreed to give anything of value to a grant employee in connection with the procurement
  • A subrecipient officer is also an officer, director, or employee of a vendor being considered
  • A vendor was involved in drafting the specifications, SOW, or evaluation criteria for the same procurement (organizational COI)
  • Any relationship that creates even the appearance of bias in vendor selection
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Required: Written COI Policy + Individual Certifications The organization must have a written COI policy. All procurement decision-makers must sign individual COI certifications before award. If a conflict is identified, the individual must be formally recused and the recusal documented in writing. Retain all COI documentation in the grant file.
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Reporting Requirement NSGP-S Report identified COI to Ohio EMA.
NSGP-NSS Report identified COI to your FEMA program officer in writing. Any post-award discovery may require contract rescission.
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Penalty for COI Violations Failure to properly identify and manage conflicts of interest can result in disallowed costs, award termination, and referral for investigation under federal law.
Quick Reference: COI Comparison
RequirementOSGNSGP-S & NSGP-NSS
Written COI PolicyRequiredRequired
Individual COI CertificationsRequiredRequired
Vendor-wrote-specs disqualificationBest PracticeRequired
SAM.gov debarment checkRecommendedRequired
Report COI to oversight agencyOhio EMA (if material)Ohio EMA (NSGP-S) / FEMA (NSGP-NSS)
Record retention3 years post-closeout3 years post-closeout