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If any litigation, claim, or audit is started before the end of the three year period, you must retain the records until all litigation, claims, or audit findings involving the records have been resolved and final action taken. IMLS, the Comptroller General of the United States, and any of their duly authorized representatives, have the right of access to any pertinent books, documents, papers, and records to make audits, examinations, excerpts, transcripts, and copies. Further, any contract you negotiate in excess of the simplified acquisition threshold for the purposes of carrying out the grant project must include a provision to the effect that you as the grantee, IMLS, the Comptroller General, or any of their duly authorized representatives shall have access for similar purposes to any books, documents, papers, and records that are directly pertinent to the project for the purpose of making audits, examinations, excerpts, and transcriptions (for example, 2 CFR §215.48(d) or 45 CFR § 1183,36(i)(10)). 17. What rules govern our procurement procedures? You are responsible for complying with the applicable procurement standards, for example set forth in 2 CPR Part 215 (for institutions of higher education, hospitals, and other non - profit organizations) and 45 CFR Part 1183 (for state, local, and Indian tribal governments). You must have standards to ensure that materials and services acquired under federal awards are obtained in an effective manner and in compliance with the provisions of applicable federal statutes, regulations, and executive orders. Written procedures should include, among other things, determining economical approaches; providing for competition; dealing with conflict of interest; efforts to use small businesses, minority -owned firms, and women's business enterprises; and maintaining records sufficient to detail the procurement process. (See Appendix A for further guidance on procurement.) 18. What are the rules for equipment and supplies? The purchase of equipment not included in the approved project budget is allowable only if it is specifically approved by IMLS and there is documentation to support that the purchase is necessary and reasonable to carry out project activities. Equipment records must be maintained that include the description of the equipment; the serial number or other identification number; the source of the equipment; the title holder; the acquisition date; the cost of the equipment; the location, use, and condition of the equipment; and any ultimate disposition data including the date of disposal and the sale price of the equipment. A physical inventory of the equipment must be taken and the results reconciled with the equipment records at least once every two years while the grant is active. 10