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The preparation of a "Determination and Finding" or "Finding of Fact" (similar name)  for each procurement action will satisfy the Federal requirements as listed in 24 CFR 85.36 (b)9, which states: "Grantees and sub grantees will maintain records sufficient to detail the significant history of a procurement.  These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price."

Definition:

Determinations and Findings (D&F) means a special form of written approval by an authorized official that is required by stature or regulation as a prerequisite to taking certain contracting actions.  The "determination" is a conclusion or decision supported by the "findings."  The findings are statements of fact or rationale essential to support the determination and must cover each requirement or the stature or regulation.
 

Content:

Each D&F shall set forth enough facts and circumstances to clearly and convincingly justify the specific determination made.  As a minimum, each D&F shall include in the prescribed agency format, the following information:

1. Identification of the agency and of the contracting activity and specific identifications of the document as a "Determination and Findings."
2. Nature and/or description of the action being approved.
3. Citation of the appropriate stature and/or regulation upon which the D&F is based.
4. Findings that detail the particular circumstances, facts, or reasoning essential to support the determination.  Necessary supporting documentation shall be obtained form appropriate requirements and technical personnel.
5. A determination based on the findings, that the proposed action is justified under the applicable stature or regulation.
6.  The signature of the official authorized to sign the D&F. and the date signed.