Uniform Guidance Procurement Standards: The Thresholds and the File Auditors Want

The short version

• The uniform guidance procurement standards are 2 CFR 200.317 to 200.327. Nonprofits follow all of 200.318 to 200.327; only States and Indian Tribes may use their own procedures instead (200.317).
• 2 CFR 200.1 does not state dollar amounts. It points to the FAR. Since October 1, 2025, FAR 2.101 sets the micro-purchase threshold at $15,000 (was $10,000) and the simplified acquisition threshold at $350,000 (was $250,000).
• A nonprofit may self-certify a micro-purchase threshold up to $50,000 once a year with documented support (200.320(a)(1)(iv)). Anything above $50,000 needs approval from the cognizant agency for indirect costs.
• Every procurement file must show the rationale for the method, the contract type, why the contractor was picked or rejected, and the basis for the price (200.318(i)).
• 2 CFR 200.214 makes recipients subject to the debarment rules in 2 CFR part 180, so a contract of $25,000 or more needs an exclusion check before award (180.220 and 180.300).

Why the thresholds moved without a rule change

Under 2 CFR 200.1, the micro-purchase threshold "is not to exceed the amount set by the FAR at 48 CFR part 2, subpart 2.1," and the FAR's simplified acquisition threshold "is used in this part." So when the FAR Council's inflation adjustment took effect on October 1, 2025 (90 FR 41872), grantee thresholds moved with it.

That matters because a procurement policy written before October 2025 often types in the old numbers. A policy that still says $10,000 is not illegal. 200.320 lets an organization set a lower threshold than the FAR. But staff end up chasing quotes the regulation no longer asks for, and a policy that says "the federal threshold" while purchasing works from an old cheat sheet is an inconsistency an auditor will notice. Our view: write the policy to reference FAR 2.101 and list the current figure with an effective date.

One caution. FAR 2.101 carves out lower micro-purchase figures, such as $2,000 for construction subject to the Davis-Bacon wage rules. How those carve-outs apply to a grantee's purchases depends on the program and the award, so confirm with the awarding agency rather than assume.

2 CFR 200.320 procurement methods by dollar value

2 CFR 200.320 sorts purchases by the aggregate dollar value of the transaction. Informal methods cover everything up to the simplified acquisition threshold; formal methods cover everything above it. Noncompetitive awards sit outside that ladder and need a listed reason.

The organization may set its simplified acquisition threshold lower than the FAR figure, never higher (200.320(a)(2)(ii)).

Other fixed dollar triggers to know

Not every number floats with the FAR. Appendix II to Part 200, which lists the clauses a nonprofit's contracts must carry (200.327), writes several amounts into its own text, and eCFR's version history shows Appendix II was not amended in the 2024 revision.

What the uniform guidance procurement standards require in writing

200.318(a) requires documented procedures for every procurement under a federal award, and 200.319(d) requires that solicitations describe the requirement clearly, avoid unnecessary brand-name specs, and state the evaluation factors. A nonprofit procurement policy that only restates the thresholds misses most of this.

Conflict of interest is where thin policies fail first. 200.318(c)(1) requires written standards of conduct that bar any employee, officer, agent, or board member with a real or apparent conflict from taking part in selecting, awarding, or administering a contract. That includes interests held by immediate family or a partner. The standards must ban gratuities from contractors (unsolicited items of nominal value may be allowed) and spell out discipline. If the nonprofit has a parent, affiliate, or subsidiary, it also needs written standards on organizational conflicts (200.318(c)(2)).

Two more rules catch people. A contractor that drafts the specifications must be excluded from competing on that procurement (200.319(b)). And a time-and-materials contract is allowed only after a determination that no other type fits, with a ceiling price the contractor exceeds at its own risk (200.318(j)). That describes plenty of hourly consulting engagements signed with no cap.

What a compliant procurement file looks like

200.318(i) sets the floor: records sufficient to detail the history of each procurement. In practice, a file an auditor can test without a follow-up email holds:

1. The need and its estimated value, so the method can be checked against 200.320.
2. The method chosen and why, in writing.
3. The solicitation or list of vendors asked to quote, with dates.
4. What came back, and the evaluation.
5. The selection memo: who won, why, and why others lost.
6. The basis for the price; above the simplified acquisition threshold, the cost or price analysis and independent estimate (200.324).
7. Conflict of interest attestations from the people who selected the vendor.
8. The SAM.gov Exclusions search result, dated before award, or the vendor certification.
9. The signed contract with the applicable Appendix II clauses.
10. For noncompetitive awards, the written justification tied to one of the five 200.320(c) circumstances.

Keep it for three years from the final financial report, longer if litigation, claims, or audits are open (200.334).

A worked purchase example

A nonprofit with an HHS award needs a consultant to migrate its case management data. Estimated cost: $42,000, billed hourly. It has not self-certified a higher micro-purchase threshold.

$42,000 is above the $15,000 micro-purchase threshold and below the $350,000 simplified acquisition threshold, so simplified acquisition applies. The program director sends a one-page scope to four qualified firms, leaving off the vendor that helped write it (200.319(b)). Three send quotes. The director and the finance lead sign conflict of interest attestations, and the evaluation memo picks the second-lowest quote because the lowest bidder could not meet the migration date. That reason goes in the file.

Because the contract is $25,000 or more, it is a covered transaction, so finance runs a SAM.gov Exclusions search on the winner and saves the dated result. The contract is hourly, so it carries a ceiling price under 200.318(j). Appendix II(B) termination language applies because it exceeds $10,000, and the domestic preference language goes in as it would for any contract. Byrd and the Clean Air clause do not, at this value. No cost or price analysis is required under 200.324 at $42,000, but 200.318(i) still requires a basis for the price, which the three quotes supply.

With a self-certified $50,000 threshold, this could have been a micro-purchase with no quotes. Legal, but then the self-certification file carries the weight, and it is redone every year.

Common audit findings

The 2025 Compliance Supplement tells Single Audit auditors what to test under requirement I, Procurement and Suspension and Debarment. They compare the policies to 200.318 through 200.327 and confirm written conflict of interest standards exist. Then they sample procurements: does each file document its history, did the method fit the dollar amount, was competition full and open, was any limit on competition justified, and was cost or price analysis done above the simplified acquisition threshold. Separately, they sample contracts and subawards to see whether the exclusion check happened before award.

Read that list as a map of where findings land. Our interpretation of the likeliest failure points, given those tests: files with no price basis, sole source awards with no written justification, policies with no conflict of interest standards, and exclusion checks done after signing or not at all. Add purchases split to stay under a threshold. 200.320 measures the aggregate amount of the transaction, and 200.318(d) asks for consolidating or breaking out purchases only where that gets a more economical result, not to avoid a method.

Where an outsourced accounting firm fits

This rarely needs a lawyer. It needs a current policy and a file habit that survives staff turnover. Work a firm can offer as a fixed project or small retainer:

• Rewrite the procurement policy to the 2024 text and current FAR 2.101 figures, with effective dates.
• Prepare the annual micro-purchase self-certification, if the client wants a higher threshold.
• Build a one-page procurement file checklist and an Appendix II clause rider for vendor contracts.
• Run a pre-audit sample of procurement files against 200.318(i), before the auditor does.
• Keep a dated log of SAM.gov exclusion checks for every covered transaction.

If a client's last Single Audit has a type I finding, the corrective action plan is a ready-made scope. Our guide to reading Single Audit findings shows where to find it.

How AwardNote uses this

Sources

All retrieved October 29, 2026.

• 2 CFR 200.1, Definitions (eCFR): ecfr.gov
• 2 CFR 200.317 to 200.327, Procurement Standards (eCFR): ecfr.gov
• 2 CFR 200.320, Procurement methods (eCFR): ecfr.gov
• 2 CFR 200.214, Suspension and debarment (eCFR): ecfr.gov
• 2 CFR 200.334, Record retention requirements (eCFR): ecfr.gov
• Appendix II to Part 200, Contract Provisions (eCFR): ecfr.gov
• 2 CFR 180.220 and 180.300 (eCFR): ecfr.gov
• FAR 2.101, Definitions (eCFR): ecfr.gov
• FAR 2.101, Definitions (Acquisition.gov): acquisition.gov
• Federal Register, FAR: Inflation Adjustment of Acquisition-Related Thresholds, 90 FR 41872 (Aug. 27, 2025): Federal Register
• OMB, 2025 Compliance Supplement, Part 3 Compliance Requirements: OMB document (PDF)
• SAM.gov, Exclusions search: sam.gov

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