Micro-purchases are the simplest and most informal of the procurement methods in the new grant guidance.
Here are the main points:
With purchases under the simplified acquisition rules (was $150,000 NOW $250,000) the process is still relatively simple and there are not extensive bidding requirements.
Once you start making purchases over was $150,000 NOW $250,000. the process gets morecomplicated and formalized.
Just like the sealed bid method, competitive proposals mean more requirements and documentation.
Sometimes because of the uniqueness of the goods or services or the immediacy of the need, competition is NOT as open as we would wish in the procurement process. If these cases, the sole-source method must be followed.
There are exceptions to pre-approval such as certain unique circumstances or a public emergency.
Regardless of the size of the purchase, these 5 characteristics must be still be met:
#1: The purchase must comply with the non-Federal entity’s documented procurement procedures
#2: The purchase must be necessary to carry out the Federal award.
#3: The purchase must be made with open competition to the extent required.
#4: The organization is in compliance with their conflict of interest policy.
#5: The purchase documentation contains a sufficient and proper history of the purchase.
This memorandum from OMB clarified several points regarding the new procurement rules as part of the implementation of 2 CFR Part 200–also known as the “Uniform Guidance.”
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