To comply with the U.S. Office of Management and Budget (OMB) 2 CFR 200 Uniform Guidance (UG), Michigan Tech must adhere to the following requirements regarding procurement (excludes Subawards):
2 CFR 200.317 - 200.326 Procurement Standards (effective October 1, 2025)
Purchase Requisition Federal Threshold
Type of Competitive Action Non-Competitive Action
Amount Reference
| $0 - $14,999 | Below the Micro-Purchase Threshold (MPT) | Requires one (1) quote or proposal from a qualified supplier | N/A |
| $15,000 - $49,999 | Between MPT and the University's Competitive Bid Threshold | Requires Two (2) or more quotes or proposals from qualified suppliers | Sole/Single Justification with supporting documentation |
| $50,000 - $349,999 | Between the University's Competitive Bid Threshold and the Simplified Acquisition Threshold (SAT) | Requires Two (2) or more Competitive Bids from qualified suppliers (per University policy) |
|
| $350,000 and above | At or above the Simplified Acquisition Threshold (SAT) | Requires Two (2) or more Public Request for Quotes (RFQ) or Request for Proposals (RFP) |
Additional Requirements
The University must take all necessary affirmative steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible, in accordance with 2 CFR 200.321.
These efforts also support the equitable distribution of University procurement spend and promote inclusion and competition among qualified suppliers.
Affirmative Steps (2 CFR 200.321(b)):
When procuring goods and services under federal awards, the University (and its subrecipients)
must:
- Place qualified small and minority businesses and women’s business enterprises on solicitation lists.
- Assure that such businesses are solicited whenever they are potential sources.
- Divide total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by such businesses.
- Establish delivery schedules, where the requirement permits, to encourage participation by such businesses.
- Use the services and assistance of the Small Business Administration, the Minority Business Development Agency, and similar organizations.
- Require prime contractors to take these same affirmative steps when awarding subcontracts.
Special Consideration:
Principal Investigators (PIs) and departments must ensure that purchases originally
made on non-external sponsored projects are not reallocated to an external project
unless the required documentation noted above was obtained at the time of the original
purchase.
Definitions and Clarifications
- Micro-Purchase Threshold (MPT):
Currently set at $15,000 per federal guidance (2 CFR 200.320(a)). For purchases at or below this amount, competitive quotes are not required if the purchaser determines the price is reasonable. - Simplified Acquisition Threshold (SAT):
Currently set at $350,000 per federal guidance (2 CFR 200.320(b)). Procurement actions above the SAT require cost or price analysis, but the higher threshold allows more purchases to follow simplified procedures. - Quote or Proposal Examples:
Acceptable forms include:- Written quote from a vendor
- Vendor price list or website printout
- Email from a vendor referencing a price
- Note: An invoice is not a quote.
- Competitive Bid:
A formal quote or proposal from competing contractors, suppliers, or vendors that allows the University to evaluate the marketplace and obtain goods or services at fair and reasonable prices. - Sole Source Purchase:
Occurs when only one vendor can provide the required item or service. A detailed justification is required, including rationale for non-competitive procurement. - Single Source Purchase:
Occurs when multiple vendors are available, but a specific vendor is selected for documented reasons. A detailed justification is required, including rationale for non-competitive procurement.
Other Related Threshold Changes
Subcontracting Plan Threshold: Increased from $750,000 to $950,000 for prime contractors.
For additional information, see Acquisition.gov Threshold Changes