External Sponsored Projects Procurement Guidelines

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:

  1. Place qualified small and minority businesses and women’s business enterprises on solicitation lists.
  2. Assure that such businesses are solicited whenever they are potential sources.
  3. Divide total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by such businesses.
  4. Establish delivery schedules, where the requirement permits, to encourage participation by such businesses.
  5. Use the services and assistance of the Small Business Administration, the Minority Business Development Agency, and similar organizations.
  6. 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