CGMS 100%

Domain: Fiscal Management

Lesson 5: Procurement standards

How to buy goods and services with grant money, and how to keep it clean · 14 practice questions

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Procurement standards live in 2 CFR 200 Subpart D, sections 200.317 through 200.327, and they govern how an organization spending federal grant funds buys goods and services, everything from office supplies to a major construction contract. This course files procurement under the Fiscal Management domain because getting it wrong is one of the most common and most expensive audit findings a grants manager will encounter: an undocumented sole-source contract or a conflict of interest that was never disclosed can put an entire award's costs in question.

The procurement methods, tied to dollar thresholds

2 CFR 200.320 describes three types of procurement methods: informal (micro-purchases and simplified acquisitions), formal (sealed bids or proposals), and noncompetitive. The informal and formal methods run from light to heavy as the dollar amount rises. Micro-purchases, the smallest tier, can be made without soliciting competitive quotes if the organization considers the price reasonable based on research, experience, or purchase history and keeps documents that support that conclusion; where practical, they should be distributed equitably among qualified suppliers. Above the micro-purchase threshold but not above the simplified acquisition threshold, simplified acquisition procedures apply, requiring price or rate quotations from an adequate number of qualified sources, informal but still competitive. Above the simplified acquisition threshold, procurement becomes formal, competitive, and public: either sealed bids (a firm fixed-price contract awarded to the lowest responsive and responsible bidder, feasible when a complete, adequate, and realistic specification exists and two or more responsible bidders can compete, and preferred for construction services) or proposals (used when sealed bids are not appropriate, allowing either a fixed-price or a cost-reimbursement contract, with award to the responsible offeror whose proposal is most advantageous considering price and other factors, not necessarily the cheapest).

The current dollar thresholds

The micro-purchase threshold and simplified acquisition threshold follow the Federal Acquisition Regulation (FAR) and are periodically raised. Effective October 1, 2025, the FAR's micro-purchase threshold is $15,000 (up from a prior $10,000) and its simplified acquisition threshold is $350,000 (up from a prior $250,000). The FAR sets lower micro-purchase amounts for some work, such as $2,000 for construction subject to Davis-Bacon wage rates and $2,500 for services subject to Service Contract Labor Standards, so check how the award's terms apply them. An organization may set lower thresholds of its own. It may also self-certify a micro-purchase threshold above the FAR amount, up to $50,000 annually, if it documents the higher threshold and supports it with a low-risk auditee qualification, an annual internal institutional risk assessment, or (for a public institution) consistency with State law; going above $50,000 requires approval from the cognizant agency for indirect costs. These thresholds move over time, so a grants manager should confirm the current figures rather than relying on a number memorized from an earlier year.

Noncompetitive (sole source) procurement: the narrow exceptions

Noncompetitive procurement, buying from one source without soliciting competing bids or proposals, is allowed only in specific circumstances, not as a matter of convenience. 2 CFR 200.320(c) permits it when the amount does not exceed the micro-purchase threshold, when the transaction can only be fulfilled by a single source, when a public exigency or emergency will not permit the delay of public notice of a competitive solicitation, when the organization requests it in writing and the federal agency or pass-through entity gives written approval, or when, after soliciting several sources, competition is determined inadequate. Each of these is a documented exception, not a default; a grants manager who wants to sole-source a contract above the micro-purchase threshold needs to be able to point to one of these specific conditions and document why it applies.

Standards of conduct: conflicts of interest in procurement

2 CFR 200.318(c) requires every organization to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, agent, or board member with a real or apparent conflict of interest may take part in the selection, award, or administration of a contract supported by the federal award. A conflict includes the person, an immediate family member, a partner, or an organization that employs or is about to employ any of them having a financial or other interest in, or a tangible personal benefit from, an entity considered for the contract. They also may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, although the organization may set standards for interests that are not substantial or for unsolicited items of nominal value, and its standards must provide for disciplinary actions for violations. An organization with a parent, affiliate, or subsidiary that is not a government also needs written standards on organizational conflicts of interest. This is a written-policy requirement, not just good intentions: an organization needs an actual document that a monitor or auditor can review.

Contract provisions that must appear in the resulting contract

Once a procurement is complete and a contract is awarded, 2 CFR 200.327 requires the contract to contain the applicable provisions described in Appendix II, depending on its dollar value and type. Examples include administrative, contractual, or legal remedies for breach in contracts above the simplified acquisition threshold; termination for cause and for convenience in contracts over $10,000; the equal opportunity clause in federally assisted construction contracts; Davis-Bacon Act compliance in prime construction contracts over $2,000 when program legislation requires it; and Contract Work Hours and Safety Standards Act compliance in contracts over $100,000 that involve mechanics or laborers. Appendix II also covers other clauses, such as debarment and suspension. A contract missing the required provisions is a procurement compliance gap even if the underlying purchase itself was properly competed.

Procurement methods by dollar threshold A ladder of four procurement methods rising with dollar amount: micro-purchase (up to $15,000, no competitive quotes needed), small purchase procedures (between $15,000 and $350,000, informal quotes from an adequate number of sources), and above $350,000 either sealed bids or competitive proposals, both formal and competitive. Micro-purchase Up to $15,000 No quotes required Small purchase $15,000 to $350,000 Price quotes, adequate sources Sealed bids Above $350,000 Lowest responsive bidder Competitive proposals Above $350,000 Most advantageous offeror Noncompetitive (sole source) is the exception, not the default Allowed only if: at/below micro-purchase, single source only, public emergency, agency or pass-through approves in writing, or competition proves inadequate Every use requires written justification under one of these conditions
Effective October 1, 2025, the micro-purchase threshold is $15,000 and the simplified acquisition threshold is $350,000; both figures move over time and should be confirmed against the current federal acquisition regulation.

Practice questions

1. Which sections of 2 CFR 200 contain the procurement standards?

  1. 200.403 to 200.414
  2. 200.317 through 200.327, in Subpart D
  3. 200.501 to 200.521
  4. 200.100 to 200.113

2. As of October 1, 2025, what is the micro-purchase threshold?

  1. $5,000
  2. $10,000
  3. $15,000
  4. $50,000 for every organization automatically

3. As of October 1, 2025, what is the simplified acquisition threshold (SAT)?

  1. $100,000
  2. $150,000
  3. $250,000
  4. $350,000

4. Which procurement method is used when a complete specification exists and at least two responsible bidders can compete, with award to the lowest responsive and responsible bidder?

  1. Sealed bids
  2. Micro-purchase
  3. Competitive proposals
  4. Noncompetitive procurement

5. In competitive proposals, is the award required to go to the lowest-priced offeror?

  1. Yes, always the lowest price
  2. No, it goes to the offeror whose proposal is most advantageous considering price and other factors
  3. Award is decided by a lottery
  4. Only offerors that are NGMA members in good standing may be awarded contracts through competitive proposals

6. Which of the following is NOT one of the allowed conditions for noncompetitive (sole source) procurement under 200.320?

  1. The item is available from only one source
  2. A public emergency does not allow the delay competitive solicitation would require
  3. After soliciting sources, competition is determined inadequate
  4. The organization simply prefers a particular vendor for convenience

7. Which section of 2 CFR 200 requires written standards of conduct covering conflicts of interest in procurement?

  1. 200.112
  2. 200.318
  3. 200.334
  4. 200.344

8. Under 200.318, whose financial interest in a bidding firm would create a prohibited conflict?

  1. Only the organization's chief executive and the chair of its board, since they sign contracts
  2. Only board members, never staff
  3. The person involved in the procurement, or their family, partner, or employer
  4. Conflicts of interest are not addressed by 2 CFR 200

9. Can an organization's procurement standards of conduct ever allow accepting anything of value from a contractor?

  1. Yes, the organization may set standards for unsolicited items of nominal value
  2. No exceptions are ever allowed under any circumstances
  3. Yes, gifts of any size are permitted as long as they are disclosed to the board after the fact
  4. Only cash gifts are prohibited; all other gifts are unrestricted

10. Which section of 2 CFR 200 requires certain provisions, like termination clauses and remedies for breach, to appear in the contract resulting from a procurement, as described in Appendix II?

  1. 200.206
  2. 200.403
  3. 200.327
  4. 200.414

11. A GCHS staff member wants to sole-source a $200,000 contract to a firm owned by their spouse, above the micro-purchase threshold and with no emergency or single-source justification. Is this permitted?

  1. Yes, as long as the staff member discloses it afterward
  2. No; it is the conflict of interest 200.318 prohibits, and at $200,000 no 200.320 noncompetitive exception applies either
  3. Yes, because a spouse's business interest is excluded from the conflict-of-interest definition when the price is fair and documented
  4. This is permitted if approved by NGMA

12. Can an organization self-certify a micro-purchase threshold higher than the base federal threshold?

  1. Yes, up to $50,000 annually with documentation; going higher requires cognizant agency approval
  2. No, the threshold can never be adjusted by the organization
  3. Yes, without limit or documentation
  4. Only federal agencies, never non-federal entities, can adjust this threshold, and only through a FAR rule change

13. Why is procurement considered a common and expensive source of audit findings?

  1. Procurement is not actually reviewed in audits
  2. Because procurement decisions are made by NGMA, not the grantee
  3. An undocumented sole-source contract or an undisclosed conflict of interest can put an entire award's costs in question
  4. Because procurement is the only topic on the CGMS exam

14. Under 200.320, is a "small purchase procedure" formal or informal, and what does it require?

  1. Formal; it requires sealed bids
  2. Informal; it requires price or rate quotations from an adequate number of qualified sources
  3. Informal; no quotes of any kind are required
  4. Formal; it requires a public emergency declaration

Glossary

Micro-purchase threshold
The dollar ceiling below which a purchase needs no competitive quotes; $15,000 in the FAR as of October 1, 2025 (lower for some construction and service work), with self-certification of a higher amount possible.
Simplified acquisition threshold (SAT)
The dollar ceiling separating informal small-purchase procedures from formal procurement; $350,000 as of October 1, 2025.
Sealed bids
A formal, price-driven procurement method requiring a complete specification and at least two responsible bidders, awarded to the lowest responsive bidder.
Competitive proposals
A formal procurement method used when sealed bidding is not appropriate, awarded to the most advantageous offeror rather than strictly the lowest price.
Noncompetitive (sole source) procurement
Buying from a single source without competition; allowed only under specific, documented conditions in 200.320.
2 CFR 200.318
The section requiring written standards of conduct covering procurement-related conflicts of interest and gratuities, along with documented procurement procedures and contractor oversight.