OMB Has Increased the Simplified Acquisition Threshold (“SAT”) and Micro-Purchase Threshold (“MPT”) for Procurements Under Grants
Providing much needed flexibility for many federal grant and cooperative agreement recipients, the Office of Management and Budget (“OMB”) has issued an exception to the Uniform Guidance Procurement Standards[1], increasing the:
- Simplified Acquisition Threshold (“SAT”) from $150,000 to $250,000, and
- Micro-Purchase Threshold (“MPT”) from $3,500 to $10,000.
This OMB-issued exception implements statutory changes to the SAT and MPT that are required by the 2018 National Defense Authorization Act (“NDAA”). By the wording of the OMB Memorandum issuing the exception, it appears to be immediately effective[2]. Grantees and cooperative agreement holders should note that they are required to accomplish procurement activities in accordance with their own internal procurement policies[3]. Therefore, thresholds in such policies should be updated to reflect these new figures before applying them.
Finally, please note that grantees are not required to raise the thresholds in their policies if they do not wish to, and could raise their thresholds for certain types of procurement activities and not others. For example, it may be that a grantee would wish to continue to require robust formal solicitation procedures for contracts exceeding certain dollar thresholds or involving certain types of work (e.g., construction projects between $150,000 and $250,000). While the MPT increase may afford much needed relief in most circumstances, grantees should consider what is right for their organization – especially in implementing the SAT increase.
OMB’s Memo (M-18-18) is available here.
If you have any questions, you are welcome to contact Scott S. Sheffler, Partner, Feldesman Tucker Leifer Fidell LLP at ssheffler@feldesman.com or (202) 466-8960.
[1] 2 C.F.R. §§ 200.317-200.326; 45 C.F.R. §§ 75.326-335.
[2] If a grantee’s specific award terms and conditions set forth the thresholds as stated dollar figures (as opposed to simply requiring that the grantee comply with the Procurement Standards as stated by OMB), an amendment to the award (or at least written clarification from the awarding agency or passthrough entity issuing the award) may be necessary to implement this change for that award.
[3] 2 C.F.R. § 200.318(a); 45 C.F.R. § 75.327(a).
