OMB Issues Guidance Raising the Micro-Purchase, Simplified Acquisition Thresholds

June 22, 2018 | By Jerry Ashworth | Post a Comment

OMB-SealTGIF! That seems to be the mantra at the Office of Management and Budget (OMB). OMB has again made a big announcement late in the day on a Friday. Last August, OMB sent out word after 4:30 p.m. Eastern time that was issuing the DATA Act Section 5 Pilot Report, updated Uniform Guidance FAQs, and 2017 Compliance Supplement. We also learned on a Friday in May that this year’s Compliance Supplement was set for release.

Now, again after 4:30 p.m. Eastern time, we received word that OMB has issued guidance to federal agencies implementing statutory changes to the micro-purchase and simplified acquisition thresholds under the federal fiscal year (FY) 2017 and FY 2018 National Defense Authorization Acts (NDAA). We’re not complaining at all, but do you notice a trend here.

In accordance with recent statutory changes set forth in the FY 2017 and FY 2018 NDAA, the guidance (M-18-18) raises the threshold for micro-purchases under federal financial assistance awards from $3,500 to $10,000, and raises the threshold for simplified acquisitions from $100,000 to $250,000 for all recipients. Further, it implements an approval process for certain institutions that want to request micro-purchase thresholds higher than $10,000. The guidance requests that federal agencies implement these changes in the terms and conditions of their awards, and recipients of existing federal financial assistance awards may implement them in their internal controls.

Although uniform guidance provisions at §200.67, Micro-purchase, §200.88, Simplified acquisition threshold, have not yet been changed, OMB stated in the guidance that “in order to allow maximum flexibility for grant recipients in light of the changes to the NOAA for FY2018, OMB is granting an exception allowing recipients to use the higher threshold of$10,000 for micro-purchases and $250,000 for simplified acquisitions in advance of revisions to the Federal Acquisition Regulations at 48 C.F.R. Subpart 2.1 and the uniform guidance.” To clarify, pursuant to §200.102, Exceptions, OMB may allow exceptions to the uniform guidance when exceptions are not prohibited by statute. M-18-18 enables this exception.

This is big, big news for all grant recipients clamoring for higher procurement thresholds and is a welcome sight. We’ve been waiting to see this for a long time. Subscribers to Thompson’s grant publications can learn more about this new guidance and its impact on procurement in upcoming articles and analysis.

Let us know your reaction to this guidance. We’d love to hear from you.

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