The Uniform Guidance emphasizes that all procurement transactions must be conducted in a manner providing full and open competition. Use of MIT Preferred vendors satisfies this requirement.

The new regulations also require that we have clearly defined roles and responsibilities, written policies, and monitoring in place to ensure compliance. We must maintain records sufficient to detail the purchase history. These records should include; Contract type, contractor selection or rejection and the basis for the contract price.

Below are the methods for procurement

  • Micro purchases
    • purchases that do not exceed $3,000.00
    • competition not required but price reasonableness must be demonstrated
    • must be distributed equitably among qualified suppliers
  • Small purchases
    • Purchases between $3,000.00 and $149,999.99
    • Price and rate quotes must be obtained from an adequate number of qualified sources (at least 2)
  • Purchases greater than the Simplified Acquisition Threshold ($150,000.00)
    • Cost and price analysis must be performed for every procurement including contract modifications
    • Requires a Request For Proposals from an adequate number of qualified sources with documented specifications, evaluation criteria and independent cost estimate.
  • Sole Source
    • Procurement by noncompetitive proposals (sole source) is procurement through solicitations from only one source and may be used only when one or more of the following circumstances apply
      • The item is only available only from a single source
      • The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation
      • The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal agency; Or
      • After solicitation of a number of sources, competition is determined to be inadequate
    • Cost or price analysis is still required to establish a reasonable price
    • Profit must be negotiated as a separate element of the price when there is no price competition

Applicable Uniform Guidance section: 200.318, 200.319 & 200.320

For more information, contact Tony Flaherty in Procurement / VPF.