Notice – Federally Funded Procurement Changes July 1st

This is notice of changes for FEDERALLY FUNDED PROCUREMENTS only.  This will not impact regular funded procurements.*


As of July 1st, OSU must adhere to the Procurement Standards contained in the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards 2 CFR 200 “Uniform Guidance” when making purchases using federal funds or when federal funds will reimburse the purchase in the future.

Due to a delay in implementation of updates to OSU’s Procurement Standards which align with the Uniform Guidance, OSU will need to follow both the Uniform Guidance and OSU’s existing Procurement Standards by adhering to whichever is more restrictive (excepting the Micro-Purchase Threshold) to ensure we are in compliance with both.  OSU’s will move forward with a Micro-Purchase Threshold of $25K while awaiting final approval from our cognizant agency.


Adherence to this will require changes to OSU’s current procurement practices for Federally Funded Procurements only.  Those changes include the following:

  • Exemption from competition are not allowed for Federally Funded Procurements.  Uniform Guidance does not allow exemptions to the competitive procurement process.  However, a few non-competitive procurement types are allowed for in cases of sole source, emergency, inadequate competition, or when a Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from OSU.  Written requests should be made to the funding agency according to their instructions.
  • Purchases above $250K have very implicit instructions for how formal solicitations are conducted.  PCMM will work with departments on those additional requirements.

As a reminder procurement thresholds are as follows:

  • Less than $25K – Direct (Micro-Purchase):  No competition required, departments may solicit contractors directly
  • $25K – $150K – Informal (Small):  Informal methods of competition required, PCMM must facilitate competitive requirements
  • Greater than $150K– Formal Procurement (Bids and Proposals):  Formal methods of competition required, PCMM must facilitate competitive requirements

*Please note that when a cost transfer is anticipated whereby OSU will procure goods or services using E&G funding and then be reimbursed later with federal funds, OSU must follow the rules for federal funding.

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