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Plain-English guide · for small nonprofits

2 CFR 200.320, explained in plain English

Updated August 2026

How much competition a purchase needs, decided by how much it costs. The two numbers that set the tiers both changed recently.

The short version

§200.320 sorts purchases into tiers by size. Small ones need almost nothing. Medium ones need price quotes from several sources. Large ones need a formal, publicly advertised process. The tier boundaries are the micro-purchase threshold and the simplified acquisition threshold, and both rose on 1 October 2025.

The numbers, and why you will see the wrong ones

§200.320 contains no dollar figures. It points at the definitions in §200.1, which point at the Federal Acquisition Regulation, which is adjusted for inflation every five years. So the regulation is stable and the numbers move underneath it.

ThresholdCurrentPreviously
Micro-purchase$15,000$10,000
Simplified acquisition$350,000$250,000

Effective 1 October 2025. Nearly every nonprofit procurement policy and guidance article written before then says $10,000 and $250,000. If your written policy quotes figures rather than pointing at the definitions, it is now out of date. A policy you do not follow is worse than a vague one.

The tiers

  1. Informal, at or below the micro-purchase threshold

    You may award without soliciting competitive quotations. Two conditions: you consider the price reasonable, and you spread micro-purchases fairly among qualified suppliers so far as you can. This is the tier most small nonprofit purchasing lives in.

  2. Small purchase, above micro-purchase, at or below the simplified acquisition threshold

    Rate quotations must be obtained from an adequate number of qualified sources. Relatively simple, but it is a real requirement: get quotes, and keep them.

  3. Formal, above the simplified acquisition threshold

    Sealed bids or competitive proposals, publicly advertised, with a written method for evaluation and award. Most small organizations never reach this tier, and those that do usually reach it once, for a building or a vehicle fleet.

  4. Noncompetitive

    Permitted only in narrow cases. The item comes from a single source. A public emergency will not permit delay. The federal agency or pass-through entity expressly authorizes it. Or you solicited and competition proved inadequate. Document which one applies, before you buy.

You can raise your own micro-purchase threshold

Under §200.320(a)(1)(iv), you may self-certify a higher micro-purchase threshold, up to $50,000. You need a clear rationale, such as qualifying low-risk auditee status or an annual internal risk assessment. Above $50,000 you need approval from the cognizant agency for indirect costs.

Self-certification must be documented and kept available. This is genuinely useful for an organization that buys a lot of mid-sized items, and it is largely unknown.

What the tiers do not excuse

The thresholds decide how much competition, not whether the other rules apply. Whatever the size, you still need four things: written procurement procedures, a written conflict of interest standard for staff involved in selection and award, cost or price reasonableness, and enough documentation to reconstruct the decision. A $200 micro-purchase from a board member's company is a conflict of interest problem, not a procurement threshold problem.

What to actually do

  1. Write the policy to reference, not to quote

    Say “the micro-purchase threshold as defined at 2 CFR 200.1” rather than a dollar figure. It stops being wrong every five years.

  2. Keep quotes with the invoice

    The small purchase tier is easy to satisfy and easy to fail, because the quotes were obtained verbally and never written down.

  3. Decide about self-certification once

    If you routinely buy between $15,000 and $50,000, do the risk assessment and raise your threshold deliberately.

  4. Document sole source before, not after

    A justification written at audit time reads exactly like what it is.

This is general information, not legal or accounting advice. Federal grant rules change and are applied differently by different agencies and auditors. Check with your auditor, your grant officer, or an attorney before relying on any of it.

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Common questions

What is the micro-purchase threshold for federal grants?

$15,000, raised from $10,000 effective 1 October 2025. 2 CFR 200.320 points at the definition in 200.1, which points at the Federal Acquisition Regulation, so the figure changes with periodic inflation adjustments.

What is the simplified acquisition threshold?

$350,000, raised from $250,000 effective 1 October 2025. Purchases above it require sealed bids or competitive proposals.

Can a nonprofit raise its own micro-purchase threshold?

Yes. Under 2 CFR 200.320(a)(1)(iv) you may self-certify a threshold up to $50,000 with a documented rationale, such as a qualifying low-risk auditee status or an annual internal risk assessment. Above $50,000 requires approval from the cognizant agency for indirect costs.

Do we need quotes for every purchase under a federal grant?

No. At or below the micro-purchase threshold you may award without soliciting competitive quotations if the price is reasonable and purchases are distributed equitably among qualified suppliers. Above it and up to the simplified acquisition threshold, rate quotations from an adequate number of qualified sources are required.

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Sources: 2 CFR Part 200 (eCFR), §200.320 and the threshold definitions at §200.1, with the current FAR figures from the FAR inflation adjustment effective 1 October 2025. Verified August 2026. These figures are adjusted periodically; check before relying on them.