Procurement policy and documentation checklist

Scope, authority, and who may commit funds

2 CFR 200.318(a)

State that the policy governs all purchases charged to federal awards and name the roles authorized to approve at each dollar level.

• Programs and funding sources covered
• Approval authority by dollar amount and role
• Segregation between requester, approver, and payer
• How exceptions are requested and recorded

Internal thresholds and methods

2 CFR 200.320

Write down your own limits alongside the federal ones. If your limit is lower, yours governs.

• Micro-purchase limit used by your organization
• Number of quotes required in each band
• When a formal solicitation is required
• Conditions and approvals for a non-competitive award

Conflict-of-interest standards

2 CFR 200.318(c)

A written standard of conduct for everyone involved in selection, award, and administration of contracts.

• Prohibition on financial or familial interest in a bidder
• Rules on gifts and gratuities, with a de minimis definition
• Annual and per-procurement disclosure requirement
• Disciplinary consequences for violations

Competition safeguards

2 CFR 200.319

Describe the practices your organization will not use, so specifications are not written around one vendor.

• No brand-name-only specifications without an “or equal” clause
• No unnecessary experience, bonding, or geographic preference
• Written scope prepared before vendors are contacted
• Prohibition on splitting a need to avoid a threshold

Cost and price analysis

2 CFR 200.324

Require an independent analysis above the simplified acquisition threshold, including modifications and change orders.

• Who performs the analysis and how it is documented
• Treatment of change orders and cumulative increases
• Profit negotiated separately on non-competitive awards

Small and minority business outreach

2 CFR 200.321

Affirmative steps to solicit small, minority-owned, women-owned, and labor-surplus-area firms.

• Sources and lists used to identify qualified firms
• How solicitations are distributed
• Record of outreach performed per procurement

Vendor eligibility and responsibility

2 CFR 180 / 200.214

Confirm a vendor is not excluded before award, and record the check.

• Exclusion check before any award at or above $25,000
• Registration and taxpayer identification collected
• Date, source, and result of each check retained

Contract administration and records

2 CFR 200.318(b), (i)

A system for monitoring performance plus records sufficient to detail the history of each procurement.

• Who monitors deliverables and accepts the work
• Required federal clauses attached to contracts
• Retention period (generally three years after final report)
• Where procurement records are stored and who can access them

Micro-purchase

Up to $10,000

• Description of the need and the funding source charged
• Price-reasonableness note
• Receipt or invoice
• Requester and approver identity and date

Small purchase

$10,000 – $250,000

• Written scope or specification
• Every quote received, with vendor names and dates
• Basis for the selection
• Conflict-of-interest disclosure
• Exclusion check for awards at or above $25,000
• Purchase order or contract and the invoice

Sealed bids / competitive proposals

Above $250,000

• Solicitation, advertising evidence, and any addenda
• All offers received and the responsiveness review
• Evaluation criteria, scores, and award memo
• Independent cost or price analysis
• Executed contract with required federal clauses
• Prior written approval where the award requires it

Non-competitive (sole source)

Any amount

• Written justification citing the allowable condition
• Documentation that competition was inadequate, if applicable
• Cost or price analysis and negotiated profit
• Approval by an authorized official, plus agency authorization if required