An Update on Procurement and the Micropurchase Threshold (MPT)
Monday, June 25, 2018
The long-awaited OMB Memorandum to address implementation of the Micropurchase Threshold was released on June 20, 2018. Specifically, OMB Memorandum M-18-18, Implementing Statutory Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for Financial Assistance, effectively implements the statutory changes set forth in the National Defense Authorization Acts (NDAA) for Fiscal Years 2017 and 2018.
A key element of the Memorandum is the section titled: Process for Requesting a Higher Threshold Under the NDAA for FY2017. COGR recognized the sense of urgency for those institutions that currently have an MPT greater than $10,000 and the need to have a clear and timely “approval process” to continue using their MPT greater than $10,000. Finally, under this section of the Memorandum, guidance has been provided:
Requests for approval should be submitted to the institution's cognizant Federal agency for indirect cost rates; however, institutions should contact the agency before sending the request to determine the correct point of contact. The cognizant Federal agency will assign review of the request to the appropriate office within the agency to determine whether to approve, and will maintain records and justification of all approvals. The request should include the threshold level being requested and the justification(s) for it based on the criteria above per Section 2 I 7(b) of the NDAA for FY2017.
COGR will provide additional detail in the June Meeting Report due out to the Membership early next week. We expect there will be questions that arise and we encourage you to contact Gilbert Tran at OMB (202-395-3052) or Mary Tutman at OMB (202-395-1703 if you have questions or concerns.
Also contact David Kennedy at COGR for additional updates and information.