Purchasing with Federal Grant Funds

When purchasing goods or services with grant funds, the purchase is subject to the Federal Uniform Guidance (UG) and University purchasing procedures. Review UG requirements on the ecfr.gov website. It is important to note that the UG only applies to federal grants (financial assistance) and not federal contracts.

In addition to the following information, review the requisition checklist which is intended to help you keep track of required documentation, applicable links to important information, and forms required for the requisition phase for purchases using federal grant funding.

The UG procurement standards identifies three thresholds:

  • Micro-Purchase: $10,000 or less
  • Small Purchase: $10,000.01 - $250,000
  • Competitive Proposal: $250,000.01 or more


Micro-Purchase Threshold ($10,000 or less)

Purchases under the Micro-Purchase Threshold can be awarded “without soliciting competitive quotations” if the price is reasonable. For purchases under $10,000, following University guidelines should be sufficient.

Small Purchase Threshold ($10,000.01 to $250,000)

Purchases in the Small Purchase Threshold, between $10,000.01 and $250,000, require “relatively simple and informal procurement methods.” Purchases within this UG threshold cross two thresholds under University purchasing policies requiring different involvement by the Purchasing Services Department.

$10,000.01 to $50,000

Departments may use the Request for Quote (RFQ) template to solicit competitive bids and submit the documentation with your requisition through the PantherExpress System.

$50,000.01 - $250,000

Contact your procurement specialist for assistance with preparing formal Request for Proposals (RFP)

Use of University-wide Contracted Suppliers

Most contracts with University-wide suppliers are “negotiated agreements” and do not sufficiently meet competitive bidding requirements under the UG. As such, competitive bidding must be done for nearly all purchases using federal grant funding over $10,000.

Suppliers marked as "Yes" in the Uniform Guidance column on our University-wide Contracted Supplier Directory have competitively bid contracts that satisfy the UG.

Competitive Proposal Threshold ($250,000.01 or more)

Purchases that exceed the Competitive Proposal Threshold, $250,000 are subject to strict procurement requirements. In order to comply with federal requirements it is essential that purchasers plan significantly in advance of purchase as the RFP process can take 8-12 weeks.

Procurement Requirements
  • Obtain independent estimates before receiving proposals such as:
    • Previous contracts or publicly available contracts such as those published by a government or public university
    • Quotes
    • Web-prices
  • Publish Requests for Proposals (RFP)
    • Your procurement specialist will ensure it is posted on our website
    • The UG does not define a time limit, the University recommends 7-14 days
  • Identify all evaluation criteria and their relative importance
    • Relative importance is meant to indicate that they are in a rank or ordered format
    • You do not need to supply a weighted criteria for this
  • Solicit from an “adequate” number of qualified sources
    • A minimum of two returned proposals is necessary to make a comparison
  • Have a written method for conducting technical evaluations of the proposals and selecting recipients
  • Award the contract through price analysis to a responsible firm whose proposal is most advantageous
    • Price should be considered along with other factors; not just low-bid
Non-Competitive Proposals

All purchases over $10,000 have a competitive bidding requirement under the UG. Regardless of whether the supplier is a University-wide Contracted Supplier, you must submit a Directed or Sole Source Justification Form* (DSSJ) for all sole-source purchases with federal grant funds that are $10,000.01 or greater.

Situations which are allowable* for sole source procurement include:

  • Available only from a single source; for sole source Research is expressly permitted in the UG
  • Awarding agency expressly authorizes noncompetitive proposals in response to a written request from the University
    • Include this when submitting the DSSJ
  • Public exigency
  • After an RFP process, competition is deemed inadequate

*Under the UG Procurement Standards, any sole source purchase over $250,000 must be accompanied by a cost analysis that includes all costs that lead to the quoted price. As this cost analysis would need to include line items for overhead and profit, it is highly unlikely that a supplier would provide this information. However, if you are able to acquire this, include it with the DSSJ. The procurement specialist will need to conduct a cost analysis of the “reasonableness of each cost element." Purchases that are $250,000 or less do not require a cost analysis with the sole source justification.

Exceptions to Competitive Bidding and Sole Source Requirements

The UG allows for “piggybacking” off of existing contracts that were competitively bid. You should ask the supplier you are working with whether they have public contracts, such as those with a government (federal, state, county, city, etc.) or a co-operative entity (E&I, Omnia, NASPO Valuepoint etc.).