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Grant procurement rules: buy with federal money the way 2 CFR 200 asks

Purchase orders paid with federal award money now follow the 2 CFR 200 buying rules and keep the evidence your single-audit CPA asks for.

FT
Falaah Team
· · 3 min read
Grant procurement rules: buy with federal money the way 2 CFR 200 asks

A nonprofit that buys with federal award money buys under rules it rarely reads. At the single audit, the auditor samples purchases and asks how each one was bought. The answer usually lives in a shared drive, an inbox and someone’s memory.

Grant Compliance puts the 2 CFR 200 procurement rules on the purchase order and keeps the record as you go.

What changes on a purchase order

  • Pick the award that pays for the order.
  • Muin shows the band and the buying method the rules ask for.
  • Attach quotes, bids or proposals, the evaluation and the price analysis to the order.
  • The order’s Grant procurement card shows what is still missing.

The bands

From 2025-10-01 the federal thresholds are:

Band Order total What it needs
Micro-purchase Up to $15,000 No quotes
Small purchase Above the micro-purchase threshold, up to $350,000 Quotes from an adequate number of qualified sources, three by default
Formal Above $350,000 Sealed bids or competitive proposals, an evaluation and a cost or price analysis
  • Orders dated before 2025-10-01 are checked against the thresholds in force on their date.
  • The check uses the order total, so splitting an order does not change its band.
  • You can self-certify a micro-purchase threshold up to $50,000 for one fiscal year, with your justification and supporting document. Anything higher needs your cognizant agency’s approval.

Exclusion screening and overrides

  • At submit and at approval, Muin screens the vendor against the OFAC and SAM.gov exclusion lists.
  • A match blocks the order.
  • A screen that could not finish also blocks it until you retry.
  • A false-positive clearance needs a written reason and a second person.
  • When a check fails and the order must still go ahead, an override needs a reason and an approver other than the requester.

Appendix II clauses on the PO

Muin attaches the 2 CFR 200 Appendix II clauses that apply to the order’s total and type, and prints them on the PO PDF. You can add your own clauses in settings.

  • Every purchase on an award has an evidence record: method, quotes, exclusion result, clauses, approvals, bill and payment.
  • Each record shows Complete or Incomplete, and exports as PDF or CSV.
  • The award’s register and an exceptions list cover overrides, noncompetitive purchases and missing evidence.
  • From the award, Share with an auditor gives your single-audit CPA a read-only link that can include the procurement records.
  • A finding the auditor records comes back to you as a task.

Price and availability

  • Part of the Grant Compliance Solution: $100 a month list price, or $1,000 a year. It needs a Plan.
  • Included in Scale.
  • Needs the Spend module.

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