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Grant Procurement Compliance (2 CFR 200)

What you need to buy something with grant money under 2 CFR 200: the buying method by dollar band, quotes or bids, exclusion screening, Appendix II clauses and an evidence record your auditor can open.

What you need to buy something with grant money depends on the order total. Grant Procurement Compliance checks every purchase order paid with federal or pass-through award money against the 2 CFR 200 procurement rules, and keeps the record your auditor samples.

When you’d use this

  • Your organization spends federal or pass-through award money on goods or services.
  • You expect a single audit, and the auditor will ask how each purchase was bought.
  • You want quotes, bids, exclusion checks and approvals kept with the order, not in a binder.

You need the Grant Procurement Compliance add-on and the Spend module. The add-on is included in Scale.

How Muin picks the buying method

Two things set the band: the order total and the procurement date (the day the order is submitted).

Band Order total What the rules ask for
Micro-purchase Up to $15,000, or your certified threshold No quotes.
Small purchase Above the micro-purchase threshold, up to $350,000 Quotes from an adequate number of qualified sources. Muin asks for three by default.
Formal Above $350,000 Sealed bids or competitive proposals, an evaluation record, and a cost or price analysis.
  • Noncompetitive buying is allowed only with one of the 2 CFR 200.320(c) reasons: micro-purchase, sole source, public exigency, agency approval, or inadequate competition. It also needs a written justification.
  • Splitting an order to stay under a band is not allowed. The check always uses the order total.
  • Orders dated before 2025-10-01 are checked against the thresholds in force on their date.

Raise a grant-funded order

  1. Go to Muin for Spend > Purchase orders and click New PO.
  2. Pick the Award that pays for the order, then add the lines.
  3. Create the draft and open the order.
  4. Read the Grant procurement card: the band, the suggested method, and what is still missing.
  5. To use a different method, click Change and write the reason. A change without a reason is refused.

Attach quotes, bids and analysis

Attach the evidence to the order’s documents, with the right document type:

  • Quote for a small purchase.
  • Bid for sealed bids.
  • Proposal for competitive proposals.
  • Evaluation for the record of how bids or proposals were scored.
  • Price analysis for the cost or price analysis on a formal purchase.
  • Justification for a noncompetitive purchase.

The Grant procurement card counts them and updates what is missing.

Exclusion screening

When you submit the order, and again when it is approved, Muin screens the vendor against the OFAC and SAM.gov exclusion lists.

  • A match blocks the order.
  • If SAM.gov cannot be reached, the order waits until it is fully screened. Retry from the Grant procurement card.
  • If the match is a different party, request a false-positive clearance with a written reason. Someone other than you approves it.
  • A confirmed match cannot be overridden. Pick another vendor.

Overrides

When a check fails and the order must still go ahead:

  1. Request an override on the order and write the reason.
  2. Another approver decides it in the Inbox, on the web or on Muin Go.
  3. You cannot approve your own override.

The reason stays on the evidence record your auditor reads.

Contract clauses (Appendix II)

Muin attaches the 2 CFR 200 Appendix II clauses that apply to the order’s total and type, such as construction orders, and prints them on the PO PDF. Download it with Download PO (PDF) once the order is submitted.

To add your own clauses, an owner or admin opens Settings > Organization > Grant procurement > Clauses.

Raise your micro-purchase threshold

2 CFR 200.320(a)(1)(iv) lets you self-certify a micro-purchase threshold up to $50,000, one fiscal year at a time.

  1. An owner or admin opens Settings > Organization > Grant procurement > Thresholds.
  2. Pick the fiscal year.
  3. Choose why you qualify: low-risk auditee, annual risk assessment, or state law for a public institution.
  4. Upload the supporting document and enter the amount, up to $50,000.

Anything above $50,000 needs your cognizant agency’s approval (2 CFR 200.320(a)(1)(v)), so Muin refuses it. Muin sends a notice before the certification’s fiscal year ends.

The evidence record

  1. Go to Muin for Spend > Grant procurement.
  2. Pick the award. Every purchase on it shows Complete or Incomplete.
  3. Open a purchase to read its method, quotes, exclusion result, clauses, approvals, bill and payment.
  4. Click Export PDF or Export CSV.

When the order changes, the record gets a new version. Earlier versions stay readable.

Register and exceptions

  • Export register on the award downloads every purchase on it as a CSV.
  • The Exceptions tab lists overrides, noncompetitive purchases and missing evidence.

Share with your auditor

Open the award under Received Grants and choose Share with an auditor. You can include the procurement records. See Grants.

Past purchases

Go to Settings > Organization > Data Import and pick Grant-Funded Purchases to bring in a CSV of purchases made before you used Muin. Each imported record is marked as imported, with the evidence kept outside Muin.

What it affects

  • A bill charged to an award shows the evidence status of its purchase order (Smart Payments > Vendor Bills).
  • Approvers see the method, quotes, exclusion check and award in the Inbox, on the web and on Muin Go.
  • Your auditor can read the procurement records for an award through the auditor link.

When it goes wrong

What you see What it means How to clear it
Quotes are missing A small purchase has fewer quotes than required. Attach the quotes, or request an override.
A formal method is required The total is above $350,000. Change the method to sealed bids or competitive proposals and attach the bids, evaluation and price analysis.
A justification is required The method is noncompetitive. Pick the 2 CFR 200.320(c) reason and attach the justification.
The vendor is on an exclusion list OFAC or SAM.gov returned a match. Request a false-positive clearance if it is a different party; otherwise pick another vendor.
The screen could not finish SAM.gov did not answer. Retry from the Grant procurement card.
You cannot approve your own override You requested it. Ask another approver.
The add-on is required Your account does not have Grant Procurement Compliance. The owner adds it in Settings > Billing.

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