Why This Guide Exists
2 CFR 200 — the Uniform Guidance for federal awards — governs how USAID-funded organisations procure goods and services. The regulation itself is 190 pages of federal administrative language. Most field officers have received a half-day overview training that covers the principles but not the specific actions required at each threshold for each procurement type. This guide translates the requirements into desk-level procedures.
The Three Procurement Thresholds
Below USD 10,000: Micro-Purchase
For purchases below the micro-purchase threshold, you may award without competitive quotations if you consider the price reasonable. However, you must: distribute micro-purchases equitably among qualified suppliers (do not give everything to one vendor), document the price reasonableness determination (a brief note explaining why the price is fair), and maintain records of each purchase. Common mistake: treating the micro-purchase threshold as a no-documentation zone. It is not. You still need records.
USD 10,000 to USD 250,000: Simplified Acquisition
For purchases in this range, you must obtain price or rate quotations from an adequate number of qualified sources (typically three or more). You must: document the cost or price analysis for every procurement, check SAM.gov for debarment or suspension before award for purchases above USD 25,000, verify geographic code compliance, and maintain complete procurement files. This is where most audit findings occur — the cost analysis and debarment check documentation.
Above USD 250,000: Full and Open Competition
Above the simplified acquisition threshold, full and open competition is required. This means formal solicitation through sealed bids or competitive proposals, published evaluation criteria, a formal evaluation process with documented scoring, and USAID prior approval for sole-source procurement. At this level, prior written USAID approval is required before proceeding with any sole-source justification.
The Cost Analysis Requirement
2 CFR 200 requires a cost or price analysis for every procurement above the micro-purchase threshold. This is the single most commonly missed documentation requirement. A cost analysis is not complex — it is a documented comparison showing that the price you are paying is fair and reasonable. Methods include: comparison with prior purchases of the same item, comparison with published price lists or catalogues, comparison with independent cost estimates, and comparison with prices obtained from other vendors.
The SAM.gov Debarment Check
Before every contract award above USD 25,000, you must verify that the vendor is not debarred or suspended on SAM.gov (System for Award Management). The process: go to sam.gov, search for the vendor by name and country, print the search result (whether positive or negative), and file it in the procurement record. Do this on the day of or day before the award decision — not weeks earlier.
Geographic Code Compliance
Most USAID programmes operate under Geographic Code 935, which restricts procurement to goods and services from the cooperating country, the United States, or developing countries. This means you must verify the country of origin for procured goods and document it. Items manufactured in non-eligible countries cannot be procured with USAID funds, regardless of where the supplier is located.
Equipment Purchases Above USD 5,000
Any single equipment purchase with a per-unit cost of USD 5,000 or more requires prior written approval from USAID. This includes vehicles, generators, IT equipment, and medical devices. File the approval before procurement begins — retroactive approval is not guaranteed and may result in cost disallowance.
Need help with 2 CFR 200 compliance? Download the free Donor Audit Readiness Checklist at ustadiafrica.com or contact us for a compliance review.