In May 2018, the Office of Management and Budget (OMB) released the 2018 Compliance Supplement.  At first glance, there are not many significant changes, except for additional changes to procurement standards as part of the National Defense Authorization Act (NDAA) of 2018.

The NDAA of 2018 increased the simplified acquisition threshold to $250,000 (previously $150,000) and the micro-purchase threshold to $10,000 (previously $3,500), respectively, for ALL auditees for ALL Federal grants.  These changes effectively redefine the level for the simplified acquisition threshold (section 200.88 of the Uniform Guidance) and the micro-purchase threshold (section 200.67 of the Uniform Guidance).  These changes will become effective when they are formally codified in the Federal Acquisition Regulations at 48 CFR Subpart 2.1.  Although not yet codified, the OMB issued a memo (M-18-18, Implementing Statutory Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for Financial Assistance) on June 20, 2018, providing an exception allowing entities to implement these changes early, with the only requirement being that entities document the higher thresholds in their procurement policies in accordance with the memo.

Institutions of higher education, or related or affiliated nonprofit entities, nonprofit research organizations or independent research institutes, which had established micro-purchase thresholds up to the $10,000 prior to the enactment of the NDAA of 2017, are allowed to continue the use of the same threshold as documented in their internal procurement policies.

Stay tuned for future updates released by the OMB and formal codification.  For additional details, contact us or refer to the 2018 Compliance Supplement at https://www.whitehouse.gov/wp-content/uploads/2018/05/2018-Compliance-Supplement.pdf and the memo issued by OMB on June 20, 2018, at https://www.whitehouse.gov/wp-content/uploads/2018/06/M-18-18.pdf.

For more information, please contact Senior Manager, Veronica Cook.

TAGGED: Single Audits
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