The Council on Governmental Relations (COGR), representing over 190 major research universities and institutions, and the Association of Independent Research Institutes (AIRI), submitted a detailed analysis to the Office of Management and Budget (OMB) regarding the administrative and cost implications of enforcing a $3,500 micro-purchase threshold for federally funded procurements. Based on surveys conducted among their member organizations, both COGR and AIRI found that implementation of the existing threshold would impose a substantial and unnecessary financial and administrative burden—exceeding $50 million annually—principally due to the need for increased central procurement staff and added compliance costs. Moreover, the change would result in a significant diversion of time and resources from research activities to administrative tasks, without yielding any demonstrated improvements in oversight or prevention of fraud, as recent audits indicated negligible findings related to procurement controls.
The letter urges OMB to reconsider and revise the Procurement Standards outlined in 2 CFR 200.317-326, advocating for either an exemption for research institutions similar to that provided to states, or an increase in the micro-purchase threshold to at least $10,000, aligned with risk assessments or state laws. The associations argue that existing internal control systems and procurement policies are robust and tailored to ensure fiscal responsibility and efficiency. The document also outlines anticipated regulatory review timelines and affirms a commitment to continued collaboration with OMB. Ultimately, COGR and AIRI emphasize that lowering the threshold undermines research productivity, increases administrative costs, and offers little additional accountability, and they call for policy changes to better support the research community’s needs.
