The Council on Governmental Relations (COGR), in concert with multiple higher education and nonprofit research organizations, submitted this formal letter to the Office of Management and Budget (OMB) to address concerns and propose revisions regarding the implementation of procurement standards under 2 CFR 200.317-326 for recipients of federal grants and cooperative agreements. While expressing appreciation for OMB's efforts in establishing the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, COGR underscores the negative impacts of the current procurement standards—particularly the $3,000 micro-purchase threshold—on research productivity, administrative efficiency, and institutional operations. The letter argues that such a low threshold, aligned with federal contract regulations rather than the distinct context of federal grants, would unnecessarily increase administrative burdens, delay research acquisition processes, and require costly systemic changes without tangible benefits in risk reduction.
COGR’s submission is structured around three central themes: maintaining a focus on federal program outcomes (especially scientific productivity), honoring the Presidential directive to reduce administrative burden, and advancing targeted proposals to ensure the successful and pragmatic implementation of procurement standards. Specific recommendations include allowing grantees an exemption process akin to that available to states (permitting the use of robust existing procurement systems), introducing common-sense improvements to clarify and streamline regulatory language, and increasing the micro-purchase threshold to $10,000 to reflect actual institutional risk and operational realities, supported by empirical data. The letter emphasizes that research institutions have strong internal controls and audit mechanisms in place, and that overly prescriptive federal rules may undermine the intended goals of efficiency and resource stewardship. COGR expresses willingness to collaborate with OMB and relevant stakeholders to refine the standards by the FY 2018 implementation deadline, aiming for a balanced approach that upholds accountability without impeding scientific advancement or institutional effectiveness.
