The Council on Governmental Relations (COGR), representing major research universities and allied organizations, submitted this letter to the Office of Management and Budget (OMB) to address concerns about the implementation of federal procurement standards under the OMB Uniform Administrative Requirements (2 CFR 200). While COGR expressed appreciation for OMB’s collaborative approach during the development of these guidelines, the letter highlights significant challenges and unintended consequences arising from the procurement standards, specifically the $3,000 micro-purchase threshold and overly prescriptive regulations. COGR argues that these standards, if enacted as written, would impede research productivity by introducing burdensome administrative requirements, delay timely acquisition of essential research materials, and require costly modifications to institutional procurement systems that already operate under robust internal controls.
In response, COGR advocates three principal recommendations: (1) the establishment of a grantee exemption process allowing qualified institutions—those with well-developed procurement policies and systems validated through audits—to follow their own procedures similar to the exemption granted to states; (2) the implementation of common-sense improvements and clarifications to sections of 2 CFR 200.317-326, developed with input from a representative working group; and (3) raising the micro-purchase threshold to $10,000, supported by empirical data, to reduce administrative burden without increasing risk of fraud or misuse of federal funds. The letter emphasizes the importance of maintaining a balance between effective oversight and minimizing administrative workload, in line with the President’s directive to reduce unnecessary bureaucratic barriers. COGR seeks continued dialogue with OMB to refine these procurement standards, ensuring they facilitate the delivery of federal program outcomes and support the operational efficiency and integrity of research institutions.
