The document is a formal letter from the Council on Governmental Relations (COGR) and the Association of Independent Research Institutes (AIRI) addressed to the White House Office of Management and Budget (OMB), reporting the findings of surveys commissioned to assess the administrative and cost impact of a proposed $3,500 micro-purchase threshold for procurement activities at research universities, nonprofit research institutions, and hospitals. The letter details that the implementation of the $3,500 threshold, as required by 2 CFR 200.320(a), would result in a significant cumulative administrative burden exceeding $50 million annually for affected institutions, primarily through the need to hire additional procurement staff and by increasing the administrative workload on both central and departmental personnel, including scientists whose time would be diverted from research activities. The analysis also points out that historical audit findings concerning procurement internal controls have been minimal, suggesting that existing institutional controls are adequate and that lowering the threshold would not yield substantial improvements in oversight or prevention of waste, fraud, and abuse.
The survey encompassed responses from a broad cross-section of research institutions, collectively representing a substantial portion of federal research expenditures, and found that nearly all would require increased staffing to comply with the lower threshold. Furthermore, the letter highlights concerns raised by leading scientific organizations that unnecessary administrative requirements threaten the productivity and efficiency of the scientific research enterprise. Accordingly, COGR and AIRI recommend either exempting research institutions from the relevant federal procurement standards (as is the case with states) or raising the micro-purchase threshold to at least $10,000, with flexibility for higher levels based on institutional risk assessment or state law. The organizations offer to continue working with OMB towards policy revisions that reduce unnecessary administrative burdens while maintaining rigorous stewardship of federal funds.
