Micro-Purchases, Quotes and Sole-Source for Reagent Orders

At what order value does a federally funded reagent purchase require price quotes or a sole-source justification under 2 CFR 200.320, and how does an institution set and document its own micro-purchase threshold?

Section 200.320 of the Uniform Guidance sorts federally funded purchases into tiers by value. At the bottom, a micro-purchase can be made without competitive quotes if the price is reasonable. In the middle, small-purchase procedures require price or rate quotations from an adequate number of qualified sources. Above that, formal competition applies, and a noncompetitive award needs one of five stated reasons ^[1].

The regulation does not fix the dollar figures for the lower tiers. It points to the Federal Acquisition Regulation and lets each institution set its own thresholds within that ceiling. So the answer to "how many quotes do I need?" always has two parts: what the federal floor allows, and what your institution's written policy actually says.

The tiers in 2 CFR 200.320

As read on 10 October 2026, section 200.320 divides procurement into informal and formal methods. Informal methods cover micro-purchases and small purchases. Formal methods cover sealed bids and proposals. A fifth category, noncompetitive procurement, sits outside the competition tiers and applies only in the circumstances listed in paragraph (c) ^[1].

The EPA notice on thresholds is a useful secondary reading because it shows how a federal agency explains the same text to its recipients ^[2]. It is written for EPA awards, so treat it as an illustration of the method and read your own agency's guidance for your award.

Micro-purchases and the self-certified threshold

The micro-purchase threshold is the amount at or below which a recipient may buy without soliciting competitive quotes, provided the price is reasonable. Section 200.1 defines it by reference to the FAR figure and says a recipient may use a higher threshold only if requested and approved by the cognizant agency for indirect costs ^[1].

The 2024 revision added a self-certification route. Under paragraph (a)(1), a recipient may self-certify a threshold up to $50,000 on an annual basis. The certification must include a justification, a clear statement of the threshold, and supporting documentation under one of three grounds: the recipient is a low-risk auditee, it has completed an annual internal risk assessment, or, for a public institution, a higher threshold is consistent with state law. Anything above $50,000 requires the cognizant agency's approval ^[1][3].

For the lab, the practical point is that you do not choose the threshold. The purchasing office does, once a year, and publishes it. Ask for the current figure in writing, note the date, and file it with the first order that relies on it. The FAR figure itself is adjusted periodically, so read the current number from the FAR definitions on the live page and not from memory.

Small purchases and how many quotes

Above the micro-purchase level, paragraph (a)(2) requires price or rate quotations from an adequate number of qualified sources ^[1]. The regulation does not say three. It says adequate, which pushes the number into institutional policy. Many universities write it as two or three quotes at defined bands; some accept published catalogue prices from several vendors as quotations.

Record each quotation as a document, not a memory. For a reagent order, a usable quotation shows the vendor's name, the date, the item description and specification, quantity, unit price, freight, and any expiry or validity period. Two quotations for "the same" material are only comparable if the specifications match. If one vendor offers a different purity grade, a different pack size or a certificate of analysis the other does not provide, say so in the selection note.

Lowest price is not always the selection criterion in a small purchase, but the file must show the reasoning when the lowest quote was passed over. A sentence such as "selected the second-lowest quote because only this vendor supplied a lot-matched certificate of analysis before shipment" is enough, provided the requirement is a genuine one and written down before the order.

When sole source is justified

Paragraph (c) lists the circumstances in which a noncompetitive award is allowed. As read on 10 October 2026, they are: the aggregate amount does not exceed the micro-purchase threshold; the item can only be fulfilled by a single source; a public exigency or emergency will not permit a delay for public notice; the federal agency or pass-through entity gives written approval on the recipient's written request; or, after soliciting several sources, competition is determined inadequate ^[1].

For a laboratory the "single source" ground is the one that matters, and it is narrower than it sounds. It applies when the item can only be fulfilled by one source. It does not apply because a lab has used a supplier before, because the supplier's catalogue number is already written into the method, or because switching would be inconvenient. It can apply where a specific lot is required for continuity of a long study and only one vendor holds that lot, or where a proprietary item has no equivalent.

Splitting orders to stay under a threshold

Procurement rules treat the need, not the invoice, as the unit. If a lab needs a quantity of one material and places several smaller orders so each falls under a threshold, an auditor will aggregate them. The same applies to a series of orders on the same day or within a short window to the same vendor for the same purpose.

There are legitimate reasons for several orders: separate projects on separate awards, staged deliveries tied to a stability schedule, or a need that arose after the first order was placed. The test is whether the split has a reason other than the threshold, and whether the file says what the reason was. If you cannot write that reason in a sentence, treat the orders as one.

Institutional policy versus the federal floor

Section 200.320 sets the floor. The institution's written procurement policy is what the auditor tests against first, and it may be stricter than the regulation. Common additions are lower quote thresholds, approved-vendor requirements, mandatory use of a purchasing system, and a requirement that certain categories go through central purchasing regardless of value.

Sponsor policy can add to both. For National Institutes of Health awards, the Grants Policy Statement is part of the terms of award and should be read alongside the institution's policy ^[4]. Where the two differ, follow the stricter one and note the choice in the file.

The procurement file for a reagent order

1. The tier the order falls into, with the institution's threshold document and its date.
2. For a micro-purchase, a note that the price was judged reasonable and how.
3. For a small purchase, the quotations received, the specification each was based on, and the selection note.
4. For a sole-source purchase, the written justification, the evidence of enquiries and the approval.
5. The award number, the approver and the date of approval.
6. The invoice, the proof of receipt and the lot number received.

Keep the file where the person who closes the award will find it. The investigator who placed the order may have left by the time an audit arrives, and the file is only useful if someone else can read it without asking.

What to check next

Ask your purchasing office for three things in writing: the current micro-purchase threshold and the date it was certified, the simplified acquisition threshold, and the number of quotations required in each band. Then add a line to your requisition form for the tier and, where relevant, the sole-source reference. The pillar article on federal grant purchasing sets these steps in the wider allowability picture.