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    The question is can the SAT be used to contract with subrecipients and contractors under either a grant or a cooperative agreement if the award is less than the SAT threshold of $150,000? Or, is the SAT only to be used for the procurement of goods or services in the support of the grant or cooperative agreement? For example, to purchase office supplies or services such as maintenance? Thank you, K Gilmore


    Answer

    The submitter of this question indicated via a telephone conversation that her nonprofit organization is a recipient of another federal agency's grant or cooperative agreement and that the question relates to provisions in the Uniform Guidance, vice any specific agency's implementation of that guidance.  The simplified acquisition threshold (SAT) is used in the context of both fixed amount subawards (2 CFR 200.201(b) and 200.322) and procurement standards (2 CFR 200.317-200.326).  Section 200.322 of the Uniform Guidance indicates that, with prior approval from the awarding agency, "a pass-through entity may provide subawards based on fixed amounts up to the Simplified Acquisition


    Threshold, provided that the subawards meet the requirements for fixed amount awards in §200.201...."
      Sections 200.201(b) and 200.322 relate only to fixed amount subawards, vice recipient's procurements issued under their federal grants and cooperative agreements.  If a recipient determines, in accordance with 2 CFR 200.330, that a lower tier transactions under their federal award would cast the party receiving the funds in a role of a contractor, vice a subrecipient, and that transaction costs no more than the SAT, the recipient could consider "procurement by small purchase procedures" (2 CFR 200.320(b)), if applicable, as one of the methods that that can be used for the recipient's procurement.  When certain types of recipients (including nonprofit organizations) of a federal agency's grant or cooperative agreement contemplate using the aforementioned "procurement by small purchase procedures", it should be aware of the language in Section 200.318 of the Uniform Guidance indicating, among other things, that the recipient ".... must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part."

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