AAU, COGR and APLU recommend that OMB raise the micropurchase threshold from $3,000 to $10,000 to reflect current practices. As data supports a higher threshold, OMB should consider future adjustments.
The UG has introduced a category known as “Micro-Purchases,” defined as purchase transactions up to $3,000, below which there is no requirement to document competition. This was not included in the proposed guidance so institutions did not have an opportunity to comment and states are exempt. Most universities presently have thresholds ranging between $5,000 and $10,000. This lower threshold will create a cost of compliance that far exceeds any potential reduction in waste, fraud and abuse that might occur from UG implementation. It will introduce delays that will negatively impact the ability of investigators to obtain research materials in a timely manner and may delay the completion of their projects. OMB should also provide a process to review and approve a micropurchase threshold higher than $10,000 for large institutions that can demonstrate the appropriateness of a higher threshold.