The 2024 Uniform Guidance Revisions: What Changed in Procurement Standards

A policy that cannot say which rule it follows

A finance manager at a grant-funded nonprofit opens the written procurement policy before a monitoring visit and finds it still says "small purchase." The equipment threshold in the policy reads $5,000. The micro-purchase figure reads $10,000. A reviewer from the pass-through entity asks which version of the Uniform Guidance the policy follows, and the manager cannot say. The document is not wrong in spirit. It simply does not record which rule it was written under.

That is a common position after a regulatory revision. The text moved, the policy did not, and nothing in the file shows which rule applied at the time of each purchase. This article walks through what the 2024 revision changed in the procurement standards, which later threshold change sits on top of it, and what to check in your written procedures so you can show which rule you followed.

What the 2024 revision was and when it took effect

OMB published the revision on April 22, 2024 (89 FR 30046, Doc. 2024-07496), and the guidance is now called the OMB Guidance for Federal Financial Assistance. The Federal Register notice gives an effective date of October 1, 2024, and says federal agencies "may elect to apply the final guidance to Federal awards issued prior to October 1, 2024, but they are not required to do so." So the version that matters for your organization is the one named in your award terms.

For anyone searching for the uniform guidance 2024 revisions procurement changes, the practical question is scope. The procurement standards sit in 2 CFR 200.317 through 200.327. Not every paragraph changed, and this article does not claim a line-by-line comparison. Before relying on any summary, including this one, read the current text at eCFR and the Federal Register final rule. eCFR describes itself as authoritative but unofficial; the official edition is the annual CFR on govinfo.gov.

Confirm with your awarding agency or pass-through entity which edition of 2 CFR 200 governs each award, since awards made before October 1, 2024 may remain under earlier terms.

Changes to thresholds and terminology

Several changes are easy to check against your policy.

• Terminology. The current 2 CFR 200.320(a)(2) describes "simplified acquisitions" for the informal method above the micro-purchase threshold and up to the simplified acquisition threshold (SAT), where earlier text spoke of "small purchase procedures."
• Equipment. The definition of equipment in 2 CFR 200.1 now uses a per-unit cost of $10,000 (or the entity's lower capitalization level), where the earlier text used $5,000.
• Single audit. Under 2 CFR 200.501(a), an entity that expends $1,000,000 or more in federal awards in its fiscal year must have a single or program-specific audit. The earlier figure was $750,000. Confirm with your auditor which fiscal year the new figure first applies to.
• Local SAT. An entity sets its own SAT based on internal controls, risk and documented procedures. Under 2 CFR 200.320(a)(2)(ii), it "may be lower than, but must not exceed, the threshold established in the FAR."
• Profit negotiation. The earlier 200.324(b) required profit to be negotiated as a separate element of the price where there was no price competition and wherever a cost analysis was done. The current 200.324 no longer contains that paragraph.
• Geographic preferences. The earlier 200.319(c) required procurements to prohibit state, local or tribal geographic preferences in evaluating bids or proposals, except where federal statutes expressly mandate or encourage them. The current 200.319 no longer contains that paragraph.

A policy that still describes "small purchase procedures," the old equipment figure, separate profit negotiation or a federal geographic-preference ban may predate the revision. Updating the words is simple; the harder part is recording the rule version each purchase followed.

The October 1, 2025 FAR threshold change

A separate change layers on top. The FAR Council's final rule, FAR Case 2024-001 (90 FR 41872, Doc. 2025-16412, published August 27, 2025), raised the micro-purchase threshold from $10,000 to $15,000 and the SAT from $250,000 to $350,000, effective October 1, 2025. The rule implements a statute that requires statutory acquisition-related thresholds to be adjusted for inflation every five years (41 U.S.C. 1908).

2 CFR 200.1 ties the micro-purchase threshold and the SAT to the amounts set in the FAR at 48 CFR part 2, subpart 2.1, so a FAR change flows through to grant recipients. FAR definitions can change again through later rulemaking, so check the current figure when you revise your policy, and ask your awarding agency or pass-through entity which figure applies to your award. For a closer look at the new figure, see the article on the micro-purchase threshold of $15,000.

Two cautions apply. State or local thresholds may be lower, and when both apply the stricter rule governs. Also confirm with your awarding agency or pass-through entity how a change applies to your specific award.

Competition and the 2 CFR 200.319 rule

Secondary keyword searches often land on 2 CFR 200.319 competition, so it is worth stating plainly. Section 200.319(a) requires that all procurement transactions under the federal award provide full and open competition. As noted above, the current text no longer carries the old geographic-preference paragraph. That does not mean local preferences are now allowed everywhere: program statutes, award terms and state law can still limit them, so check before you use one.

Section 200.319(b) also requires that contractors that develop or draft specifications, requirements, statements of work or invitations for bids be excluded from competing on those procurements. Related provisions in 200.325 allow the federal agency or pass-through entity to review technical specifications before solicitation, and the recipient must submit them on request.

For the full method structure, the article on 2 CFR 200.320 procurement methods covers informal, formal and noncompetitive methods.

What to check in your written procedures

Section 200.318(a) requires documented procedures consistent with State, local and tribal laws and regulations and with the standards in 2 CFR 200.317 through 200.327. Use this list as a starting point, then verify each item against current text.

1. Terminology and thresholds. Does the policy use "simplified acquisition" and the current micro-purchase and SAT figures, each with its effective date and citation?
2. Rule record. Does the file record which edition of the Uniform Guidance and which threshold applied to each procurement, so you can show which rule it followed at the time?
3. Method rationale. Section 200.318(i) requires records showing the rationale for the method, the contract type, contractor selection or rejection, and the basis for the price.
4. Evaluation factors. For proposals, 200.320(b)(2)(i) requires identifying every evaluation factor and its relative importance, and 200.320(b)(2)(ii) requires written technical-evaluation and selection procedures.
5. Conflicts of interest. Written standards of conduct, with a bar on participation by anyone holding a real or apparent conflict (200.318(c)).
6. Cost or price analysis. Above the SAT, 200.324(a) requires a cost or price analysis, with an independent estimate made before receiving bids or proposals.
7. Retention. Section 200.334 sets three years from the final financial report unless an exception applies, and local public-records rules may require longer.

For micro-purchases, an entity may self-certify a threshold above the FAR figure, up to $50,000, on an annual basis, keeping documentation available to the awarding agency or pass-through entity and auditors (2 CFR 200.320(a)(1)(iv)). A threshold above $50,000 needs approval from the cognizant agency for indirect costs (200.320(a)(1)(v)). Micro-purchases still need a documented reasonable price (200.320(a)(1)(ii)), and local policy may set a lower limit. Nothing here lets any buyer skip procurement for any purchase, including software.

The article on written procurement procedures under 2 CFR 200 goes deeper on drafting, and the overview of Uniform Guidance procurement standards for nonprofits helps with context.

Why the record matters, and what may still change

Section 200.318(k) makes the recipient responsible for settling the contractual and administrative issues arising from its procurements, including source evaluation, protests, disputes and claims, so its own file is its defense. Remedies for noncompliance under 2 CFR 200.339 include temporarily withholding payments, disallowing costs, and suspending or terminating an award. Scope matters when reading audit data. In a 2023 article, the Washington State Auditor's Office reported that federal procurement was the most common single audit finding it reports, about 26 percent of them, and that figure reflects one state's audits only.

The rules may also move again. On May 29, 2026, OMB published a proposed rule, "Regulation for Federal Financial Assistance" (91 FR 32198), that would revise 2 CFR Part 200 again. It is proposed, not final: as of October 2026 the Federal Register shows no final rule, so check federalregister.gov and confirm the current status with your awarding agency before changing your policy.

A practical habit follows from all this: when a threshold or section changes, date the change in your policy and note which procurements fall before and after it.

Next steps for your policy file

Start with a one-page log of each rule your policy relies on, its citation, its effective date and the date you last checked it. The Written Procurement Procedures Gap Assessment Workbook is designed to help you compare your procedures against the 2 CFR 200.317–200.327 requirements and record the gaps; see its store page, where it is available now. To hear when the evaluation workspace opens, you can join the waitlist.

RFPManagement records and computes. It does not give legal or procurement advice. The award decision stays with your organization.