{"requirements":[{"id":"R01","actor":"Recipient","modality":"definition","statement":"The circular applies to any recipient procurement that uses FTA financial assistance, unless FTA specifies otherwise in writing.","source_pages":[15],"quote":"This guidance, unless otherwise specified by FTA in writing, applies whenever a recipient uses FTA financial assistance for its procurement activities."},{"id":"R02","actor":"FTA / Recipient","modality":"condition","statement":"Precedence: where the circular is inconsistent with changes in a statute or regulation, the statute or regulation supersedes the circular. The circular is applicable as of January 17, 2025.","source_pages":[1],"quote":"In cases where this circular is inconsistent with changes in any statute or regulation, the statute or regulation will supersede this circular. This circular is applicable as of January 17, 2025."},{"id":"R03","actor":"Recipient","modality":"condition","statement":"The date of an award, or of an amendment adding funds, may determine which regulatory requirements apply. This is why effective thresholds are supplied as case inputs.","source_pages":[1],"quote":"The date of an award or amendment adding funds may determine the application of the specific regulatory requirements."},{"id":"R04","actor":"Recipient","modality":"definition","statement":"Interpretive rule: mandatory terms (must/shall) describe binding requirements. Permissive terms (may/should) are non-binding guidance that permits discretion.","source_pages":[15],"quote":"should be interpreted only as non-binding guidance, recommendations, or best practices, and permit discretion."},{"id":"R05","actor":"Recipient","modality":"definition","statement":"2 CFR Part 200 incorporates the FAR simplified acquisition threshold and micro-purchase threshold, which may be updated at 48 CFR Part 2. The blueprint does not hardcode these values. Effective thresholds are supplied inputs.","source_pages":[20],"quote":"The Uniform Administrative Requirements (2 CFR Part 200) also incorporate the simplified acquisition threshold and micro-purchase threshold established in the FAR. This threshold may be updated at 48 CFR Part 2."},{"id":"R06","actor":"Recipient","modality":"definition","statement":"The source states a simplified acquisition threshold value as of a specific date. This is a dated reference only and is not used as a hardcoded rule constant.","source_pages":[38],"quote":"Contracts for more than the simplified acquisition threshold ($250,000, as of October 1, 2024)"},{"id":"R07","actor":"Recipient","modality":"obligation","statement":"The recipient shall conduct all procurement transactions under an FTA award in a manner that provides full and open competition.","source_pages":[67],"quote":"The recipient shall conduct all procurement transactions under an FTA award in a manner that provides full and open competition."},{"id":"R08","actor":"Recipient","modality":"obligation","statement":"The recipient must use competitive procedures appropriate for the acquisition. Those procedures must comply with State and local law and with Federal requirements.","source_pages":[73],"quote":"The recipient must use competitive procedures appropriate for the acquisition undertaken. The procedures used must comply with State and local law as well as with Federal requirements."},{"id":"R09","actor":"Recipient","modality":"permission","statement":"The recipient may acquire property and services without competitive quotations only if all of the following are met: (a) State and local law permit it; (b) the value is at or below the current micro-purchase threshold; (c) the recipient considers the price reasonable based on research, experience, purchase history, or other information; and (d) the recipient maintains documents supporting that conclusion.","source_pages":[73],"quote":"If permitted by State and local law, the recipient may acquire property and services valued at or below the current micro-purchase threshold without obtaining competitive quotations if the recipient considers the price reasonable based on research, experience, purchase history, or other information, and maintains documents to support its conclusion."},{"id":"R10","actor":"Recipient","modality":"permission","statement":"The Federal micro-purchase threshold is established in 2 CFR 200.1 and 48 CFR 2.101. The recipient may set for itself a lower or higher micro-purchase threshold.","source_pages":[73],"quote":"The Federal micro-purchase threshold is established in 2 CFR 200.1; 48 CFR 2.101. The recipient may set for itself a lower or higher micro-purchase threshold."},{"id":"R11","actor":"Recipient","modality":"permission","statement":"The recipient may self-certify a micro-purchase threshold up to $50,000.","source_pages":[73],"quote":"Pursuant to 2 CFR 200.320(a)(1), the recipient may self-certify a micro-purchase threshold up to $50,000."},{"id":"R12","actor":"Recipient","modality":"obligation","statement":"The recipient must act on an annual basis and must maintain documentation available to FTA and auditors under 2 CFR 200.334. The source sentence omits the annual action's verb. Treating it as annual self-certification is an interpretation, not a stated fact.","source_pages":[73],"quote":"The recipient must on an annual basis and must maintain documentation to be made available to FTA and auditors in accordance with 2 CFR 200.334."},{"id":"R13","actor":"Recipient","modality":"obligation","statement":"The self-certification must include a justification and a clear identification of the threshold. It must also include supporting documentation of at least one of: (a) low-risk auditee qualification under 2 CFR 200.520 for the most recent audit; (b) an annual internal institutional risk assessment; or (c) for public institutions, consistency of a higher threshold with State law.","source_pages":[73],"quote":"The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: a qualification as a low-risk auditee, in accordance with the criteria in 2 CFR 200.520 for the most recent audit; an annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, for public institutions, a higher threshold is consistent with State law."},{"id":"R14","actor":"Recipient; cognizant agency for indirect costs","modality":"obligation","statement":"A micro-purchase threshold higher than $50,000 must be approved by the recipient's cognizant agency for indirect costs. Thresholds of $50,000 or below fall within the self-certification permission instead.","source_pages":[73],"quote":"A micro-purchase threshold higher than $50,000 must be approved by the recipient’s cognizant agency for indirect costs."},{"id":"R15","actor":"Recipient","modality":"permission","statement":"To the extent practicable, the recipient should distribute micro-purchases equitably among qualified suppliers. This is non-binding guidance.","source_pages":[73],"quote":"to the extent practicable, the recipient should distribute micro-purchases equitably among qualified suppliers."},{"id":"R16","actor":"Recipient","modality":"prohibition","statement":"The recipient may not divide or reduce the size of its procurement merely to come within the micro-purchase limit.","source_pages":[73],"quote":"The recipient may not divide or reduce the size of its procurement merely to come within the micro-purchase limit."},{"id":"R17","actor":"Recipient","modality":"obligation","statement":"For a micro-purchase, the recipient must maintain documents supporting its consideration that the price is reasonable.","source_pages":[73],"quote":"The recipient must maintain documents to support its consideration that the micro-purchase price is reasonable based on research, experience, purchase history, or other information, as required under 2 CFR 200.320(a)(1)(ii)."},{"id":"R18","actor":"Recipient","modality":"permission","statement":"Exception for micro-purchases: the recipient need not justify the procurement method, contract type, or contractor selection or rejection. This takes precedence over the general procurement-history record requirement in R19.","source_pages":[73],"quote":"The recipient need not justify the procurement method used, selection of contract type, or reasons for contractor selection or rejection."},{"id":"R19","actor":"Recipient","modality":"obligation","statement":"General rule: recipients must document the rationale for the procurement method used for each contract. Micro-purchases are relieved of this justification under R18.","source_pages":[26],"quote":"Recipients must document the rationale for the procurement method used for each contract."},{"id":"R20","actor":"Recipient","modality":"condition","statement":"Simplified acquisition procedures are authorized when the aggregate dollar amount is higher than the micro-purchase threshold and does not exceed the simplified acquisition threshold.","source_pages":[74],"quote":"2 CFR 200.320(a)(2) authorizes simplified acquisition procedures when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold as defined in 2 CFR 200.1; 48 CFR 2.101."},{"id":"R21","actor":"Recipient","modality":"permission","statement":"The recipient may set a lower threshold for simplified acquisition procedures.","source_pages":[74],"quote":"The recipient may set a lower threshold for simplified acquisition procedures."},{"id":"R22","actor":"Recipient","modality":"prohibition","statement":"The recipient may not set a simplified acquisition threshold higher than the Federal threshold.","source_pages":[74],"quote":"2 CFR 200.320 does not permit a recipient to set a simplified acquisition threshold higher than the Federal threshold."},{"id":"R23","actor":"Recipient","modality":"obligation","statement":"When using simplified acquisition procedures, the recipient must obtain price or rate quotations from an adequate number of qualified sources. The recipient may use judgment on what number is adequate.","source_pages":[74],"quote":"The recipient must obtain price or rate quotations from an adequate number of qualified sources. The recipient may exercise judgment in determining what number is adequate."},{"id":"R24","actor":"Recipient","modality":"prohibition","statement":"The recipient may not divide or reduce the size of its procurement to avoid the additional procurement requirements applicable to larger acquisitions.","source_pages":[74],"quote":"The recipient may not divide or reduce the size of its procurement to avoid the additional procurement requirements applicable to larger acquisitions."},{"id":"R25","actor":"Recipient","modality":"obligation","statement":"For simplified acquisitions, the recipient must maintain records supporting: (a) the decision to use the procedure; (b) the contract type; (c) the sources solicited; and (d) the reasons for contractor selection or rejection.","source_pages":[74],"quote":"The recipient must maintain records to support its decision to use the simplified acquisition procedure, the selection of contract type, the sources solicited, and the reasons for contractor selection or rejection."},{"id":"R26","actor":"Recipient","modality":"permission","statement":"Under the exceptions to full and open competition, micro-purchase procedures that do not require competition may be used when the aggregate amount does not exceed the micro-purchase threshold.","source_pages":[80],"quote":"When the aggregate amount of the procurement transaction does not exceed the micro-purchase threshold"},{"id":"R27","actor":"Recipient","modality":"prohibition","statement":"A recipient must not divide a known requirement into smaller purchases for the purpose of avoiding competition requirements.","source_pages":[80],"quote":"A recipient must not divide a known requirement into smaller purchases for the purpose of avoiding competition requirements."},{"id":"R28","actor":"Recipient","modality":"permission","statement":"The recipient should consider consolidating or breaking out a procurement for economy. Breaking out procurements may be legitimate, for example to increase DBE and small-business participation. Splitting is therefore not prohibited in itself; only the stated anti-avoidance purpose is prohibited.","source_pages":[32],"quote":"The recipient should consider whether to consolidate or break out the procurement to obtain a more economical purchase."},{"id":"R29","actor":"Recipient","modality":"permission","statement":"Legitimate break-outs are recognized as able to provide opportunities for DBEs and other small firms.","source_pages":[32],"quote":"In other circumstances, breaking out procurements may provide greater opportunities for Disadvantaged Business Enterprises (DBEs)"},{"id":"R30","actor":"Recipient","modality":"prohibition","statement":"Guidance: a recipient should not split a large procurement merely to use the informal methods available below the simplified acquisition or micro-purchase thresholds.","source_pages":[32],"quote":"However, a recipient should not split a large procurement merely to take advantage of the informal procurement methods available for procurements below the simplified acquisition threshold or micro-purchase threshold."},{"id":"R31","actor":"Recipient","modality":"obligation","statement":"A cost or price analysis is required for every procurement action above the simplified acquisition threshold, including contract modifications and option exercises.","source_pages":[84],"quote":"2 CFR 200.324 requires the recipient to perform a cost analysis or price analysis in connection with every procurement action, including contract modifications and options exercises, in excess of the simplified acquisition threshold."},{"id":"R32","actor":"Recipient","modality":"condition","statement":"Reverse auctions may be used only for procurements at or below the simplified acquisition threshold.","source_pages":[27],"quote":"Recipients may use reverse auctions only for procurements at or below the simplified acquisition threshold."},{"id":"R33","actor":"Recipient","modality":"definition","statement":"Documentation should be commensurate with the procurement. For example, a receipt may suffice for a small credit card purchase.","source_pages":[26],"quote":"For example, a receipt or bill accompanying a $100 credit card purchase might contain all the required information to support that procurement."},{"id":"R34","actor":"Recipient","modality":"permission","statement":"If Federal requirements conflict with State or local requirements, the recipient should promptly notify the FTA regional office in writing.","source_pages":[21],"quote":"If Federal requirements conflict with State or local requirements, the recipient should promptly provide written notification to the FTA regional office responsible for administering its award."},{"id":"R35","actor":"State or Indian Tribe recipient","modality":"obligation","statement":"A State or Indian Tribe must use the same procurement policies and procedures it uses for acquisitions not financed with Federal assistance.","source_pages":[16],"quote":"a State or Indian Tribe must use the same procurement policies and procedures that it uses for acquisitions not financed with Federal assistance."},{"id":"R36","actor":"Recipient","modality":"obligation","statement":"Recipients are required to self-certify annually that their procurement systems comply with Federal regulations.","source_pages":[23],"quote":"Recipients are required to annually self-certify that their procurement systems are in compliance with Federal regulations"}],"process":[{"id":"P01","action":"Confirm the procurement uses FTA financial assistance and is in scope of the circular.","requires":[],"source_pages":[15],"quote":"This guidance, unless otherwise specified by FTA in writing, applies whenever a recipient uses FTA financial assistance for its procurement activities."},{"id":"P02","action":"Identify the applicable source edition and precedence. A statute or regulation supersedes an inconsistent circular. The award date may determine which regulatory requirements apply.","requires":["P01"],"source_pages":[1],"quote":"The date of an award or amendment adding funds may determine the application of the specific regulatory requirements."},{"id":"P03","action":"Take the lawfully effective micro-purchase and simplified acquisition thresholds as supplied case inputs. Do not hardcode or infer them from later law.","requires":["P02"],"source_pages":[20],"quote":"The Uniform Administrative Requirements (2 CFR Part 200) also incorporate the simplified acquisition threshold and micro-purchase threshold established in the FAR."},{"id":"P04","action":"If the recipient proposes its own micro-purchase threshold: a threshold up to $50,000 may be self-certified with a justification, threshold identification and supporting documentation; a threshold above $50,000 requires cognizant-agency approval.","requires":["P03"],"source_pages":[73],"quote":"A micro-purchase threshold higher than $50,000 must be approved by the recipient’s cognizant agency for indirect costs."},{"id":"P05","action":"Determine the aggregate amount of the procurement transaction. Check whether any division or reduction was made merely to come within the micro-purchase limit or to avoid larger-acquisition requirements.","requires":["P03"],"source_pages":[73,74],"quote":"The recipient may not divide or reduce the size of its procurement"},{"id":"P06","action":"Evaluate the micro-purchase route without competitive quotations. This requires: (a) State and local law permit it; (b) the amount is at or below the effective micro threshold; (c) the price is considered reasonable; and (d) supporting documents are maintained.","requires":["P05"],"source_pages":[73],"quote":"If permitted by State and local law, the recipient may acquire property and services valued at or below the current micro-purchase threshold without obtaining competitive quotations"},{"id":"P07","action":"For micro-purchases: maintain price-reasonableness documentation, and distribute purchases equitably among qualified suppliers where practicable. Method, contract-type and selection justifications are not required.","requires":["P06"],"source_pages":[73],"quote":"The recipient need not justify the procurement method used, selection of contract type, or reasons for contractor selection or rejection."},{"id":"P08","action":"Evaluate the simplified acquisition amount band: the amount must be above the effective micro threshold and not above the effective simplified threshold.","requires":["P05"],"source_pages":[74],"quote":"higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold"},{"id":"P09","action":"For simplified acquisitions: obtain price or rate quotations from an adequate number of qualified sources, and maintain the required records.","requires":["P08"],"source_pages":[74],"quote":"The recipient must obtain price or rate quotations from an adequate number of qualified sources."},{"id":"P10","action":"For procurement actions above the simplified acquisition threshold, perform a cost or price analysis and use formal methods. This blueprint's outputs do not authorize those methods.","requires":["P08"],"source_pages":[84],"quote":"2 CFR 200.324 requires the recipient to perform a cost analysis or price analysis in connection with every procurement action"},{"id":"P11","action":"If Federal requirements conflict with State or local requirements, promptly notify the FTA regional office in writing.","requires":["P01"],"source_pages":[21],"quote":"If Federal requirements conflict with State or local requirements, the recipient should promptly provide written notification to the FTA regional office responsible for administering its award."}],"outputs":{"micro_without_quotes_allowed":{"rules":[{"when":{"all":[{"field":"procurement_divided_or_reduced","op":"eq","value":true},{"field":"purpose_avoid_larger_requirements","op":"eq","value":true}]},"value":false,"source_pages":[73],"quote":"The recipient may not divide or reduce the size of its procurement merely to come within the micro-purchase limit."},{"when":{"all":[{"field":"state_local_law_permits_micro","op":"eq","value":true},{"field":"aggregate_amount_usd","op":"lte","value":{"field":"effective_micro_threshold_usd"}},{"field":"price_considered_reasonable","op":"eq","value":true},{"field":"price_reasonableness_documented","op":"eq","value":true}]},"value":true,"source_pages":[73],"quote":"If permitted by State and local law, the recipient may acquire property and services valued at or below the current micro-purchase threshold without obtaining competitive quotations if the recipient considers the price reasonable based on research, experience, purchase history, or other information, and maintains documents to support its conclusion."}],"default":false},"cognizant_approval_required":{"rules":[{"when":{"field":"proposed_micro_threshold_usd","op":"gt","value":50000},"value":true,"source_pages":[73],"quote":"A micro-purchase threshold higher than $50,000 must be approved by the recipient’s cognizant agency for indirect costs."}],"default":false},"simplified_amount_band_eligible":{"rules":[{"when":{"all":[{"field":"aggregate_amount_usd","op":"gt","value":{"field":"effective_micro_threshold_usd"}},{"field":"aggregate_amount_usd","op":"lte","value":{"field":"effective_simplified_threshold_usd"}}]},"value":true,"source_pages":[74],"quote":"2 CFR 200.320(a)(2) authorizes simplified acquisition procedures when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold as defined in 2 CFR 200.1; 48 CFR 2.101."}],"default":false},"artificial_split_prohibited":{"rules":[{"when":{"all":[{"field":"procurement_divided_or_reduced","op":"eq","value":true},{"field":"purpose_avoid_larger_requirements","op":"eq","value":true}]},"value":true,"source_pages":[73,74],"quote":"The recipient may not divide or reduce the size of its procurement"}],"default":false}}}