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To: Sponsors of the Child and Adult Care Food Program, School Nutrition Program and Summer Food Service Programs
From: Oregon Department of Education Child Nutrition Programs
Date: January 21, 2026
Re: Changes in the Federal Procurement Standards
Effective October 1, 2025, the federal Micro Purchase and Simplified Acquisition Thresholds have changed. Review your organization’s Procurement Policies and Procedures to ensure they stay within the federal and state thresholds. As always, local entities may be more restrictive but not less.
Federally funded procurements of goods or services, including USDA Food processed end-products, are subject to two key threshold increases:
- The federal Micro-Purchase Threshold has increased from $10,000 to $15,000.
- The Simplified Acquisition Threshold (SAT) has increased from $250,000 to $350,000.
These adjustments directly affect the competitive procedures Program Sponsors are required to implement by the Federal Procurement Standards in 2 C.F.R. 200.317–200.327 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”).
Micro-Purchase Threshold
2 CFR 200.320 of the Uniform Guidance sets forth the level of competition required for federally-funded procurements based on the dollar value of the goods or services to be purchased. Procurements valued at or below the micro-purchase threshold may be awarded without soliciting price or rate quotations. 2 C.F.R. 200.320(a)(1). The definition of micro-purchase threshold in the Uniform Guidance is pegged to the micro-purchase threshold set forth in the Federal Acquisition Regulation (“FAR”) at 48 C.F.R. Part 2, Subpart 2.1. See 2 C.F.R. 200.1 (Defining Micro-purchase threshold). OMB’s final rule cited above, which increases the micro-purchase threshold in the FAR from $10,000 to $15,000, therefore applies automatically to procurements under the Uniform Guidance, and means Program Sponsors have the authority to amend their current Procurement Policies to increase their micro-purchase threshold in grant-funded procurements to up to $15,000 if it’s consistent with State and local law. Currently the State of Oregon micro-purchase threshold is set at $25,000.
2 C.F.R. 200.320(a)(1)(iv) has an annual self-certification provision that allows Program Sponsors to establish a higher micro-purchase threshold up to $50,000 than the Federal threshold if they meet one of the requirements listed below.
A) A qualification as a low-risk auditee, in accordance with the criteria in 2 C.F.R. 200.520 for the most recent audit;
B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
C) For public institutions, a higher threshold is consistent with State law.
Moreover, the Uniform Guidance requires Program Sponsors to conduct informal procedures, consisting of solicitation of price or rate quotations “from an adequate number of qualified sources,” in federally-funded procurements that exceed the micro-purchase threshold but cost no more than the simplified acquisition threshold. 2 C.F.R. 200.320(a)(2).
Simplified Acquisition Threshold (SAT)
For procurements above the micro-purchase threshold but at or below the SAT, 2 C.F.R. 200.320(a)(2) requires informal procedures—specifically, solicitation of price or rate quotations “from an adequate number of qualified sources.” Procurements above the SAT require more formal processes, such as publicized Requests for Proposals (RFPs) or Invitations for Bids (IFB).
As with the micro-purchase threshold, the SAT definition in the Uniform Guidance is pegged to the SAT set forth in the FAR. 200.1 (Defining Simplified acquisition threshold). Thus, the increase in the SAT in the FAR from $250,000 to $350,000 will apply automatically to grant-funded procurements and means Program Sponsors may amend their Procurement Policies to increase their SAT in grant-funded procurements up to the new $350,000 threshold if it’s consistent with State and local law. Currently, the State of Oregon Simplified Acquisition Threshold is $250,000.
ODE has updated the Procurement Resources available on the ODE Child Nutrition Program Procurement page to reflect these new thresholds.
Sincerely,
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