2 CFR 200 procurement file checklist

Federal procurement findings usually come from missing records, not mystery rules. The purchase may have been fair, but the file does not show why the method was allowed, who competed, why the vendor won, or why the price was reasonable.

Use this checklist with the 2 CFR 200 procurement standards guide. For small purchases, also read the micro-purchase documentation guide.

1. Purchase need

Start the file with a short description of what is being bought and why it supports the award. Tie it to the approved budget, work plan, or award purpose. If the item is shared across programs, explain the allocation method.

This step helps prove the cost is allocable. It also helps reviewers catch items that need prior approval before the purchase moves forward.

2. Procurement method

State the procurement method before selection. Common methods are micro-purchase, small purchase, sealed bid, competitive proposal, and noncompetitive procurement.

Use the controlling threshold in your written policy. Federal ceilings are not the only rule. State law, pass-through terms, award conditions, and internal policy can set lower limits.

Keep a short method memo or checklist in the file. It should show the expected dollar amount and why the method fits.

3. Conflict of interest review

2 CFR 200.318 requires written standards of conduct. The file should show that staff checked for real or apparent conflicts. A simple certification can work for routine purchases. Larger or sensitive procurements may need committee disclosure forms.

If a conflict exists, document who was removed from the decision and how the organization protected the process.

4. Competition support

The file should match the method. A micro-purchase file may only need price reasonableness and equitable distribution notes. A small purchase file should include quotes or rate support from an adequate number of sources. A sealed bid or proposal file should include the solicitation, responses, scoring, and award decision.

Keep proof of outreach, not just the winning quote. If a vendor did not respond, keep the email or solicitation log.

5. Sole-source justification

Noncompetitive procurement needs a written basis. The file should state which allowed condition applies: single source, public emergency, agency authorization, or inadequate competition after solicitation.

“We like this vendor” is not enough. “The vendor owns the required software license and no other vendor can provide the maintenance” is closer, but still needs price review and approval.

6. Price or cost analysis

2 CFR 200.324 requires price or cost analysis for procurement actions over the simplified acquisition threshold, including contract modifications. Smaller purchases still need enough support to show the price is reasonable.

Support can include quotes, catalog prices, market rates, prior purchase history, independent estimates, or cost breakdowns. Keep the support in the file.

7. Contractor responsibility

Document that the contractor can perform. Review experience, capacity, insurance, licenses, and other requirements that matter for the work.

For covered transactions, check SAM.gov exclusions when required. Keep the search date and result. Do the check near award, not months before.

8. Approval and contract

Keep approval evidence, the signed contract or purchase order, scope, price, period, and any federal clauses required by the award. If the contract changes, keep the amendment and the reason.

The final file should let a reviewer trace the purchase from need to payment.

9. Match invoices to the file

The procurement file should not stop at award. When invoices arrive, compare them to the contract, purchase order, and approved scope. Confirm the vendor billed the right rate, period, quantity, and deliverable. If the invoice includes extra work, keep the written approval for the change.

This step protects both procurement and allowability. A well-competed contract can still create a questioned cost if the invoice does not match the approved work.

10. Review files before audit season

Do a sample review before the auditor asks. Pick purchases from each federal award and each procurement method. Check whether the file has method support, competition records, price support, conflict review, approval, contract, invoice, and payment proof.

Fix missing internal documents if they exist elsewhere. Do not recreate quotes or backdate approvals. If support is missing, write a truthful note that explains what happened and how the process will change.

Quick file list

• Purchase need and award tie
• Method determination
• Conflict review
• Solicitation or quote records
• Selection memo
• Price or cost analysis
• SAM.gov or responsibility check
• Approval
• Contract, purchase order, and amendments
• Invoice and payment support

How GrantPipe can help

GrantPipe can store procurement support with the award and cost record. That gives grants and finance staff one place to find method, quotes, approvals, and payment support when an auditor samples the transaction.

DEFINITION

Procurement file

The records that show how a federally funded purchase was planned, competed, selected, approved, and priced.

DEFINITION

Price analysis

A review used to decide whether the price is fair and reasonable, based on quotes, market data, history, catalog prices, or other support.