Purpose of this Article: This solution article provides the recording and answers to questions from the 2025 Fiscal Year End MGO Single Audit Under the Uniform Guidance Live Event held Thursday, May 15, 2025. The deck presented is attached at the bottom of this article.
Audience: All SF Financials and SF Procurement Users
Author: Jessica Berkley
Version/Update Date: 1.0 / May 2025
Q1: Do we need to check SAM.gov for suspension and debarment for procuring materials and supplies with the Micro-Purchase or Small Purchase Procedures procurement methods?
A1: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Specifically, a contract for goods or services is a covered transaction if any of the following applies:
1. The contract is awarded by a participant in a non-procurement transaction covered under § 180.210, and the contract amount is expected to equal or exceed $25,000.
2. The contract requires the consent of an official of a Federal agency. In that case, the contract is always a covered transaction regardless of the amount or who awarded it.
3. The contract is for Federally required audit services.
This can be found in the Code of Federal Regulations at the following link (Title 2 Subtitle A Chapter I Part 180 Subpart B § 180.220): https://www.ecfr.gov/current/title-2/subtitle-A/chapter-I/part-180
So, in general, the requirement for checking for suspension or debarment would apply for contracts/purchases equal to or exceeding $25,000, which exceeds the $10,000 threshold for micro-purchases.