Grant-funded technology purchases: what records survive an audit?

What does the Uniform Guidance require for technology purchases?

The Uniform Guidance requires a written procurement procedure, a record of how each technology purchase was made, and a property record for anything that counts as equipment. Under 2 CFR 200.318, a nonprofit must "maintain and use documented procurement procedures" for purchases under a federal award or subaward, and must keep "records sufficient to detail the history of each procurement transaction."

Those procurement records must show the rationale for the procurement method, the contract type, why a vendor was selected or rejected, and the basis for the price. The same section says your procedures "must avoid the acquisition of unnecessary or duplicative items," which matters when a program buys software licenses that overlap with tools the organization already pays for.

The rules apply to awards made under the 2024 revision of the Uniform Guidance, which took effect for federal awards issued on or after October 1, 2024. Older awards follow the terms written into them, so check each award before you assume which version governs a purchase.

Which procurement method applies to a laptop, a firewall or a software contract?

The procurement method for a laptop, firewall or software contract depends on the total dollar amount of the purchase. 2 CFR 200.320 sets three tiers: micro-purchases, simplified acquisitions and formal procurement. Each tier carries a different documentation burden.

• Micro-purchases can be awarded "without soliciting competitive price or rate quotations," as long as you keep documents that support your conclusion that the price is reasonable. The threshold is one your organization sets and documents, and it cannot exceed the Federal Acquisition Regulation value unless an exception applies.
• Simplified acquisitions sit above the micro-purchase threshold and below the simplified acquisition threshold. Price or rate quotations "must be obtained from an adequate number of qualified sources."
• Formal procurement is required above the simplified acquisition threshold. These methods are competitive, require public notice, and 2 CFR 200.324 requires a cost or price analysis for each such transaction.

The FAR values changed on October 1, 2025. A Federal Register notice published August 27, 2025 raised the micro-purchase threshold from $10,000 to $15,000 and the simplified acquisition threshold from $250,000 to $350,000, effective October 1, 2025. The Uniform Guidance caps both of your thresholds at the FAR values, and lower thresholds are still allowed. If your written procedure quotes $10,000 and $250,000, confirm that the board chose those figures on purpose and record that decision.

A nonprofit may self-certify a micro-purchase threshold of up to $50,000 on an annual basis. Section 200.320(a)(1)(iv) requires a justification, a clear statement of the threshold, and support such as low-risk auditee status or an annual internal risk assessment. Keep that self-certification with your procurement files, because the rule says it must be available to the agency, the pass-through entity and auditors.

When can you skip competition and buy from one vendor?

You can buy from one vendor without competition only in the five circumstances listed in 2 CFR 200.320(c). Those are a purchase at or below the micro-purchase threshold, a need that only a single source can fill, a public exigency or emergency that will not allow the delay of public notice, written approval from the federal agency or pass-through entity, or inadequate competition after soliciting several sources.

Technology purchases often lean on the single-source reason, for example a renewal of the case management platform your program already runs. That is a reason you write down at the time of purchase, with the facts that support it. A note added after an auditor asks reads very differently from one dated before the invoice.

Is a laptop equipment or a supply under the Uniform Guidance?

In most cases a laptop counts as a supply under the Uniform Guidance. 2 CFR 200.1 defines equipment as tangible personal property, including information technology systems, with a useful life of more than one year and a per-unit cost at or above the lesser of your capitalization level or $10,000. A computing device below that cost is a supply regardless of how long it lasts.

The classification decides which records you need. Equipment carries the property management rules in 2 CFR 200.313(d): a property record, a physical inventory "at least once every two years," a control system to prevent "loss, damage, or theft," an investigation of any loss, and regular maintenance. Servers, storage arrays and network cores bought as one system can cross the equipment line even when no single box does, so record how you priced the unit.

Equipment purchases can also need permission before you buy. Under 2 CFR 200.439(b), capital expenditures for general purpose equipment require prior written approval from the federal agency or pass-through entity, and special purpose equipment needs approval at a unit cost of $10,000 or more. Computing devices treated as supplies, such as laptops, can be charged directly when they are essential and allocable to the award under 2 CFR 200.453(c).

What belongs in a property record for grant-funded equipment?

A property record for grant-funded equipment must include the fields listed in 2 CFR 200.313(d)(1):

• A description of the property and a serial number or other identification number
• The source of funding, including the Federal Award Identification Number (FAIN), and the title holder
• The acquisition date and cost, and the percentage of federal contribution toward the purchase
• The location, use and condition of the property
• Disposition data, including the date of disposal and sale price

Disposition has its own rule. Under 200.313(e), equipment with a current fair market value of $10,000 or less per unit may be retained, sold or otherwise disposed of with no further obligation to the agency. Above that value, the agency is entitled to a share. That is one more reason to record condition and value when a server is retired, alongside the record that its drives were wiped.

Are there vendors you cannot buy from with grant funds?

Yes, grant funds cannot buy covered telecommunications equipment or services. 2 CFR 200.216, which implements section 889 of Public Law 115-232, bars recipients from using grant funds to procure, extend or renew contracts for covered telecommunications equipment or services. The rule names telecommunications equipment produced by Huawei Technologies Company and ZTE Corporation, and, for public safety, government facility security and critical infrastructure surveillance purposes, video surveillance and telecommunications equipment from Hytera, Hikvision and Dahua, including their subsidiaries and affiliates.

This comes up most often with low-cost security cameras, network video recorders and white-label routers, where the manufacturer is not the brand on the box. Ask resellers to confirm the manufacturer in writing and keep that confirmation with the purchase file.

How long do you have to keep these records?

Records for grant-funded purchases must be kept for three years from the date you submit the final financial report for the award, under 2 CFR 200.334. For awards renewed quarterly or annually, the clock starts from each quarterly or annual financial report.

During that period, 2 CFR 200.337(a) gives the federal agency, the pass-through entity, Inspectors General and the Comptroller General a right of access to any records pertinent to the award. Nonprofits that spend $1,000,000 or more in federal awards in a fiscal year also face a single audit under 2 CFR 200.501(a). Quotes saved in one employee's inbox are hard to produce after that employee leaves, so store procurement files in a shared location the organization controls.

What should you do this quarter?

This quarter, update your procurement procedure, decide on a self-certified threshold, organize purchase files by award, reconcile equipment and add a covered telecommunications check. Those five steps cover most of the gap between buying technology and proving you bought it correctly:

• Update your written procurement procedure to the current FAR thresholds of $15,000 and $350,000, or to the lower thresholds your organization chooses, and have the board or finance committee approve the change.
• Decide whether a self-certified micro-purchase threshold of up to $50,000 makes sense, and if so, write the justification and file it.
• Create one folder per award for technology purchases, holding quotes, the selection rationale, the price basis and any single-source justification.
• Reconcile your equipment list against what is actually on hand if you have not done a physical inventory in the last two years.
• Add a covered telecommunications check to your purchase approval step for cameras, routers and phone systems.

Federal awards issued since October 1, 2024 also require "reasonable cybersecurity and other measures to safeguard information" under 2 CFR 200.303(e). If funders are asking about that, our guide to grant application cybersecurity questions covers what to say, and our nonprofit technology budget guide covers planning the spend.

What should your counsel review before a grant-funded technology purchase?

Counsel should review which rules govern each award and each sensitive purchase when a new award arrives and before you approve a purchase that is near a threshold, comes from a single vendor or includes cameras or network gear. Bring these decisions:

• Which version of the Uniform Guidance governs each award, since the 2024 revision applies to awards issued on or after October 1, 2024. Bring the award notices and any amendments.
• Whether a multi-component system counts as one unit of equipment under 2 CFR 200.1 and needs prior written approval under 2 CFR 200.439(b). Bring the quote, your capitalization policy and the approved budget.
• Whether a single-source purchase fits one of the circumstances in 2 CFR 200.320(c). Bring the written justification and the vendor quote.
• Whether a camera, recorder or router is covered equipment under 2 CFR 200.216 for its intended use. Bring the reseller's written manufacturer confirmation and a description of where the device will be used.

How can s90 help?

If an auditor or pass-through entity asked tomorrow for the quotes, selection rationale and property record behind a grant-funded purchase, and nobody could find them, that is where s90 helps. Through Complete IT, s90 manages IT for nonprofits and social service agencies in Los Angeles and Orange County, with proof every quarter that it is working. We keep device and equipment records that line up with your award files, flag purchases that touch covered telecommunications rules, and give your finance team the quotes and asset history an auditor asks for. If a grant-funded technology purchase is coming up, we are happy to talk it through.