Procurement compliance for every requisition: the stricter rule applied, the cooperative contract proved to the page, every exception signed
Every federally funded buy documented the day it is requested, with its proof.
See one case, screen by screen ↓Procurement compliance is proving that every purchase followed the rules that govern it: the state's bid law, the institution's purchasing policy and, whenever a federal grant pays any part of it, the Uniform Guidance procurement standards in 2 CFR 200.318–327, with the stricter rule applying. Procurement Compliance Review puts eight agents in front of that proof, so a buyer decides with every test cited and the Director of Purchasing signs every exception.
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Procurement compliance in a college or school district means every purchase satisfies two rule books at once: the state's bid law and, whenever a federal grant pays any part of it, the Uniform Guidance procurement standards in 2 CFR 200.318–327. When they differ, the stricter one wins. Since October 1, 2025 the federal micro-purchase threshold is $15,000 and the simplified acquisition threshold $350,000, so purchasing policies, quote rules and training written before then are out of date.
Most purchases ride a cooperative contract, which is lawful only if the cooperative competed it, the college is an eligible user, the contract is in term and the vendor's quote matches the price sheet. Those four facts sit in four different PDFs. A buyer proves them by hand, splits hide in plain sight under the micro-purchase threshold, sole-source files are written after the fact, and the Single Audit sample finds the gaps a year later. Procurement Compliance Review puts eight agents in front of that reading, so a buyer decides and the Director of Purchasing signs.
Estimated split of a buyer's hours on one federally funded cooperative purchase, by hand and with the agents, in hours. Our arithmetic, kept modest; the solution's own clock is three business days from budget approval.
Eight agents read the funding, prove the cooperative contract and match the quote; a buyer prepares and the Director signs every exception.
Requisition R-26-04417 asks Brandvale Community College for 14 vertical machining centers for the Advanced Manufacturing lab, $212,480 from Tolvane Machine Tool Supply. Here is what happens to it on Wednesday, October 21, 2026, screen by screen, in the working solution.
186 requisitions are open, and the agents checked 212 overnight against the thresholds, the cooperative contracts and the federal rules. 17 need a buyer, 4 wait for the Director's signature and 23 are ready to release. The grants system answered slowly before dawn, so six federally funded requisitions will be checked again at 10:00 AM, and none was released.
The account string splits the purchase: 60%, $127,488, from the Perkins V Basic Grant and 40%, $84,992, from the state capital equipment allocation. The pin at $212,480 sits above the $15,000 micro-purchase threshold and below the $350,000 simplified acquisition threshold on the federal lane, and above the $100,000 formal bid threshold on the state lane. The federal rule alone would need quotes; the state needs a formal bid.
The stricter rule applies: Formal bid — met by cooperative contract IEPC-24-118, formally competed under RFP 23-41.
Turning off "Federal money pays" dims the federal lane. The method stays a formal bid, but five tests fall away: the federal share, the federal contract clauses, the anti-lobbying certification, the exclusion check and the equipment record. Each of them applies only because federal money pays.
The agent read contract IEPC-24-118: awarded under RFP 23-41 (award record, page 1), in term from March 1, 2024 to February 28, 2027 (section 1.4, page 2), federal clauses in Exhibit F (page 31). Clicking the eligible-user test opens section 2.3 on page 4 with the line highlighted: public and private nonprofit institutions of higher education may purchase under the contract.
Quote Q-55102 prices the TM-VMC 30 at $15,177.14 a unit "at IEPC pricing". Line 7 of the contract's price sheet lists $14,120, with the same delivery, installation and training. That is $1,057.14 a unit and $14,800 on 14 units over, $8,880 of it federal; at the contract price the requisition would be $197,680.
Never takes "coop pricing" on a quote as proof.
Lena prepares the hold with reason code PC-03, "Quote above the cooperative price sheet". The agent drafted the note asking the vendor to re-quote at $14,120 a unit by October 23, 2026, with both pages cited, and the note to the requester explaining the one reason. Sign is locked for the person who prepared it.
Marcus signs the hold at 9:20 AM. At 9:21 AM the requisition is back in the buyer's queue and the vendor is asked to re-quote. Requester, buyer and approver are Dr. Rafael Quintero, Lena Ostrowski and Marcus Odell: three people, always.
Three lab-casework orders from Summit Lab Furnishings in eight days, $13,900, $12,980 and $14,650, each sit under the $15,000 micro-purchase threshold and add up to $41,530 on a federal grant. The agent proposes holding the third and combining them into one quoted purchase, with confidence 0.93; the buyer confirms the split with PC-05 or dismisses it with a reason.
For 24 welding simulator licenses, $38,750 on the Perkins grant, the agent drafted the single-source file under 2 CFR 200.320(c)(2): why only one source, three alternatives checked, and a price 4.2% above last year and 4.5% under list. Only the Director can approve it, ask for more, or reject it with a code.
The external auditor sampled 40 federally funded purchases from fiscal year 2026. The evidence agent builds one section per purchase: the method, the quotes or contract proof, the exclusion check as of the award date and both signatures. 37 are complete, 2 need a document already found, and 1 is open.
Pack ready: 40 sections, 612 pages, with two student names redacted.
The same requisition, seen by the four people who carry it: what their day looked like, and what it looks like now.
Eight agents read the funding, prove the cooperative contract and match the quote; a buyer prepares and the Director signs every exception.
Treats one requisition as one unit of work: runs the other agents in order, keeps the three-day clock and assembles the file.
Reads the account string and the grants system, finds the federal share and the award, places the purchase on both rule lanes and applies the stricter.
Reads the cooperative's award record, eligible-user clause, term, federal clauses and price sheet, and matches the vendor's quote line by line.
Checks the quote file for an adequate number of qualified sources, records no-bids with their written replies, and drafts the price analysis.
Watches 30 days of orders and purchasing-card charges for the same vendor and item class kept under a threshold, and draws the running total.
Drafts single-source and emergency justifications with market research and price reasonableness, citing the condition in 2 CFR 200.320(c).
Checks the federal exclusion list, the anti-lobbying certification, conflict-of-interest disclosures and student-data agreements, and records the date of every check.
Assembles the pack for each purchase the auditor samples, and the year summary, from what was recorded the day it was bought.
Signs every exception; never his own purchase. The agents propose; a named person decides.
The assistant answers from the same records the agents read, citing the page, and opens the screen that shows it.
Why is R-26-04417 being held?
Because Tolvane quoted $15,177.14 a unit "at IEPC pricing", and the contract price sheet lists $14,120 (Attachment C, page 2, line 7): $14,800 over on 14 units, $8,880 of it federal. Nothing else is open: the cooperative competed the contract, the college is an eligible user, and it is in term.
Which purchases look split this month?
Two clusters need a decision. Summit Lab Furnishings: three lab-casework orders from Biology in eight days, $13,900, $12,980 and $14,650, each under the $15,000 federal micro-purchase threshold and $41,530 together on a federal grant. And two purchasing-card charges at Ridgeway Office Interiors a day apart, each under the $5,000 limit.
Draft the sole-source justification for the welding simulators
It is drafted. The renewal qualifies under 2 CFR 200.320(c)(2): the software runs only on the 24 installed VirtuArc stations, and VirtuArc sells renewals direct. Three alternatives were checked; replacing the stations would cost an estimated $186,000. The price is 4.2% above last year and 4.5% under list. Marcus Odell decides.
Build the pack for the auditor's 40 sampled purchases
Building it from what was recorded the day each purchase was made: the method, the quotes or contract proof, the exclusion check as of the award date and both signatures. 37 are complete, 2 need a document already found, and 1 is open: PO-26-04071, a possible split.
13 screens from the working solution, on its sample data. Pick one to see it large.
What the purchasing office decides for itself. Every change is versioned, dated and written to the audit trail.
| Setting | Default | Choose from |
|---|---|---|
| Federal micro-purchase threshold | $15,000 | The college may set it lower; never higher without a self-certification under 2 CFR 200.320 |
| State formal bid threshold | $100,000 | Set to the state's bid law for community colleges |
| Apply the stricter rule when federal money pays | Always on | State bid law and 2 CFR 200.318–327, test by test |
| College quote rule | 3 quotes | 2 quotes · 3 quotes · 3 quotes over $25,000 only |
| Requisition to a checked method | 3 business days | 2 · 3 · 5 business days, counted from budget approval |
| Split-purchase window | 30 days | 30 · 60 · 90 days |
| Keep procurement records | 5 years, state schedule | 3 years from the final expenditure report (2 CFR 200.334) · 5 years · 7 years; legal hold; redact on export |
| A person reads the page below confidence | 0.85 | Version pinned per requisition; every override carries a reason code |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
Sources: 2 CFR 200.318–327 and 200.320 (procurement standards and methods, revision effective October 1, 2024) · 2 CFR 200.1 and the FAR inflation adjustment of October 1, 2025 ($15,000 micro-purchase, $350,000 simplified acquisition) · 2 CFR 200.334 (records) · Federal Audit Clearinghouse finding 400414 (FY2023, a school district: eight vendors without adequate small-purchase quotations, $88,074 questioned in a 35-transaction sample, a repeat of the prior year's finding) · "target" = design goal, measured in the live solution · "demo" = seen in the working solution, on its sample data · "typical" = published figures · "estimated" = our arithmetic, kept modest. Brandvale Community College, its vendors and cooperatives, and the people named on this page are fictional: characters and sample data in the working solution.
Procurement compliance is proving that every purchase followed the rules that govern it: the state's bid law, the institution's purchasing policy and, whenever a federal grant pays any part of it, the Uniform Guidance procurement standards in 2 CFR 200.318–327, with the stricter rule applying. Procurement Compliance Review puts eight agents in front of that proof, so a buyer decides with every test cited and the Director of Purchasing signs every exception.
Since the FAR adjustment of October 1, 2025, the federal micro-purchase threshold is $15,000 and the simplified acquisition threshold is $350,000; above it, a formal method is required for federal money. The state's own formal bid threshold often sits lower, so the solution places every requisition on both lanes and applies the stricter. An institution may set the micro-purchase threshold lower, and every change is versioned.
A split purchase is one need bought as several smaller orders, each under a threshold, so that the quotes or bid the full amount requires are skipped. The split-purchase agent watches 30 days of orders and purchasing-card charges for the same vendor and item class, draws the running total against the threshold, and proposes combining them. The buyer confirms or dismisses with a reason; the agent never cancels an order.
A piggyback is lawful only if the cooperative competed the contract, the college is an eligible user, it is in term and the quote matches the price sheet. The piggyback agent reads the award record, the eligible-user clause, the term, the federal clauses and the price sheet, cites each to its page, and matches the vendor's quote line by line. It never takes "coop pricing" on a quote as proof.
No. The agents read, match and draft: holds, notes to vendors, sole-source and emergency files, price analyses and audit packs. Releasing a purchase order, signing an exception and dismissing a split are people's actions, and below a confidence of 0.85 a person reads the page.
Yes. The buyer prepares each decision with a reason code, the Director of Purchasing and Contracts signs every exception and every batch release, and the grants compliance accountant confirms federal allowability. Requester, buyer and approver must be three different people, and the system locks the sign button for anyone else.
Yes. The micro-purchase and state formal bid thresholds, the college quote rule, the clocks, the split-purchase window, who signs exceptions, student-record masking, retention and the agents' confidence threshold are all settings, versioned and on the audit trail. Applying the stricter rule when federal money pays is always on.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your purchasing policy, your state's bid law, your cooperative contracts and a sample of past requisitions. It goes live once every quality gate has passed, and we will walk you through it on your own requisitions first.
Repeat findings caught two months before fieldwork, each with a signed plan.
1-min demoSection 117 Foreign Gift ReportingNo foreign source missed or understated, every reported line traced to its record.
1-min demoFacility Condition AssessmentCapital dollars go to the riskiest systems first, and every rank shows its proof.
1-min demoWe'll run Procurement Compliance Review on a sample of your own requisitions, cooperative contracts and quotes.