2 CFR 200.325: Federal agency or pass-through entity review

What 2 CFR 200.325 requires

1. Reporting

What you must do

Submit the technical specifications of proposed procurements when the Federal agency or pass-through entity requests review (ideally before specifications are incorporated into a solicitation; post-solicitation reviews are limited to technical aspects), and, when requested, provide procurement documents (requests for proposals, invitations for bids, independent cost estimates) for pre-procurement review. Pre-procurement review may occur when: procurement procedures or operations fail to comply with this part's standards; a procurement expected to exceed the SAT will be awarded without competition or only one bid is expected; a procurement expected to exceed the SAT specifies a 'brand name' product; a sealed-bid procurement expected to exceed the SAT is to be awarded to other than the apparent low bidder; or a proposed contract modification changes the scope or increases the contract amount by more than the SAT.

When it applies

Funder request for review, or any § 200.325(b)(1)-(5) risk condition arising under the award (noncompetitive/single-bid above SAT, brand-name above SAT, other-than-low-bidder sealed-bid award above SAT, scope-changing or above-SAT modification).

Budget justificationDraft solicitation attachments

2. Certifications

What you must do

The entity is exempt from pre-procurement review if the Federal agency or pass-through entity determines its procurement system complies with this part's standards; the entity may request a system review/certification (generally where there is continuous high-dollar funding and third-party contracts are awarded regularly) or may self-certify its system — the self-certification must cite specific policies, procedures, regulations, or standards as complying and keep the system available for review, and does not limit the funder's right to review.

When it applies

The applicant claims a certified or self-certified procurement system to avoid pre-procurement review.

Certifications and assurancesProcurement policy attachment

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Sections 2 CFR 200.325 refers to

2 CFR 200.1 Definitions
2 CFR 200.317 Procurements by States and Indian Tribes

Regulation text of 2 CFR 200.325

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(a) The Federal agency or pass-through entity may review the technical specifications of proposed procurements under the Federal award if the Federal agency or pass-through entity believes the review is needed to ensure that the item or service specified is the one being proposed for acquisition. The recipient or subrecipient must submit the technical specifications of proposed procurements when requested by the Federal agency or pass-through entity. This review should take place prior to the time the specifications are incorporated into a solicitation document. When the recipient or subrecipient desires to accomplish the review after a solicitation has been developed, the Federal agency or pass-through entity may still review the specifications. In those cases, the review should be limited to the technical aspects of the proposed purchase.

(b) When requested, the recipient or subrecipient must provide procurement documents (such as requests for proposals, invitations for bids, or independent cost estimates) to the Federal agency or pass-through entity for pre-procurement review. The Federal agency or pass-through entity may conduct a pre-procurement review when:

(1) The recipient's or subrecipient's procurement procedures or operation fails to comply with the procurement standards in this part;

(2) The procurement is expected to exceed the simplified acquisition threshold and is to be awarded without competition, or only one bid is expected to be received in response to a solicitation;

(3) The procurement is expected to exceed the simplified acquisition threshold and specifies a “brand name” product;

(4) The procurement is expected to exceed the simplified acquisition threshold, and a sealed bid procurement is to be awarded to an entity other than the apparent low bidder; or

(5) A proposed contract modification changes the scope of a contract or increases the contract amount by more than the simplified acquisition threshold.

(c) The recipient or subrecipient is exempt from the pre-procurement review in paragraph (b) of this section if the Federal agency or pass-through entity determines that its procurement systems comply with the standards of this part.

(1) The recipient or subrecipient may request that the Federal agency or pass-through entity review its procurement system to determine whether it meets these standards for its system to be certified. Generally, these reviews must occur where there is continuous high-dollar funding and third-party contracts are awarded regularly.

(2) The recipient or subrecipient may self-certify its procurement system. However, self-certification does not limit the Federal agency's or pass-through entity's right to review the system. Under a self-certification procedure, the Federal agency or pass-through entity may rely on written assurances from the recipient or subrecipient that it is complying with the standards of this part. The recipient or subrecipient must cite specific policies, procedures, regulations, or standards as complying with these requirements and have its system available for review.

Source: eCFR · checked Sep 17, 2026

Questions about 2 CFR 200.325

What does 2 CFR 200.325 require?

Submit the technical specifications of proposed procurements when the Federal agency or pass-through entity requests review (ideally before specifications are incorporated into a solicitation; post-solicitation reviews are limited to technical aspects), and, when requested, provide procurement documents (requests for proposals, invitations for bids, independent cost estimates) for pre-procurement review. Pre-procurement review may occur when: procurement procedures or operations fail to comply with this part's standards; a procurement expected to exceed the SAT will be awarded without competition or only one bid is expected; a procurement expected to exceed the SAT specifies a 'brand name' product; a sealed-bid procurement expected to exceed the SAT is to be awarded to other than the apparent low bidder; or a proposed contract modification changes the scope or increases the contract amount by more than the SAT. The entity is exempt from pre-procurement review if the Federal agency or pass-through entity determines its procurement system complies with this part's standards; the entity may request a system review/certification (generally where there is continuous high-dollar funding and third-party contracts are awarded regularly) or may self-certify its system — the self-certification must cite specific policies, procedures, regulations, or standards as complying and keep the system available for review, and does not limit the funder's right to review.

When does 2 CFR 200.325 apply?

Funder request for review, or any § 200.325(b)(1)-(5) risk condition arising under the award (noncompetitive/single-bid above SAT, brand-name above SAT, other-than-low-bidder sealed-bid award above SAT, scope-changing or above-SAT modification). The applicant claims a certified or self-certified procurement system to avoid pre-procurement review.

Plain-English summaries for information only, not legal advice. Always check the regulation text, your award terms and your agency’s guidance.