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Written procurement history

In accordance with 2 CFR 200.318 General Procurement Standards, the subrecipient shall retain records of the procurement process. The records should include, at a minimum: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (Independent Cost Estimate (ICE) and Price or Cost Analysis). For procurement document retention schedules, refer to the TxDOT PTN Master Grant Agreement. 


The subrecipient should review their organizational and community needs to determine what goods, services, or equipment are needed for business-related operations. Once a decision has been made, the subrecipient shall also determine if the item is considered a reasonable expense. For more information,  see §200.404 Reasonable Costs.

Independent cost estimate

ICE is a tool to assist in determining the reasonableness or unreasonableness of the bid or proposal being evaluated and is required for all procurements regardless of dollar amount.  When completing an ICE, the subrecipient should use:

  • Published price lists.
  • Historical pricing information from contracts awarded by the subrecipient.
  • Comparable purchases by other subrecipients.
  • Engineering estimates.
  • Independent third-party estimates.

Note: The subrecipient should not contact an active vendor that may bid on the solicitation for estimates because that could be a violation of the required full and open competition clause contained within 2 CFR §200.319 Competition.

Procurement method selection and contract type

The subrecipient shall document how the procurement method was selected and verify it is an appropriate method for the goods or services being procured.  


In this section, the subrecipient describes how competition was promoted throughout the solicitation process.