Getting a Dental Project Approved Under 2 CFR 200.320: What Your CEO, CFO and Procurement Need to See

Getting a dental improvement project approved at a health center takes three yeses. The CEO needs to see how it expands access, the CFO needs to see the cost and the return, and procurement needs a purchase that follows your written policy and 2 CFR 200.320. A one-page proposal that answers all three keeps the project moving.

Dental directors and dental office managers usually see the problem first: patients waiting weeks for an exam, chairs empty after no-shows, a schedule template that no longer fits the procedures on it. Turning that into an approved project means presenting it to leaders who are weighing the whole organization’s budget and risk. Here is what each of them needs, how the federal purchasing thresholds work, and what to put in a proposal.

Who needs to say yes to a dental improvement project?

In most health centers, three groups weigh in. The CEO decides whether the project fits the organization’s priorities. The CFO decides whether it can be paid for and what it returns. Procurement, which may be one person or a full finance team, confirms the purchase follows your written procurement policy. Larger projects may also need board approval under your bylaws or financial policies.

Each group is answering a different question, and a proposal that answers only one of them tends to stall. Plan for all three from the start.

What does the CEO need to see?

The CEO is looking for the link to the mission and the strategic plan. Lead with access: how many patients are waiting for dental care, how long a new patient waits for an exam, and how many more patients the clinic could see once the problem is fixed.

Use numbers your health center already tracks. No-show rate and encounters per hour are both on NNOHA’s dental dashboard, so leadership may already know them. If the project supports a goal in the strategic plan or a board priority, name it directly.

What does the CFO need to see?

The CFO needs three things: what the project costs, where the money comes from, and what it returns.

• Cost: the full price, including staff time, training and anything recurring.
• Funding source: operating funds, a grant or a mix. This shapes the purchasing rules, because purchases paid with federal grant funds must follow the federal procurement standards described below.
• Return: added encounters, recovered revenue or reduced costs, estimated from your own data.

For many dental projects, the return comes from capacity you already pay for. Unfilled no-shows, same-day gaps and lost recall are the most common places dental chair time leaks, and each recovered visit can be counted. Give a conservative estimate and explain how you will measure it after launch. A CFO will trust a modest number with a clear tracking plan over an ambitious one without it. A weekly scorecard, like the one Elica Health’s office managers review every week, gives you that tracking plan.

How do the procurement thresholds in 2 CFR 200.320 work?

When a health center pays for goods or services with federal grant funds, the federal Uniform Guidance procurement standards apply. 2 CFR 200.320 sets out the purchasing methods, and the dollar thresholds for each one are tied to the Federal Acquisition Regulation. Those thresholds rose on October 1, 2025:

• Micro-purchase, up to $15,000 (previously $10,000): no quotes are required, as long as the price is reasonable and you document how you know.
• Simplified acquisition, above $15,000 and up to the simplified acquisition threshold of $350,000 (previously $250,000): you need price or rate quotes from an adequate number of qualified sources.
• Formal procurement, above $350,000: sealed bids or a publicized request for proposals with written evaluation criteria.

Two points to confirm before you build your plan. First, your health center’s written procurement policy governs. If it still lists $10,000 and $250,000, those are your limits until the policy is updated, and many policies set a specific number of quotes. A health center can also self-certify a micro-purchase threshold of up to $50,000 with a documented risk assessment. Second, every purchase needs a documented cost or price analysis, including small ones.

Your finance team and your notice of award are the final word on which rules apply. This post is general information, not legal advice.

What does procurement need from you?

Procurement’s job is to make sure the purchase holds up in an audit. You make that easier by bringing:

• A clear scope: what you are buying, why, and what success looks like.
• A cost estimate, so procurement can see which threshold applies. Above the simplified acquisition threshold, an independent estimate is required before bids or proposals come in.
• Quotes, if the purchase is above the micro-purchase threshold, from the number of sources your policy requires.
• A written justification if only one vendor can do the work. Noncompetitive purchases are allowed only in limited cases, such as when the item or service is available from a single source.

Bring procurement in early. A short conversation before you collect quotes can save weeks of rework.

What belongs on a one-page proposal for a dental project?

Keep it to one page so each reader finds their answer quickly:

• The problem, in numbers: the wait for a new patient exam, no-show rate, encounters per day.
• The proposed fix and what it includes.
• Who it serves: patient groups, sites and providers affected.
• Total cost and funding source.
• Expected return and how you will measure it.
• Procurement path: the threshold that applies and the quotes or justification you have.
• Timeline and who owns the work.
• The ask: the specific decision you need, and by when.

Build the case for your dental clinic

Optimize works with health center dental clinics on scheduling templates, no-show reduction, team workflows and the scorecards that show results. If your team has a dental project in mind, a Strategy Call is an opportunity to talk through your clinic’s goals and where to start.

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