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For recipients of federal awards · Enterprise
The independent cost estimate your federal grant asks for, with the prices behind it.
Cities, counties, districts, utilities, transit agencies, airports and school districts that spend federal award money must analyse the cost or price of larger procurements. This package is built to document the independent estimate that 2 CFR 200.324(a) requires: a pre-bid estimate built from what public agencies actually awarded for the same items, a post-bid price analysis, and price checks on change orders, with a link to the source document behind every number.
Request the package Check coverage for your item list (free)
The rule
“The recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals.”
2 CFR 200.324(a), as read on ecfr.gov on 2026-10-28 (eCFR, section version dated 2024-10-01 (current to 2026-10-26)). Read it on eCFR. The simplified acquisition threshold is $350,000 (48 CFR 2.101); a recipient may set a lower one.
Who it applies to
It applies to a recipient or subrecipient of a federal award, for the award terms and the program it came from. FEMA, for one, tells recipients to follow the federal procurement standards at 2 CFR 200.317–200.327 and to formulate an independent cost estimate for procurements over $350,000 (FEMA: Purchasing Under a FEMA Award, read 2026-10-28). Other federal programs carry their own award terms; check yours.
What is in the package
A. Pre-bid independent cost estimate
PDF and Excel from your item list (item, quantity, unit). One row per line with low / likely / high unit prices (25th / 50th / 75th percentile of comparable winning bids), quantity extensions, a contingency you set, optional escalation to the bid date with the Cost Index (Beta), a basis-of-estimate sheet, a receipts appendix, a block for your certification and a document ID with a creation time. A line with no public comparable is left for your own price. Coverage is stated plainly: how many lines and what share of the total.
B. Post-bid cost or price analysis
PDF and editable Word file from the all-bidder tabulation. Each bidder against the estimate; a banner when only one bid arrives; lines outside the 25th–75th percentile range; a front-loading check; a quantity-sensitivity test (does the low bidder change if flagged quantities move 10, 20 or 30%); a draft reasonableness paragraph for you to edit; every comparison linked to its source tab. The same analysis is available alone, for projects without federal money, as a bid evaluation memo.
C. Change-order price checks
For 12 months on the same project: upload the change-order lines and each unit price is set against the awarded range for that item. One page per change order. 2 CFR 200.324(a) covers contract modifications.
Samples
Both are built from a real public project, Allegan County Road Commission contract LH 400194 (bids opened 2026-04-15, tabulation published by the agency). Marked SAMPLE: the agency did not use Hubstake. The sample estimate was made after the bid opening and says so on its first page, which is what the document does when that happens.
Sample estimate (PDF) Sample estimate (Excel) Sample post-bid analysis (PDF) (Word)
Access
- Parts A, B and C are done for you on Enterprise: use the request form and we reply with a quote.
- Free for anyone: upload an item list in Benchmark and see how many lines have a comparable and how confident each is. No prices are shown without full access.
- All-staff Enterprise licences include unlimited packages for the agency.
- The first package is free for a public agency: one per agency, from an account on a .gov or .us email address.
- Your item list and tabulations stay private to your account. They are not added to the index and not published.
Free: independent estimate determination form
A blank, generic form for the procurement file: who made the estimate, when, from what, and before which bid deadline. PDF · Word.
Unbalanced bids
For federal-aid highway contracts, 23 CFR 635.102 defines a mathematically unbalanced bid as “a bid containing lump sum or unit bid items which do not reflect reasonable actual costs plus a reasonable proportionate share of the bidder's anticipated profit, overhead costs, and other indirect costs.” and a materially unbalanced bid as “a bid which generates a reasonable doubt that award to the bidder submitting a mathematically unbalanced bid will result in the lowest ultimate cost to the Federal Government.” (eCFR). The analysis flags lines and tests quantities against those definitions; it does not decide that a bid is unbalanced.
Questions
What does 2 CFR 200.324(a) require?
It says the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, above the simplified acquisition threshold, and that "as a starting point" it must make independent estimates before receiving bids or proposals. The text is quoted above from eCFR.
What is the simplified acquisition threshold?
The FAR figure is $350,000 (48 CFR 2.101 as read on ecfr.gov; the section lists exceptions). 2 CFR part 200 uses that figure, and a recipient may set a lower one. Check your own procurement policy.
Does this package guarantee that we meet the rule?
No. Hubstake supplies historical public prices and a draft built to document the independent estimate. The agency reviews each line, enters its own price where there is no public comparable, and makes and certifies its own estimate. Not legal advice.
How does the document show the estimate came before the bids?
Every document carries an ID and a creation time (Eastern). The public page hubstake.io/doc/<ID> confirms the ID, the creation time, the project title and the number of lines, and shows no prices. If the expected bid opening is already past when a document is generated, the document says so on its first page.
What if there is no comparable price for a line?
The line says "No public comparable: enter your engineer's price" and is left for you to fill. Hubstake never fills a line silently. Lump sums and allowances are never benchmarked.
Where do the prices come from?
From winning bids in public bid tabulations, each linked to the agency's own document. A range needs 8 or more awarded bids from 5 or more projects of the same agency; otherwise up to 5 observed awarded bids from the same or a bordering state in the last 5 years are shown, labelled as observed bids, not an estimate. Engineer's estimates and losing bids are never used.
Is my item list kept private?
Yes. Uploaded item lists and tabulations are private to your account, are not added to the index, and are not published.
Request the package
No payment here. Tell us the agency, the project, the funding program, roughly how many lines and the bid opening date; we reply with how to send the file and a quote.
Hubstake supplies historical public prices and a draft. The agency makes and certifies its own estimate. Not legal advice.