Do I need to disaggregate payments to vendors under $25,000, paid in a previous quarter, if I reach the $25,000 threshold through additional payments in subsequent quarters?
A. The guidance published on June 22, 2009 (M-09-21) allows recipients to aggregate payments to vendors less than $25,000. The guidance does not require recipients to aggregate this information, therefore, recipients may also choose to disaggregate and report all vendors separately.
If a recipient chooses to aggregate this information in a previous quarter, additional vendor payments in subsequent quarters will not automatically trigger the $25,000 threshold and require disaggregated reporting for that vendor. The $25,000 threshold is triggered by individual payments to a vendor within a quarter and not cumulative payments to a vendor over the life of the project. However, the number of aggregated vendor payments and associated dollars should be reported cumulatively in the respective data elements.
For example, if a vendor receives a payment for $17,000 in Q1 and receives another payment for $17,000 in Q2, the vendor does not have to be separately reported in Q2 because the cumulative amount paid over the two quarters exceeds $25,000. The vendor payments in this example can be aggregated in both Q1 and Q2, since the individual payments in each quarter fall under the threshold of $25,000.
If using the same example, but both payments occur within the same quarter, the vendor payments can still be aggregated. For example, if a vendor receives a payment for $17,000 in Q1 from State agency A and $17,000 in Q1 from State agency B, the vendor does not have to be separately reported in Q1 since the individual payments fall under the threshold of $25,000.
