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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?

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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?

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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

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