VCOM Institutional Policy and Procedure Manual

VCOM Federal Funds Procurement Policy

Policy #U005

Purchasing ensures that the price is fair and reasonable. Principal Investigators document these facts and attests that supplier selection and price determination has taken place in accordance with the principles outlined below by initialing or approving the Purchasing Request. Principal Investigators shall check the cost price analysis box on the Purchase Request as evidence that a cost price analysis was done. The cost review for grant/contract compliance shall be conducted by the Office of Research Administration. When federal funds shall be utilized to purchase a single item estimated to cost between $5,001 and $25,000, two (2) verbal quotes shall be obtained by the Principal Investigator and summarized on the Purchase Request. The Purchase Request and accompanying verbal quote documentation shall be forwarded to the Office of Research Administration for review and approval. Upon approval, the Purchase Request shall be forwarded to the Purchasing Department for procurement. When federal funds shall be utilized to purchase a single item estimated to cost above $25,000 (current small purchase threshold), three (3) written quotes from a minimum of three (3) qualified sources on supplier letterhead shall be obtained by Principal Investigator and attached to the Purchase Request and routed to the Office of Research Administration. The Office of Research Administration will review for grant compliance. If approved, the Purchase Request shall be forwarded to the Purchasing Department. The award shall be made to the lowest responsive, responsible sources. For purchase requests above $25,000, VCOM will analyze lease and purchase alternatives to determine which would be the most economical and practical procurement. Purchasing from Commonwealth of Virginia, VCOM, Virginia Tech or other contracts that have been competitively bid or negotiated are exempt from the bidding thresholds discussed herein. The Principal Investigator or the Purchasing Department shall note that one of these types of contracts was employed on the Purchase Request. VCOM Purchasing Department shall maintain the Purchase Request. The Office of Research Administration shall also retain a copy of the Purchase Request as well as all written quotations. If written quotes are not obtained, a sole source justification form shall be provided by the Principal Investigator, attached to the Purchase Request and maintained in the grant files. Written documentation shall include the determination and basis for the proposed sole source procurement and be approved both by the Office of Research Administration and the Purchasing Department. Before purchasing goods through subcontractors, the Office of Research Administration shall review the Excluded Parties List System (EPLS) website available on sam.gov and document that the bidder is neither debarred nor suspended from doing business with the federal government nor delinquent in a debt to the United States as defined in 2.CFR.215.44. Subawards or contracts will not be permitted with parties that are debarred, suspended or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Because specific federal programs require approval from the federal government before engaging in a transaction in which a conflict of interest exists, VCOM shall check with the relevant federal agency before engaging in a transaction with a conflict of interest. Equipment purchased with federal funds is generally considered the property of the recipient unless otherwise indicated in the notice of award. If the equipment will be federally owned, disposition instructions will be followed per the notice of award. 4. ADDITIONAL POLICIES WHEN USING FEDERAL FUNDS TO PURCHASE

5. D URATION OF P OLICY The Federal Procurement Policy established by the Research Office is effective as of the date above and shall remain effective until amended or terminated by the President and the Dean.

VCOM Federal Funds Procurement Policy

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