Federal Funds Purchasing Policy
Purchases funded by federal grants must adhere to regulations found in Uniform Guidance, as outlined in the National Defense Authorization Act (NDAA) – 2 CFR 200.320 – Methods of Procurement to be followed to receive funds and to meet annual audit compliance.
Classifications of Procurement
Micro-purchases – acquisition of supplies or services, purchase dollar amount does not exceed $10,000
Small purchase – acquisition of supplies, services or equipment, purchase dollar amount from $10,001 to $150,000. Price or rate quotations must be obtained from an adequate number of qualified sources prior to completing the purchase.
Sealed bids – acquisitions with purchase dollar amount greater than $150,000, bids must be publicly solicited and a fixed price contract must be awarded to the responsible bidder whose bid is the lower price.
Competitive proposals – acquisitions with purchase dollar amount greater than $150,000 and more than one firm submitting a quote, and either a fixed price or cost reimbursement structured contract is awarded. Contracts must be awarded to the established and responsible firm whose proposal is most suitable to the project, with price and other factors evaluated.
Noncompetitive proposals – acquisitions based on receipt of a proposal from one specialized source. A waiver must be granted. Submission of the Sole Source Justification Form is required.
Additional information on each of these methods is available in Uniform Guidance 200.320 Methods of procurement to be followed https://www.gpo.gov/fdsys/granule/CFR-2014-title2-vol1/CFR-2014-title2-vol1-sec200-320
Guidelines for PIs and other purchasers
Purchase $10,000 or less – use professional judgement or ask Purchasing Director for assistance when evaluating potential suppliers, and utilize discounts offered, if available. Purchase orders are not required. Please note that installment purchases of $10,000 or less for a total purchase amount greater than $10,000 are not micro-purchases.
Purchases $10,001 to $150,000 – a purchase order, at least three price quotes, and details outlining the basis for firm/vendor selections are required prior to completing the actual purchase. Written documentation from vendor’s published price listings, websites, or other advertised pricing in professional journals must be submitted with the purchase order and the purchase must not be made until the purchase order has been approved. The grants office has authority to deny permission for the invoice to be paid from federal funds if the purchase order is not approved prior to the receipt of the invoice. Contact the Purchasing Director, Michael Elliott, for assistance in obtaining three quotes.
Purchases greater than $150,000 – contact Michael Elliott, Purchasing Director, for assistance with the formal bid process. Please discuss your plans for major purchases as soon as possible to allow adequate time for the bidding process to be completed.
In instances when competitive bids are not appropriate, the requirement for obtaining bids may be waived. An exception may be made when a reasonable and valid statement of justification for waiving the bidding process is submitted in writing for approval, using the Sole Source Justification Form.
Examples of purchases that would not require a competitive bidding process:
The vendor or supplier is a sole source for the item to be purchased (specialized piece of scientific equipment, unusual and rarely available used equipment, works of art, specialized service where the contractor or consultant has unique ability or knowledge required to perform the service, purchase of equipment with compatibility requirements).
To request a waiver, complete the Sole Source Justification Form and submit to the Associate Comptroller, Accounting Services.
Do not complete purchase until notification is received that the waiver has been approved.
