Procurement and Purchasing

Policy

Authorities delegated and retained/administrative responsibility

The Board of Trustees delegates administration of the college’s purchasing functions to the president and the vice president for finance and administration/CFO.

Ethics

Purchasing is performed by the Procurement & Accounts Payable in the Finance Department, Facilities Services, Information Technology Services, Student Life, Athletics, and other campus departments. Considerable authority has been entrusted to departments to make purchasing decisions. The convenience afforded by this decentralized environment is coupled with full responsibility for decisions and complete understanding of the college’s procurement and purchasing policies and procedures. All purchasing decisions should be made in the college’s best interests.

1. a.      Conflict of interest

The college expects that all procurement is administered in accordance with its Code of Ethical Conduct and Conflict of Interest policy.

Colorado College generally does not enter into contracts with students, faculty, and staff or members of their immediate families. In rare instances in which a purchase is in the best interest of the college, documentation of the reasons for the decision to pursue such a contract needs to be sent to the manager, procurement & accounts payable for approval before the transaction or purchase is made.

1. b.      Confidentiality

When discussions arise between vendors and the college, representatives of the college are to protect a vendor’s confidentiality as well as the interests of the college by refraining from disclosing prices, terms, or conditions quoted by other vendors.

1. c.      Segregation of duties

Departments involved in purchasing are to ensure that the responsibilities of purchasing, receiving, and authorizing payment for goods or services are not performed by the same individual.

Purchasing programs and initiatives

There are a variety of considerations to be made with purchasing programs and initiatives.

2. a. Purchasing agreements

Where there are cost savings or net rebates associated with purchasing cooperatives, the college participates in purchasing agreements. The manager, procurement & accounts payable approves these memberships.

2. b. Supplier diversity

The college is committed to developing mutually beneficial relationships with small, minority-owned, women-owned, disadvantaged, veteran-owned, and local business enterprises.

2. c. Sustainable procurement

When possible, the college considers environmental impact in purchasing decisions. The use of products and services with less environmental impact will be considered favorably when it is a best-value decision to do so. Factors included in the decision are: energy efficiency; shipping materials (returnable, reusable, or made from recycled content); and environmental performance of the supplier/producer (waste prevention, waste reduction, pollution prevention, clean air/water programs, and other initiatives).

Tax exemption

3. As a 501 (c)(3) entity, Colorado College is exempt from paying sales tax in the city of Colorado Springs, the state of Colorado, and other states where the college has filed for an exemption. 

Purchasing methods

4. Once the need for goods or services has been identified, those authorized to purchase have several purchasing methods available to them:

4.a. Purchasing card

The college’s Purchasing Card Training Guide describes appropriate use of purchasing cards beginning with issuance and concluding with card deactivation.

4.b. Purchase requisitions

Purchase requisitions/orders are required for all single purchases, services or contractual agreements in excess of $25,000. The purchase requisition must be accompanied by documentation of competitive bidding. Three bids are required or a Request for Sole Source/Single Source Procurement Form must be submitted as outlined in the procedures section.

4.c. Purchase orders

Purchasing & Accounts Payable reserves the right to issue a purchase order or make payment centrally.  Purchase orders or authorizations must be completed before the time of purchase and forwarded to Procurement & Accounts Payable for review and approval prior to purchase of the goods.

1. Regular order: created from purchase requisitions. The purchase requisition and the supporting documentation of the purchase requisition become support for the purchase order.
2. Blanket purchase order: This should be used for repetitive purchases, or for a particular supplier of goods or services which may include multiple shipments. Blanket purchase orders should include: the time period for the performance; clear indication of the purpose of the blanket; the not to exceed amount for the blanket; the scope of goods or services to be included or excluded; the person authorized to issue releases against the blanket. At the end of the fiscal year, all blankets will be closed and reopened with new blanket purchase order numbers. Each department is responsible for the re-issuing of all blanket orders for the following fiscal year; prior approval from the person initially approving the transaction is required to extend expenditures beyond the fiscal year end.
3. Change order: issued to document an amendment to an existing “open” purchase order. Changes may pertain to product specifications, scope of work, standards, terms of agreement, unit pricing, or total cost. Change orders will not be processed once an order is complete; a new requisition/purchase order is required.

Purchases

5. a. Information technology

All technology, software and audio/visual equipment that will be purchased with college funds must be acquired through Information Technology Services. If a contract relates to Information Technology, the requestor should create a tech adoption request in accordance with the Technology Adoption Policy before following standard contracting approval and authorization processes.

5.b. Purchases on government grants and contracts

Members of the college community seek federal and state grants for sponsored projects such as academic research. Please consult with one of the college’s grants professionals – the director of corporate and foundation relations or the director of sponsored research – well in advance of submitting any grant proposal to a government agency.  Grants to government agencies must be submitted by an “authorized organizational representative” (AOR).  The president of the college has delegated institutional signatory authority for all documents that obligate the college to activities featuring federal sponsors, irrespective of the title or designation of the document: e.g. “proposals,” “award agreements,” and “amendments” are all covered herein. Please see the college’s policy on Signature Authority for Government Grants.

In carrying out its sponsored projects, the college complies with the terms of the agreement. These terms may be stated in the sponsored project agreement as well as in statutes, regulations, and policy statements.

When making purchases with federal and state grants, there are a number of requirements including:

1. Flowdown of terms and conditions: A grant or contract may require the college to include certain contractual clauses in purchase orders or subcontracts issued under the award. The director of sponsored research identifies when these requirements need to be included in the purchase order;
2. Prior approval: A government representative may be required to approve a proposed purchase of capital equipment or complex goods or services before the college places the order;
3. Document retention: If a purchase requires government approval of subcontract provisions, the buyer will obtain necessary approval and retain that documentation. The requesting department is responsible for maintaining records of approval documentation. Documentation should be retained for a minimum of three years from the date of the last financial report on the grant. When required, Procurement & Accounts Payable may request copies of these documents.

Purchases made when procuring property or services under a federal award and made with federal funds must follow the Procurement Standards under the federal government’s Uniform Guidance 2 CFR 200. The procurement standards are located within the Uniform Guidance in Subpart D, sections 200.317-200.326.   The college’s Purchasing Guidelines for Purchasing Made with Federal Funds are also available on the Research Compliance website. In particular we need to ensure:  

1. Reasonable Prices and Rates: When hiring contractors or making purchases with vendors using federal funding, we need to ensure that we are obtaining reasonable prices and rates. This entails obtaining at least two quotes. While this can be done informally – such as via a phone call or web search – capturing these quotes must be documented. Please contact the Director of Sponsored Research for detailed guidance.
2. Pre-requisition screening: Existing inventory of capital equipment should be screened for availability before ordering by contacting Facilities Services. Per Uniform Guidance 2 CFR 200.318, this prevents the purchase of “unnecessary or duplicative items.”

Leases

6.a. Vehicles

Facilities Services coordinates the lease or purchase of all campus vehicles and obtains approval from the vice president for finance and administration. Once the required reviews have been completed, Facilities Services processes the lease/purchase via a purchase order.

6.b. Equipment

Equipment may be financed using various types of leases and should be coordinated through Facilities Services or the vice president for finance/CFO.  Facilities Services will issue a purchase order for the overall amount of the lease and provide oversight of the lease until the exchange of ownership documentation takes place.

Roles and responsibilities

7.a. Role of Requestor

The requestor has first-hand knowledge of the goods or services being purchased. The college relies on the requestor to have made determinations of appropriateness before initiating the purchase. For items with a value of more than $1,000, it is usually expected that a requestor will have discussed the purchase with their supervisor or chair of their department prior to expending funds. 

7.b. Role of Approver

The approver is the supervisor, manager, vice-president, department chair or dean of the requestor. As part of the approval process, the approver ensures that the purchase is consistent with college policies, and accurately coded (fund, organization, account, and program code). 

Approval and authorization 

8. The college has guidelines in place that if the college receives a prepared contract, review and approval authority takes place in accordance with the college’s Contract Authorization Guidelines. Reviewers shall use the college’s standard Contract Review Guidelines, “Questions to Ask Before You Sign.”

If a contract is complex, if the total amount exceeds $25,000, or if any contract covers a period of more than one year, the requestor should follow the college’s protocol to seek approval from the vice president for finance/CFO, who may also retain external legal counsel to perform a contract review.

If a contract relates to Information Technology, the requestor should create a tech adoption request in accordance with the Technology Adoption Policy before following standard contracting approval and authorization processes.

If a contract is a grant from a private foundation, please consult with the Foundation Relations Office for its expectations on processing these grants.

If a contract is a grant from a government agency or is a sponsored project, please consult with the director of sponsored research for the college’s protocol on these grants.

In all instances, contracts must be signed in accordance with the following Procurement Authorizations.

COLORADO COLLEGE PROCUREMENT AUTHORIZATIONS

Procedures

Waiver of competitive bidding

The Request for Sole Source/Singel Source Procurement Form must accompany a requisition for goods or services in excess of $25,000. Bids may be waived under the following circumstances:

Sole source: the vendor being used is the only one who provides the good or service needed by the college.

Emergency: the goods or services are needed immediately to address an environmental, safety, or health emergency

Economic: goods or services from another vendor would result in incompatibility with existing goods or services; require substantial time or money to use due to training requirements, retrofitting, etc.; and/or goods or services are offered at a substantial discount.

States other than Colorado where the college has successfully filed for tax exemption

Please refer to the Finance Office website for the most up to date information.

Definitions

Procurement:

a strategic approach to sourcing and purchasing of goods and services. This involves all stages of a purchase including specification development, value analysis, supplier market research, negotiation, marketing, buying activities, administration of contract, and control of inventory, traffic, receiving and stores.

Purchasing:

the act of buying within the boundaries already set up by procurement (i.e., buying or paying for goods and services with the purchasing card).

Blanket purchase order:

should be used for repetitive purchases, for a particular supplier of goods or services which may include multiple shipments.

Contract:

an agreement between the college and another party, which consists of stated prices, terms, and conditions for the purchase of specific goods/services

Purchase order:

written offer for the college to purchase goods/services with set terms and conditions.

Single source:

a vendor selling items for which price competition may be available but to whom a contract is awarded without price competition because of reasonable circumstances (e.g., quality or familiarity with the college).

Sole source:

competitive bidding is not feasible because the goods to be procured are unique or proprietary, or a vendor has an exclusive or territorial agency.

Supplier:

a person or organization that provides goods or services to the college. “Supplier” is used interchangeably with “vendor.”

Sustainable procurement:

the purchase of products and services that have a lesser or reduced effect on human health and the environment when compared with competing products that serve the same purpose. This comparison may consider raw materials acquisition, production, manufacturing, packaging, distribution, reuse, operation, maintenance, or disposal of the product.

Vendor:

a person or organization that provides goods or services to the college. “Vendor” is used interchangeably with “supplier.”