Procedures for All Principal Investigators

The government does not want to see federal funding going to businesses or people who have mismanaged federal funding in the past. We need to do our "due diligence" with every major vendor to ensure that they are not an "excluded party" - that is, they are not suspended, debarred or otherwise excluded from conducting business with the federal government.

Prior to engaging with a vendor, Colorado College must:

• check that this vendor is not excluded from receiving federal funding AND
• document that this check was conducted prior to purchasing any goods or services.

For each grant, the following must be determined:

Step 1 - Identify the "Responsible Individual" for the "Exclusion Review." This could be the PI or the Director of Sponsored Research.

Step 2 - PI and/or Staff Assistant develop a list of commonly used vendors and those expected to be used for purchases in excess of $10,000 in any fiscal year during the grant period. This list should be provided to the Responsible Individual within one month of the Post-Award Meeting.

Step 3 - The Responsible Individual conducts a review of each vendor and documents the Excluded Party search for each vendor within one month of receiving the list of vendors from the PI and/or staff assistant.

Step 4 - Any potential new vendors (for purchases expected to exceed $10,000 in a fiscal year) are sent to the Responsible Individual so that a review can be conducted prior to purchase.

Step 5 - On an annual basis, the commonly used vendors are checked again by the Responsible Individual, and the review is documented. It is recommended that this annual check take place in the spring, just prior to the summer research season.

These instructions describe how to conduct your "excluded party" or "EPLS" search.