These guidelines supplement the College's standard procurement policy and should be followed for any purchase made with federal funds.

The federal government imposes a set of standards for the acquisition of supplies, equipment and real property purchased with federal funds. Procurement procedures must comply with the standards imposed by OMB (Office of Management and Budget) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR-200).

Guidelines for Purchases

• All purchases must be in compliance with the College's Statement for Conflicts of Interest and Code of Ethical Conduct as well as the Financial Conflict of Interest policy specific to federal grant funding. In addition no employee, officer, or agent of the College shall participate in the procurement of goods and equipment supported by grant funds (whether federal or private) if a real or apparent conflict of interest would be involved. Such a conflict would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization that employs or is about to employ any of these parties, has a financial or other interest in the firm selected for an award or purchase. The officers, employees, and agents of the college shall neither solicit nor accept gratuities, favors, or anything of monetary value from vendors or contractors.
• The vendor or contractor that meets the required quality standards at the lowest cost should be selected. Regardless of the cost of acquisition, grant recipients are required to avoid purchasing unnecessary items. If the cost to purchase a larger quantity is cheaper than the quantity you need, federal guidelines require that only the quantity needed should be purchased.
• Capital Equipment is defined by the OMB as "tangible nonexpendable personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit." The acquisition cost includes installation charges and freight. Additional information is include in the Capital Equipment section below.
• Debarment and Suspension: No purchases shall be made from parties who have been involved in fraud, waste or abuse. The General Service Administration's (GSA) lists the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory or regulatory authority on the System for Award Management. (The list was formerly known as the EPLS or Excluded Parties List System.) If a grant requires expenditures totaling $10,000 in a fiscal year from one vendor, it is necessary to complete and document a Debarment and Suspension check on sam.gov before a purchase is made. Please review these procedures and contact the Director of Sponsored Research for assistance with this process.
• Small, Minority-Owned, and Women's Business Enterprise Utilization: Colleges and universities expending federal funds are required to make positive efforts to use small businesses, minority-owned firms, and women's business enterprises whenever possible.
• The Davis-Bacon Act requires contractors and subcontractors on federally funded or assisted contracts to pay their laborers and mechanics employed under the contract no less than the locally prevailing wages and fringe benefits for corresponding work on similar projects in the area. The Colorado Department of Labor determines the locally prevailing wage rates.

Purchasing Guidelines Based on Threshold

The threshold amounts refer to the total cost of the purchase. For example, purchasing three $900 laptops is considered to be a $2,700 purchase, not three separate items. A $90,000 equipment purchase with a $5,000 delivery/set-up fee and $8,000 in ancillary parts constitutes a purchase over $100,000.

• Purchases under $10,000 ("Micro-purchases"): Competitive quotations are not required if the prices are reasonable. Selection should be based on quality and cost. To the extent practicable, purchases must be distributed equitably among qualified suppliers.
• All Purchases (single or cumulative) over $10,000 from a single vendor within a fiscal year: Written price or rate quotations must be obtained from an adequate number of qualified sources (see table below). A purchaser should not expend his or her own funds for reimbursement on purchases over $3,000.

Specific Requirements Based on Purchase Amount

Documentation Requirements

Documentation must be maintained for single or cumulative purchases from a single vendor within a fiscal year that exceed $10,000. The documentation must be sufficient to detail procurement history. A quote is a written statement from a vendor regarding the price for a specific good or service. Quotes and bids should include specifications and qualifying characteristics considered by vendor/contractor including delivery and time frame, scope of work, references, and other relevant specifications.

Procurement and service contract documentation must contain the following:

• Basis for the vendor/contractor selection. Information showing how the College arrived at the decision to award the contract to that particular vendor/contractor.

• Basis for the award cost or price: the cost and price analysis should be documented to establish that the institution obtained a fair price.

A Vendor Selection Form is required in the following circumstances:

• A sole source purchase
• A minimum number of cost estimates and quotations are not obtained
• Lowest cost bid is not selected

Ownership of Items Purchased with Grant Funds

Grants are awarded Colorado College, not to individual PIs. As such, items and equipment purchased with grant funds belong to Colorado College. All institutional policies regarding capital equipment, purchasing, and procurement apply.

Capital Equipment

Capital equipment is defined by the OMB as "tangible nonexpendable personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit." All costs associated with making the asset serviceable can be capitalized. Equipment acquired with external support becomes the property of Colorado College unless restricted by the sponsor.

• PI Responsibilities: PIs are required to ensure the proper receipt of the equipment, track equipment, participate in inventories and notify the Office of Finance & Administration with regard to condition, location, loss or damage to the equipment. The PIs establish maintenance procedures and records and are responsible for the operational condition of the equipment.
• Record Keeping: Colorado College maintains records including description, serial number, source of funding (including the Federal Award Identification Number, or FAIN), who holds title, acquisition date and cost, location, use and condition status, and disposition data. This information is maintained by the Tax & Compliance Manager as well as stored in the College's Fixed Asset records.
• Inventory: The Office of Finance & Administration tags assets at the time of acquisition. The Office of Finance & Administration performs a physical inventory of equipment purchased with grant funds every two years to verify the existence and condition of the equipment, and the accuracy of the College's records.
• Disposal: If an item purchased with grant funds is determined to be obsolete, and the item's value exceeds $5,000, disposition rules must be followed. This may include requesting disposition instructions from the awarding agency. Possible disposition practices may require compensating the Federal awarding agency for its proportion of the original cost applied to the fair market value. Please notify the Tax & Compliance Manager if disposing of an asset purchased with federal funds.