Purchases & Subawards using Federal Funds

Federal funds used for purchases and subawards must comply with the Procurement Standards included in OMB Circular A-110, sections .40 – .48 and meet the procurement requirements specific to those individual sponsor award terms and conditions.

To ensure that the procurement standards are met, Principal Investigators must, at a minimum, meet the following requirements:

  • avoid purchasing unnecessary items.
  • where appropriate, perform an analysis of lease and purchase alternatives to determine which would be the most economical and practical procurement for the Federal Government.
  • ensure solicitations for goods and services provide for all of the following:
    1. A clear and accurate description of the technical requirements for the material, product or service to be procured. In competitive procurements, such a description shall not contain features which unduly restrict competition.
    2. Requirements which the bidder/offeror must fulfill and all other factors to be used in evaluating bids or proposals.
    3. A description, whenever practicable, of technical requirements in terms of functions to be performed or performance required, including the range of acceptable characteristics or minimum acceptable standards.
    4. The specific features of “brand name or equal” descriptions that bidders are required to meet when such items are included in the solicitation.
    5. The acceptance, to the extent practicable and economically feasible, of products and services dimensioned in the metric system of measurement.
    6. Preference, to the extent practicable and economically feasible, for products and services that conserve natural resources and protect the environment and are energy efficient.

For amounts of $25,000 or more, vendors & subawardees must be verified against the Excluded Parties List using the search function of SAM (System for Award Management).  Vendors are verified by the Accounting Department prior to charging the cost to the federal award fund. Subawardees are verified by the Sponsored Programs Office prior to issuance of the subaward.

For amounts of $100,000 or more, the Principal Investigator must provide the following:

  • basis for vendor selection
  • justification letter for lack of competition when competitive bids or offers are not obtained, and
  • basis for award cost or price

The Procurement Standards have been updated in the Uniform Guidance (2CFR200 §200.317-200.326) and will be implemented effective beginning July 1, 2018. The College will continue to follow the Procurement Standards included in OMB-110 until the new Uniform Guidance Procurement Standards are in effect on July 1, 2018.