Purchases with Federal Funds
SIBCR receives significant funding from federal sources and must comply with the federal regulations for purchases with federal funds as well as expenses transferred onto federal funds. See Appendix B for a summary table of purchase requirements. These purchases are reviewed by the SIBCR Accounting Office for compliance with federal regulations (i.e., debarment and suspension) and are subject to internal and external audit. PIs and their authorized designees are required to provide the Accounting Office with back-up documentation and retain a copy on file for federal auditors. Examples of documentation include: a rationale for method of procurement, vendor information, bids, quotes, and/or cost/price analyses.
A. Micro-Purchases - Goods or services ≤ $25,000: Purchases should be made at a cost considered reasonable and distributed equitably among qualified suppliers (to the extent practicable). A Vendor Justification Form (VJF) is not required. Use of SIBCR-approved vendors is encouraged.
B. Small Purchases - Goods or services > $25,000 to $250,000: Price and rate quotations must be obtained from an adequate number of qualified sources. Purchasers must complete the SIBCR VJF and provide backup documentation to the SIBCR Accounting Office. Purchases or expenses transferred onto federal funds must meet the VJF criteria.
C. Purchases >$250,000: A formal bid process with written quotes is required for federal purchases greater than $250,000. Quotes must follow competitive proposal guidelines (or sealed bids if construction). A competitive bid proposal requires that a formal Request for Quote (RFQ) or Request for Proposal (RFP) be publically advertised, evaluated and selected in accordance with Uniform Guidance specifications.
D. Non-competitive procurement: is used when choosing a specific company and bypassing the competition. It is only allowable under certain specific circumstances as listed on the SIBCR VJF.
E. Avoid wasteful or duplicative purchases: Uniform Guidance requires SIBCR purchasers to avoid the purchase of unnecessary or duplicative items. In addition, when possible, purchasers should compare the costs of leasing versus buying, assess the feasibility of consolidating, breaking out purchases or sharing a product or service to reduce overall costs.
F. SIBCR may not engage in transactions with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities pursuant to Executive Orders 12549 and 12689, 2 CFR part 180.
All Funds Other Than Federal
Follow funder/grant terms and best practices for purchases with any non-federal funds.Typically, only purchases made with federal funds must comply with the terms of Uniform Guidance. However, note that any purchases transferred to a federal award must comply with the Uniform Guidance and the terms of the award, even if the purchase was originally made with non-federal funds. Likewise, purchases transferred to other funds must comply with sponsor or donor terms,if applicable, even if the purchase was originally made with unrestricted funds. See Appendix B for a summary table of best practices when using non-federal funds. SIBCR approved vendors should be used whenever possible.
A. Micro-Purchases - Goods or services ≤$25,000: for purchases with a total value of $25,000 or less, the purchaser may use their discretion to select a responsible supplier to purchase goods or services.
B. Small Purchases - Goods or services > $25,000 to $250,000: if an SIBCR approved vendor is not available (or a purchaser believes there is an opportunity to acquire the good or service for a lower cost, taking the total cost of ownership into consideration), purchasers should obtain at least two quotes (three or more is best practice) from qualified suppliers. See Appendix B regarding a summary table of best practices when using non-federal funds. The SIBCR VJF is not required.
C. Goods or services >$250,000: for purchases greater than $250,000, purchasers should conduct a formal bid process from at least two vendors (three or more is a best practice). Contact the SIBCR Accounting Office to discuss the purchase process.
D. Wasteful or duplicative purchases: A best practice is to consider ways to prevent the purchase of unnecessary or duplicative items.
E. SIBCR may not engage in transactions with any parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities pursuant to Executive Orders 12549 and 12689,2 CFR part 180.
Diverse and Disadvantaged Businesses, Regardless of Funding Source
SIBCR purchasers must take affirmative steps when possible to create a climate of inclusion and support of diverse and disadvantaged businesses. This category includes disadvantaged, minority owned, women owned, small, veteran-owned and service-disabled veteran-owned businesses. Whenever possible, purchasers are encouraged to:
1. Identify and place qualified diverse and disadvantaged businesses on solicitation lists;
2. Assure that such businesses are solicited when they are potential sources;
3. Divide total requirement, when economically feasible, into smaller tasks or quantities to permit maximum participation by such businesses;
4. Establish delivery schedules, where requirements permit, which encourage such business to respond; and,
5. Use service and assistance from such organizations as SBA and the Minority Business Development Agency of the Department of Commerce.