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Learn rules for purchasing with sponsored funds, including Vendor Justification and Debarment Certification. Find resources, tips, and updates at www.procurement.fad.harvard.edu.
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Sponsored Programs and Procurement Requirements Overview Ray Wise Judy McSweeney Fall 2009
Agenda • Rules Review • Considerations • More Info • Questions
When purchasing with sponsored funds, there are two key rules • Purchases over $5000 must complete a Vendor Justification • Form is available at procurement website • Addresses purchases with federal funds, grants, and subcontracts • Provides a means of documenting competitive bid, sole source/selected source decisions, and cost/price analysis verification in compliance with regulations • The VJF is built in to the HCOM application for pilot users (though if bids were received they must be retained locally) • Applies to purchases at this amount regardless of how the purchase is made • Purchases over $25,000 with federal funds must obtain a signed Suspension and Debarment certification prior to purchase • (FAR) 52.209-5 requires that Harvard obtain written certification from vendors receiving a purchase order of $25,000 and over and made with Federal funds that they have not been debarred (prohibited) from doing business with the Federal Government. A prime contractor such as Harvard, who knowingly does business with a debarred vendor, risks having its Federal contract terminated. • Applies to purchases at this amount regardless of how the purchase is made There are no changes to federal regulations or Harvard policies
Considerations • Applies regardless of payment form • Payments at these $ amounts on a Corporate Card, PCard, or reimbursed to a traveler still require the VJF and Debarment Certification • Applies regardless of type of vendor • Hotels, cleaning companies, security guards…these are still purchases • Does not apply to subcontracts • Federal regulations are clear that this applies only to procurements. Status for sub-contracts is managed through the contract language
More Considerations • Applies once per commitment, not once per payment • Equipment purchases subject to progress payments or installments only require a VJF and Debarment Certification when the overall purchase order (for the total amount) is issued • Blanket purchase orders or Standing Orders (e.g. for a 12 month supply of materials with monthly deliveries) only require a VJF and Debarment Certification when the blanket purchase order (for the 12 month supply) is issued or when the commitment to buy is made • Keep in mind • At the $25,000 dollar level (Debarment Threshold), most purchases will be made with a quote or bid from one or more vendor(s). Vendors can provide the Debarment Certification with these quotes. • Debarments do happen, and vendors come on and off the list. It’s rare, but sometimes Harvard does have payments to a debarred vendor
More Information • All the latest buzz on Procurement: www.procurement.fad.harvard.edu • Full listing of all science vendor agreements • Tips and techniques for managing budgets • “How to save” guidance for most commodity areas • Latest news: breaking agreements, scam updates, and more • Too much to list!
