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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

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Presentation Transcript
agenda
Agenda
  • Rules Review
  • Considerations
  • More Info
  • Questions
when purchasing with sponsored funds there are two key rules
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
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
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
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!