OMB Circular A110 and Uniform Guidance

Current University of Delaware Policy Purchases up to $5,000 via University of Delaware card card. Purchases greater than $5,000 and up to $50,000, solicitation of quotations / bids will be at the discretion of Procurement Services. Buyers in Procurement Services are accountable for exercising professional due diligence by soliciting quotations (documented) when appropriate. Purchases greater than $50,000 require price quotations or sealed bids to be obtained from at least three legitimate vendors (if available), solicited by Procurement Services and advertised publicly only if in the best interest of the University. In the event that only a single source can be located for a particular purchase, Procurement Services will make that determination and the buyer will so document in the purchasing system.

Peer Institution Policies The Johns Hopkins University Less than $3,000 via procurement card. $3,000 up to $25,000 use eMarketplace. Greater than $25,000 routed to Purchasing for competitive quotes. University of Pittsburgh Less than $5,000 does not require competitive bidding. $5,000 up to $49,999 competitive bidding process with the exception of sole source purchases. Greater than $50,000 competitive bidding process with the exception of sole source purchases. Product and service requirements must be submitted to the Purchasing Department, which will conduct the bidding in conjunction with the requesting unit. Duke University Less than $3,000, submit shopping cart via SAP Buy@Duke. $3,000 or greater - three competitive bids or sole source justification.

A-110 Post Award Requirements 215.45 Cost and price analysis Some form of price or cost analysis shall be made and documented in the procurement files in connection with every federally funded procurement action. Price analysis may be accomplished in various ways, including the comparison of price quotations submitted, market prices and similar indicia, together with discounts. Cost analysis is the review and evaluation of each element of cost to determine reasonableness, allocability and allowability.

A-110 Post Award Requirements (cont.) 215.46 Procurement records Procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include the following at a minimum: Basis for contractor selection; Basis for award cost or price; Justification for lack of competition when competitive bids or offers are not obtained

UD Procedures – A110 Compliance To comply with A-110, the University policy regarding purchases on federal awards now includes the following: Purchases with a total combined value between $5,000 - $50,000 should have some form of documented fair market price comparison (e.g. web searches, formal quotes, etc.) or a sole source justification which can be obtained or completed by department personnel, and must be attached to the requisition. Sole Source Justification requires a signed form (a new document) available on the Procurement services website under “Forms” at http://www1.udel.edu/procurement/forms/ Purchases with a total combined value above $50,000 require formal quotes or a sole source justification prepared by Procurement Services.

Why Now? Current audit finding Erroneous application of State exemption under previous audits

2 CFR 200.Uniform Guidance Effective July 1, 2018, federally funded procurement up to $3,500 may be awarded without soliciting competitive pricing if the University considers the price to be reasonable. Procurement between $3,500 and $150,000 requires price or rate quotations obtained from at least three qualified sources (if available). Procurement > $150,000 must be competitively quoted by Procurement Services.

Updated University Procedures In an effort to ensure compliance by July 2018, Procurement Services is working on the functionality in the Purchase Order Requisition webform to allow pre-approval of Federally Funded Credit Card purchases with a total combined value between $3,500 and $5,000. Approval to proceed with the purchase will be granted by the RA provided fair market value price comparison documentation is attached to the webform. Sole Source Justifications require a signed form (a new document) available on the Procurement services website under “Forms” at http://www1.udel.edu/procurement/forms/

Sole Source Justification Form

Provider Category Determination for Subcontracts Subrecipient or Contractor (“fee for service”)? Submit with Purchase Order Req. and Statement of Work Used to determine the appropriate provider category for a particular program or project under a research grant Requires input from: PI Research Administrator Procurement Services (objective third party = control) Critical because the selected category impacts how the grant is administered and how overhead is charged https://www1.udel.edu/research/pdf/OMBCircularA-110.pdf

Provider Category Determination Worksheet

Questions?

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