Accounts Payable/Purchasing RF Symposium March 2015 Dave Martin – Campus Financial Services Manager Megan Moran – AP/Purchasing Supervisor Ned Gellner – Corporate Payment Compliance Manager

Topics  RF Foreign Entity process - FATCA  OMB Uniform Guidance – summary of new procurement related requirements  Travel – RF Travel Handbook  Open discussion on other AP or Purchasing topics

FATCA  Foreign Account Tax Compliance Act – enhanced reinforcement of U.S. compliance rules for entities  Financial (FFI) versus Non-Financial (NFFI)  FATCA main focus is information not tax  FATCA comes first  Requires foreign entities to report information – otherwise potential withholding in some situations

New RF Process to meet U.S. Tax and Reporting Rules  Determine the supplier - IRS “Sourcing”  U.S. Source OR  Foreign Source  If U.S. Source, apply further rules  30% withholding general default rule  Unless other exclusions or exemptions exist

OMB Uniform Guidance  Procurement Standards contain arguably the biggest changes for campuses  OMB has granted institutions an optional one year grace period for implementing changes  RF opted to continue to comply with A-110 through FY16 and has documented in the procurement policies  Effective date of new requirements is July 1, 2016

Defined Procurement Methods (1) Procurement by Micro-Purchases (up to $3,000) – no need to solicit competition if price deemed reasonable (2) Procurement by Small Purchase Procedures ($3,000 to $150,000) – requires solicitation of quotations from an “adequate number” of sources  This is the biggest & potentially most onerous change  Current RF policy requires competition at $50,000  Could potentially require significant additional effort resulting in delays in acquiring goods and services

Procurement Methods (cont.) (3) Procurement by Sealed bids (more than $150,000) – preferred in construction or other purchases where price is the major component (formal advertising required) (4) Procurement by Competitive Proposals (more than $150,000) – RFP must be publicized and awarded to most advantageous offer with price and other factors considered (5) Noncompetitive purchases (single source) – used when product or service is only available from one source or in other limited instances

Procurement Standards (cont.) Other changes of interest include:  Listing of detailed “affirmative action steps that must be taken” to assure that MWBEs and labor surplus firms are used when possible  Cost or price analysis required for all procurements above the simplified acquisition threshold ($150k)  Negotiation of profit required for each contract over $150k in which there is no competition (single source procurements)  Must maintain records sufficient to detail the history of the procurement (rationale for the method of the procurement, selection of contractor type, reasons why contractors selected and basis for the contract price)

Procurement Standards (cont.)  Only apply to procurements charged directly to a federal award  Campus team is reviewing proposed revisions which include revising RF Procurement Policy to account for purchases using other funding sources  Push back from higher-ed community may result in $3,000 threshold being increased

RF Travel Handbook  Consolidation of 25 travel guidance documents  Efficient and user friendly access to travel procedures and information  Updated to include Uniform Guidance language that travel dependent care costs are an allowable charge to grants but must be consistently applied

Questions?