1. 2 CFR 200 Procurement Principles
Research Administrator Monthly Forum
May 2018
Presented by: Michael Ritz, CIA,CPA
Research Compliance Officer
Office of Research and Project Administration

2. Background
2 CFR 200 prescribes procurement requirements historically associated with state and local governments
More proscriptive than prior regulations (OMB A-110)
Research institutions requested reconsideration of the requirements
Effective date was deferred twice, with pending effective date of July 1, 2018
Appears the original 2 CFR 200 requirements will be applicable to us

3. Background 200.318 General Procurement Standards 200.319 Competition
Methods of procurement to be followed
Contracting with small and minority businesses, women’s business enterprises
Contract cost and price
Federal awarding agency or pass-through entity review

4. Today’s Objectives Familiarize you with:
Procurement Standards Expectations Document
Competitive Bid Policy – Sponsored Funds
Supplier Price Justification and Conflict Information Form – Sponsored Funds

5. Principle of Fiduciary Care
Procurement Standards Expectations Document Section A: General Procurement ( )
Principle of Fiduciary Care
Utilize established Corporate Purchasing mechanisms to procure goods and services for sponsored projects
Ensure fulfillment of ordered goods and performance of services in accordance with the terms, conditions and specifications of the contracts and purchase orders prior to approving payment
Avoid unnecessary or duplicative purchases

6. Procurement Standards Expectations Document Section A: General Procurement (200.318)
Consolidate procurements where possible
Where appropriate, seek or perform lease-versus-purchase analysis
Attempt to use surplus property in lieu of purchasing new equipment and property
Apply due diligence so contracts are awarded only to contractors who can successfully perform (e.g., involve Corporate Purchasing)

7. Principle of Best Price and Lack of Bias
Procurement Standards Expectations Document Section B: Competition ( )
Principle of Best Price and Lack of Bias
Full and open competition
Prohibit geographical preferences

8. Principle of Larger Transactions Requiring More Diligence
Procurement Standards Expectations Document Section C: Procurement Methods ( )
Principle of Larger Transactions Requiring More Diligence
Micro Purchases
Simplified Acquisition Threshold
Competitive Proposal Threshold

9. Procurement Standards Expectations Document Section C: Procurement Methods (200.320) Micro-purchases
Individual transactions < $3,500
Distribute equitably among qualified suppliers
No need for solicitation of competitive quotations if price is deemed to be reasonable

10. Procurement Standards Expectations Document Section C: Procurement Methods ( ) Simplified Acquisitions
Individual transactions $3,500 to $149,999
Price or rate quotations must be obtained from an adequate number of qualified suppliers

11. Procurement Standards Expectations Document Section C: Procurement Methods ( ) Competitive Proposals
Individual transactions $150,000 or greater
Formal proposal process
Always collaborate with Corporate Purchasing

12. Procurement Standards Expectations Document Section C: Procurement Methods ( ) Lack of Competition
Only one source responds; OR
One of the conditions provided in 2 CFR 200 applies
Justification of fairness and reasonableness of price is needed, including a breakdown of cost components

13. Competitive Bid Policy – Sponsored Funds
Objective
Competitive sourcing requirements are dependent upon the size of the purchase
Guidelines
Bids must be obtained
SSPJCI Form (sponsored funds)
Conflicts of Interest
Confidentiality of Bids/Quotations/Proposals

14. Competitive Bid Policy – Sponsored Funds
Micro Purchases (<$3,500)
One quote/proposal
Simplified Acquisition Threshold ($3,500 - $149,999)
Multiple written quotes
Competitive Procurement Process ($150,000 +)
Multiple written, formalized, non-sealed bids
*The use of a competitive bid and negotiated agreement on behalf of the University satisfies the bid requirements for all three categories above.

15. Micro Purchases Ensure price is fair and reasonable
Complete the SSPJCI Form

16. Simplified Acquisition Threshold
When goods/services have standard and easily compared specifications, employ the Request for Quote (RFQ) process.
Written quotes on supplier’s letterhead (verbal bids not acceptable)
If all factors are equal, lowest priced supplier should be awarded the contract.
Complete the SSPJCI Form

17. Competitive Procurement Process
Formal proposal process required
Work with Corporate Purchasing once a Scope of Work or a requirements document has been drafted
Complete the SSPJCI Form
Identification of qualified suppliers is a key component
Suppliers Previously Contracted
RFI/Supplier Pre-Qualification
Bid Evaluation Method Grid

18. What if there is lack of price competition?
A single bid is submitted
Document the justification of the fair and reasonable criteria for the price
e.g.: In-house estimates
e.g.: Price for same or similar items
Alternatively, cancel the formal bid process and negotiate the contract price with the sole bidder
Cost breakdown required
Cost analysis required
Final resolution to be reviewed and approved by Corporate Purchasing

19. What if there is a single/sole source?
(Formal proposal process deemed not feasible)
Can only be awarded under certain specific instances (refer to policy)
Documentation of price reasonableness is needed

20. Sponsored Funds Supplier Price Justification Conflict Information (SSPJCI) Form

21. SSPJCI Form Section A Written Quotes, Proposals, Competitive Bids
Section B Non-Competitive/Low Bid Not Selected
Section C Cost/Price Analysis
Section D Conflict of Interest Information
Section E Minority and Small Business Information

22. SSPJCI Form What are the requirements that I need to know?
Sponsored Funds (FAO=GR) Goods and Services
Purchase Requisition Amount
Requirements
$0 - $3,499
One written quote/proposal
Sponsored Funds Supplier Price Justification Conflict Information Form (SSPJCI) - Section C- E
$3,500 - $149,999
Multiple (2) written quotes
Sponsored Funds Supplier Price Justification Conflict Information Form (SSPJCI)- Section B-E
$150,000 and greater
Multiple (3) written formalized bids through a competitive bid process (i.e. Request for Proposal (RFP)/Request for Quotation (RFQ)
Sponsored Funds Supplier Price Justification Conflict Information Form (SSPJCI) - Sections A-E

23. SPJCI Form Where do I find it? How do I complete it?
The Sponsored Supplier Price Justification Conflict Information Form (SSPJCI) is located on the Purchasing Website in the Forms Bank.
How do I complete it?
The form is a 5-page PDF fillable form that can be filled out on-line. The departmental requestor must complete the SSPJCI Form. The next several screens will provide additional detail in filling out the form. Please note that incomplete forms will be returned and will delay your request.
What are the next steps after completing it?
Upon completing the SSPJCI Form and obtaining appropriate signatures based on the University Signature Authority Policy,
312 Requisition: Submit it along with your 312 requisition and other supporting documentation (i.e. quote, Independent Contractor Forms, Contracts etc.) to Purchasing by fax at , intramural mail at Box or
Pcard Transaction: Upload the completed form with your Pcard Transaction.
F4 Payment Request: Submit it along with your F4 Payment Request Form to Accounts Payable, Box

24. SSPJCI Form Requested By: Date: Phone: Req#: Vendor: Section A:
Identify the person who is requesting the supply, equipment or service.
Phone:
Identify the phone number of the person requesting the supply, equipment or service.
Section A:
Competitive bids are required for purchases of $150,000 and greater. Work with Purchasing to assist with the competitive bid process. To support the selection of the supplier, please indicate the supplier name and total quoted price. Attach the quote and identify if the supplier is a small business. Note: Purchases between $3,500 - $149,999 multiple written quotes are required.
Date:
Enter the date you are completing the form
Req#:
Enter the 312 requisition that will accompany this completed form.
Vendor:
Enter the name of the supplier you would like to contract with. Note: Purchasing may change the supplier based on contracts currently in place.

25. SSPJCI Form Section B – Required for All Purchases > $3,499:.
Section B – Required for All Purchases > $3,499:
Identify by checking the appropriate box if the selection is based on the following including the reason.
Non-Competitive
Low Bid Not Selected
Additional detailed explanation can be included to support your selection with the form.

26. SSPJCI Form
Section C – Cost/Price Analysis – Required for All Purchases (312, Pcard and F4:
Select all that support the determination that the purchase is fair and reasonable.

27. SSPJCI Form Section D – Required for All Purchases:
If there is a conflict, please identify name and title of the individual affiliated with the conflict.
In addition, identify the process utilized to manage it.
A person, with signature authority based on University Signature Policy to commit funds for the department and can certify the information is correct, is required to sign the SPJCI Form.
Section D – Required for All Purchases:
Conflict of Interest Information:
Identify if there is a conflict of interest with this transaction. Check “No Conflict of Interest if one does not exist.
If a conflict exists, the University’s Sr. VP of Administration and Finance or their designee, must approve the purchase.

28. SSPJCI Form
Section E – Minority and Small Business Information – Required for All Purchases
Identify, based on the categories listed, the number of suppliers solicited and the reason they were not selected based on the designated key.
An authorized department representative (FAO Manager, Cost Center Manager and/or Department Head) is required to sign to certify the awareness of the University’s Competitive Bid Requirements in support of Federal Guidelines and confirm that small and/or minority businesses were solicited wherever there were potential sources.
Additional comments can be identified to support the information provided.

29. Questions