Purpose

The purpose of this policy is to comply with OMB 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards regarding procurement of property and services under a Federal award (2 CFR 200.317 - 200.326).

Policy

Davidson College is committed to ensuring that all purchases of property and services are appropriate and conducted in accordance with sponsor terms and conditions, federal regulations and College policy. The Office of Grants & Contracts is responsible for ensuring that purchases directly charged to federally sponsored awards will comply with the cost principles outlined in the Office of Management and Budget (OMB) 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.317 - 200.326). The Uniform Guidance outlines five methods of procurement: micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive (sole source) proposals. Some general standards apply to all five types of procurement.

  • The policies surrounding the procurement must be documented
  • The procurement must be necessary
  • The procurement must be subject to full and open competition among vendors
  • The procurement cannot present a conflict of interest

Types of Procurement

Micro-purchases

  • <$10,000 threshold
  • No bid or quote process required
  • No cost or price analysis required
  • Should be distributed among a range of qualified vendors

Small purchases

  • $10,000 up to $250,000
  • Price or rate quotes required from an adequate number of sources
  • Should be distributed among a range of vendors

Quotes (at least 3) can be sourced through a number of methods (online, email, written. Documentation must include:

  • Copies of quotes
  • Dates obtained
  • Rationale for selection

Purchases will not be authorized without this documentation.

Sealed Bids - Sealed bids are required for any construction project greater than $250,000

  • >$250,000
  • Typically used for construction contracts
  • Two or more bidders
  • Complete, adequate, and realistic specification or purchase description is available
  • Firm fixed-price contract is feasible and can be selected based on price

Competitive Proposals

  • Required request-for-proposal process and solicitation of an adequate number of bidders
  • Written method of evaluation, considering price as well as other factors advantageous to the program

Non-competitive (sole source) proposals - falls into one or more of the following circumstances:

  • Unique - item available only from a single source
  • Public emergency will not permit a delay resulting from competitive solicitation
  • Expressly authorized by the awarding agency or pass-through entity
  • Competition is determined to be inadequate after solicitation.

Sole-source purchases must be justified in writing indicating which of the circumstances above applies. Sole-source purchases will not be authorized without this documentation.

Administration of Policy: The Director of Grants and Contracts shall oversee this policy and review it at least once every two years. Changes to this policy shall be made in accordance with the college's Policy on Policies.

Adopted: 07/01/17
Last Revised: 04/19/21
Last Reviewed: 04/19/21