Faculty & Staff

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General Procurement Procedures

All funding agencies use the terms and conditions of their awards to govern the use of the resources. In addition, with U.S. government funding there are statutes, government-wide directives, and regulations with which Columbia University must comply. It is the responsibility of the PIs and Country/Project Directors to know and ensure adherence to these governing regulations as they apply to procurement, as well as to other aspects of operations. Requirements include:

• All bids/quotes must be in English or key elements must be translated
• Pro forma invoices may be used as quotes, but are not acceptable for payment – stamped receipts from the vendor are required
• The required bids/quotes must be attached to the expense documentation – or a written explanation must be provided (see the Sole/Single Source Justification Form, available in Appendix 17 of the ICAP SOPs)

In addition, all expense documentation must clearly indicate:

• A clear description of what the vendor provided, making it evident whether they were goods or services
• In the case of services, the location (including country) in which they were provided, and if in more than one location, the partial allocations by location

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Procurement Using USG (Federal) Funds

The University policy on Procurement Using Federal Funds provides information on the documents and provisions governing USG-funded projects, including OMB Circular A-110 for grants and cooperative agreements and the Federal Acquisition Regulation (FAR) for contracts. The policy may be found at University policy library.
It is the responsibility of the PI and Country/Project Director to ensure that USG funds are not used to procure from federally debarred vendors and are not used for prohibited and restricted goods and services, including pharmaceuticals.
Note that CDC, USAID, and other USG entities require specific approval prior to making an expenditure for the following:

• Alterations and renovations of buildings
• Subgrants and subcontracts
• Consultants
• Vehicles
• Other major equipment having a unit cost greater than a set level, such as US$5,000

Note also that competitive bidding is required for most purchases. Where stated requirements are not met, a signed Sole/Single Source Justification Form (Appendix 17 of the ICAP SOPs) must be on file. For procedures that may be helpful, see Section 6.12 of the ICAP SOPs.

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Value Added Tax

U.S. government regulations require that all value added tax (VAT) be reimbursed, which in turn requires that each international project with USG funds make a diligent effort in this area. A Documentation of Submission for VAT Reimbursement Form (Appendix 35 of the ICAP SOPs) must be submitted as part of the monthly Finance Report. For more information, see Sections 6.9.11 and 6.12.15 of the ICAP SOPs.

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NY-Based Procurement Mechanisms

Those responsible for purchasing goods and services must utilize the most appropriate mechanism to do so. The University’s Procurement Mechanisms Policy is designed to maximize the efficiency and convenience of the purchasing process, consistent with good business practices, and in full compliance with all applicable USG regulations. The policy provides guidance concerning the choice of the most appropriate procurement mechanism, as summarized below:

1. Central Purchase Orders: A central purchase order is a document issued to a vendor by the University’s Purchasing Office confirming an agreement for the supply of goods and services. Central purchase orders must be used: 1) to execute most service agreements, and 2) to complete the acquisition or lease of most goods and capital equipment where the agreed price is in excess of $2,500 and for which a p-card may not be used.
2. EZPO: An EZPO is a document issued to a vendor by a school or department confirming an agreement for the supply of certain small purchases of goods without review by the Purchasing Office. It may be used for small purchases of goods valued from $501 to $2,500, where it is not feasible or desirable to utilize a p-card. EZPOs may also be used for certain larger purchases from University-wide Purchasing Agreement (UwPA) vendors in amounts up to the maximum contract-specific dollar threshold specified by the Purchasing Office.
3. Blanket Purchase Order: A blanket purchase order is a blanket order issued to a vendor by the Purchasing Office for a small number of repetitively purchased goods where it is impractical to issue a separate purchase order for each requested delivery. Blanket purchase orders may be used where all of the following conditions apply: 1) the order is for a fixed period; 2) the order is for a specified set of items; 3) the order defines an agreed price for each item; 4) the number of items covered by the order is limited, generally to 25 or less; and 5) releases against the order are documented in a manner that allows each release to be tracked, audited, and reconciled to receipt and payment records.
4. P-Card: A p-card is a credit card that authorized University personnel may use to purchase goods and services for use by the University. It is the preferred purchasing mechanism for most goods and minor equipment valued at $2,500 or less, and for certain larger purchases that do not require a central purchase order. The p-card is also the preferred purchasing mechanism for small dollar purchases of certain regularly purchased services and for certain larger purchases from UwPA vendors.
5. Direct Payment by Accounts Payable: Direct payment by Accounts Payable may be used regardless of dollar value for purchases of goods or services that do not require a purchase order of any kind and where another purchasing mechanism is not preferred or required as outlined elsewhere in this section. Examples include honoraria, printing services, and legal fees approved by the Office of the General Counsel.

Those engaged in purchasing should be thoroughly familiar with the full text of the University’s Procurement Mechanisms Policy. Employees are also encouraged to make use of the University’s online Interactive Purchasing Guide, which assists with selecting the best procurement mechanism.

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Field-Based Procurement Mechanisms

When an international field office is unable to procure certain goods or services through New York or such arrangements are unwieldy, costly, and inefficient, then the field office may proceed with direct procurement locally. In such cases, proper procurement procedures must be established in writing and compliance with them enforced.

For local payments, preference should be given to using checks or electronic transfer of funds instead of cash. When paying for large procurement transactions, it is wise to arrange for vendors to be paid directly through a wire transfer from New York.

If the international project operates through a local entity and that entity would like to enter into service or vendor agreements or contracts, prior approval is required from the New York office unless the New York office in consultation with Office of the General Counsel (OGC) authorizes the PI or Country/Project Director to sign.

Prior approval is not required if the Principal investigator or Country/Project Director is authorized by OGC to represent the local entity to sign certain agreements and contracts executed between the local entity and local vendors. See Service and Vendor Agreements for details.

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