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Procurement Policy for Federal Grant-Funded Purchases

1. Purpose

The purpose of this policy is to ensure that goods and services purchased for the performance of a federal grant are obtained in a cost-effective manner and in compliance with federal regulations, specifically 2 CFR 200.317-326.

2. Scope

This policy applies to Principal Investigators and any designees ("buyer") authorized to initiate purchases on behalf of a federal grant. This policy is not applicable to the general purchases of the College.

3. Responsibility

The Principal Investigator is responsible for determining whether a purchase is allowable under the terms of the federal grant and will ensure purchases are in accordance with this policy (Allowable Cost Guidelines). Upon request, the Business Office will provide decision support on purchasing requirements and will also serve as the final repository for purchase transaction records under federal grants.

4. Overview

To promote compliance with federal regulations, the College requires buyers to perform some measure of cost/price analysis when making purchases under federal grants. Buyers shall avoid purchasing unnecessary items. All vendor bids and quotations must be evaluated on the basis of product quality, technical compliance with specifications, total cost, and the vendor's acceptance of the College's terms and conditions. The vendor selection process for goods and services valued at $3,000 or greater must be documented and stored as part of the transaction record.

5. Vendor Selection and Bidding Requirements

Buyers shall consider the following before making a vendor selection:

    • Does the vendor provide the best mix of quality, service and price for the specified need? Federal regulations require that the lowest price have priority, unless quality, service or delivery time takes priority as to need.

    • Does the vendor qualify as a small, disadvantaged, minority or women-owned business? Qualifying vendors should be given preference to the extent in which is practical and economically feasible.

    • Does the vendor supply products and services that conserve natural resources, are energy efficient, and protect the environment? Vendors should be given preference, to the extent in which is practical and economically feasible, for such products.

The level of bidding required and documentation to be submitted to the Senior Accounting Analyst is determined by the dollar amount of the purchase.




< $3,000



Formal bid process

Not Required


Acceptable forms of bids


Email confirmation, published catalogue, other written document

Minimum number of bids required



Complete a Vendor Selection Form and Submit bid documentation to the Controller's Office before purchase is made

Not Required


Analyze lease vs. buy options

Not Required


For purchases less than $3,000:

Formal documentation of vendor selection is not required. Buyers are expected to conduct an informal cost/price analysis and select the vendor offering the best mix of quality, service and price for the specified need. Reasonable efforts shall be made to ensure fair and competitive pricing.

For purchases greater than or equal to $3,000:

A minimum of three (3) bids are required. Each vendor must be provided with the same precise and accurate description of the specifications and technical requirements for the item or service. Web price lists and catalogue listings can be considered bids.

Buyers must complete a Vendor Selection Form. Upon completion of the form, it will be routed to the Business Office for approval. Once approval is confirmed, the buyer may proceed with the purchase.

When lease options are available, an analysis of the lease versus buy option must be performed to determine which alternative would be the most economical and practical form of procurement. The Contracts department will assist buyers with a lease/buy analysis upon request.

6. Obtaining Competitive Bids

Solicitations for goods and services shall provide the following:

    • A clear and accurate description of the technical requirements for the material, product, or service desired. The description shall not be designed to limit competitive solicitation from multiple vendors.

    • Requirements that the bidder must fulfill and all other factors to be used in evaluating bids and proposals.

    • A description of the technical requirements in terms of functions to be performed or performance required, including the range of acceptable characteristics or minimum acceptable standards.

    • The specific features of "brand name or equal" descriptions that bidders are required to meet.

    • To the extent practical, that products and service be dimensioned in the metric system of measurement.

    • Preference, to the extent in which is practical and economically feasible, for products and services that conserve natural resources, protect the environment, and are energy efficient.

Positive efforts shall be made to utilize small-business, minority-owned firms and women's business enterprises, whenever possible.

7. Non-Competitive Vendor Selection

Occasionally, a buyer is unable to competitively bid based on the requirements. These situations are characterized as sole or single source transactions. Non-competitive vendor selection may only be used when one or more of the following circumstances apply:

    1. The item is available only from a single source;

    2. The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation;

    3. The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity;

    4. After solicitation of a number of sources, competition is determined inadequate.

For non-competitive purchases the Principal Investigator must complete the Vendor Selection Form if the purchase is greater than or equal to $3,000.

8. Exceptions

The Controller must approve any exceptions to this policy by written notice.

9. Feedback

Your feedback regarding this policy is appreciated. Please send an e-mail to the Finance Team ( if you have any comments, questions or suggestions.

Policy Maintained by: Finance and Administration, AVP for Treasury and Controller
Effective Date: June 1, 2018
Last Reviewed: July 19, 2023