Policy Name: Purchasing Policy

Owner: Purchasing Department

Author: Finance Department, finance@css.edu

Effective Date: March 17, 1986

Revised: Revised: June 1990; February 1993; March 1994; March 1997; March 1998; April 1999; March 2000; July 2001; August 2002; August 2003; October 2004, April 2013, January 2019, May 2023

Next Review Date:

Applicable laws, regulations, compliance: Code of Federal Regulations

I. Purpose

This policy has been established to provide consistent guidelines for the procurement of goods and services by College employees for College business purposes. It is the policy of the College to maintain adequate records and sufficient controls to assure efficiency and integrity. It is the College's policy to procure and to pay for only those goods and services that are ordinary, necessary, reasonable in amount, properly documented and authorized.

II. Policy

A. Overview

Stewardship

Employees who procure goods and services should exercise care and good stewardship on behalf of the College's best interest. Costs incurred should be commensurate with benefits derived.

Documentation

The IRS requires expenditures to be supported by adequate records which clearly establish that the expenditures were (a) ordinary and necessary (b) reasonable in amount and (c) incurred for a valid business purpose.

Centralized Purchases

The following purchases must be centralized and processed through the requisition & purchase order (“PO”) process:

• Legal and Title IX services
• Software, memberships, dues
• Furniture, fixtures, equipment
• Library/reference materials
• Purchases over $500
• All contractual documents (monetary and nonmonetary) requiring an authorized signer of the College

Contracts for Products or Services

Contracts must be awarded only to responsible contractors. Individuals responsible for contracts for products and services on behalf of the College must submit them to Purchasing for administrative review prior to signing. All contracts and agreements on behalf of the College must be submitted to Purchasing for review and will be signed by the College’s CFO. Employees, officers, or agents of the College may not participate in the selection, award, or administration of a contract supported if a real or apparent conflict of interest exists. Contracts will be stored in the College’s centralized contracts management system. Oversight, by the individual and/or department contracting for services, will be maintained to ensure contractors perform in accordance with terms & conditions and specifications of contracts.

Review and Audit Process

The Finance Department performs a critical review and audit of any expenditure and may request additional documentation, where required, to establish an ordinary and necessary business purpose. The Finance Department reserves the right to request a higher level approval by a Cabinet member or the President.

Compliance and Accountability

Compliance and accountability are the responsibilities of each individual employee. Each employee incurring expenses must do so in full compliance with this policy. Each employee is responsible for the submission of complete and accurate documentation to substantiate each expense. Procurements or other commitments made by unauthorized personnel are not legal and binding upon the College and may result in a personal payment obligation for the individual making the procurement or commitment.

Conflict of Interest

Employees, officers, or agents of the College may not purchase products and services from businesses or participate in the selection, award, or administration of a contract if they have a real or apparent conflict of interest . Such a conflict of interest would arise where the individual, any member of their immediate family, their partner, or an organization which employs or is about to employ any of these parties has a financial or other interest in or tangible personal benefit from a vendor or contractor under consideration.

Officers, employees, and agents of the College may neither solicit or accept gratuities, favors, or anything of monetary value from potential vendors or contractors. Gifts of a nominal value may be accepted in accordance with the College’s Conflict of Interest Policy.

When any College business transaction under consideration presents the potential for a conflict of interest, the employee concerned shall not be involved in the transaction. Any College employee who is or is to be involved in a College business transaction in which a potential for conflict of interest exists, on their own part or on the part of another College employee, is required to promptly report such potential conflict to Purchasing. See the College’s Conflict of Interest Policy.

Fraud

Any misrepresentation of expenses shall be grounds for disciplinary action, including possible termination of employment. Each procurement of a good or service is a representation that the transaction is a legitimate business expense supported by accurate and genuine documentation. The College will seek repayment and restitution from employees for expenses that are fraudulent or prohibited.

B. Responsibilities

Purchasing Department Responsibility

The Purchasing Department is the central authority for the procurement of goods and services required by all College departments. The Purchasing Department is responsible for the approval of new vendors and entering appropriate vendor information into the Banner system. The Purchasing Department shall determine when a RFP (Request for Proposal), RFQ (Request for Quote), or Bid Request should be utilized to obtain the best overall value on behalf of the College.

The Purchasing Department

• Maintains consistent standards of quality to permit efficient and effective operations.
• Develops alternative sources of supply in order to promote a competitive atmosphere in vendor performance.
• Develops positive relationships with suppliers in order to create an environment which will enable the College to discover new ideas, products, better prices and service.
• Maintains accurate and complete records and controls and assures efficiency and integrity.
• Researches new products which are relevant to the College.
• Establishes standardization in requirements in order to simplify specifications and reduce costs of materials.

Employee Responsibility

Each employee is expected to:

• Spend College money carefully and judiciously only for necessary and reasonable business expenses.
• Exercise good judgment in determining the most economical means of obtaining goods and services.
• Procure goods and services in accordance with this policy.
• Submit documentation for all expenses in accordance with this policy.
• Understand that payment will not be made for expenses lacking adequate documentation.
• Understand and follow the capital asset procedure and policy

Department Budget Manager Responsibility

Department Budget Managers have primary responsibility for ensuring compliance with this policy. Expenses that appear to be unusual or excessive shall be investigated prior to approval. Department Budget Managers must verify that expenses meet the following criteria:

• The expense was incurred for College business.
• The information contained in documentation is accurate, complete, and in accordance with this policy.
• The expenditure is charged to the proper fund, organization, expense account and fiscal year.
• Budget is available for the procurement.
• Goods and services are procured in accordance with this policy.

Finance Department Responsibility

The Finance Department has the primary responsibility for managing the fiscal activities of the College and the related institutional authority delegated by the Board of Trustees for the administration for such matters, including all purchasing policies and transactions.

C. Purchasing guidelines

Purchase Order

A purchase order serves as a binding commitment for delivery of goods and services by a vendor and payment by the College. Unless otherwise allowed by the use of the College P-Card, procurement transactions shall be executed with a purchase order. Funds for known expenditures must be encumbered at the beginning of the fiscal year or as soon as known.

Requisition approval:

• Level 1 Approver: Department Budget Manager up to $5,000
• Level 2 Approver: Associate Vice President or Dean up to $10,000
• Level 3 Approver: Cabinet member or Grant Budget Manager up to $25,000
• Level 4 Approver: Chief Financial Officer or President over $25,000

The Purchasing Procedures must be reviewed prior to submitting a requisition.

III. Receiving

All goods and services, including P-card transactions, must have documentation of receipt.

IV. Invoices

Invoices must identify the authorized and approved purchase order.

Invoices require receiving documentation, an itemized invoice and budget manager approval for payment.

V. Purchase Card (P-Card)

The College's commercial credit card, or purchase card (“P-Card”), is issued to employees who regularly engage in business travel or regularly incur business expenses on behalf of the College that is not available through the College’s Purchasing Department. P-Cards are not to be used for personal expenditures. P-Card holders must comply with the policies, procedures and governing regulations concerning the use of the card.

All P-card transactions require advanced approval from the Department Budget Manager and are subject to the College’s expense policy.

Authorized P-Card purchases

• Business travel: lodging, meals, transportation
• Event/Entertainment meals for external parties (e.g. donors, applicants, alumni)
• Small dollar purchases (under $500) that are not required to be centralized per this policy.
• Emergency use with Finance Department approval

Unauthorized P-Card purchases

• Everything listed under Centralized Purchases.
• Any non-travel purchase over $500.

The P-Card is not to be used for any product, service or with any merchant considered to be inappropriate for College funds. Failure to comply with the above guidelines for authorized purchases under the P-Card program may result in disciplinary action, cancellation of your card privileges, and possible termination of employment.

VI. Capital Assets

Items that meet the following criteria will be reported as a capital asset and tagged by Purchasing:

• Individual item that costs $5,000 or greater and has a useful life of three (3) years or more
• Bulk purchase of the same item that have an: 1) individual cost less than $5,000; 2) is purchased in a single order with a minimum total cost of $25,000 or greater; and 3) has a useful life of three (3) years or more

Capital assets must be included in the approved capital asset budget. Unbudgeted capital asset requests require additional approval from the College’s CFO or President.

VII. Federal and Grant Purchasing Guidelines

All Federal and Grant Purchasing Guidelines must follow institutional purchasing and contract policies in addition to the following guidelines. All procurement using federal funds must comply with Uniform Guidance (view full requirements here), and any agency-specific procurement requirements. Purchases and commitments not in compliance with the Federal requirements will need to be returned, canceled or paid with department funds or other non-federal sources.

• Purchases must be necessary, not duplicative and must provide a direct benefit to the Federal grant
• Transactions must be conducted in a manner providing full and open competition and vendors or contractors involved in the preparation of specifications, requirements or statements of work are excluded from participating in such procurements
• Necessary affirmative steps must be taken to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible
• As appropriate and to the extent consistent with law, the College will, to the greatest extent practicable under a Federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States.
• Transactions must be supported by original detailed and unduplicated documentation, and records must be sufficiently maintained to detail the history of procurement
• Contracts under Federal grants will contain the applicable provisions described in 2 CFR Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
• All solicitations will incorporate a clear and accurate description of technical requirements for the material, product, or service, and identify all requirements which the offerors must fulfill, and all other factors used in evaluating bids or proposals
• All prequalified lists of persons, firms, or products which are used will be current and include enough qualified sources to ensure maximum open and free competition
• Potential bidders will not be precluded from qualifying during the solicitation period
• Cost or price analysis will be performed in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications
• Procurements will be conducted in a manner that prohibits the use of statutorily or administratively imposed state, local, or tribal geographical preferences, except in cases where federal statutes mandate or encourage it
• One of the allowable procurement methodologies will be used

Procurement Methodologies for Federal and Grant Purchases