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POLICY – PROCUREMENT FOR FEDERAL GRANT FUNDED PURCHASES
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. This policy is governed by OMB 2 CFR Part 200 and is consistent with Final Guidance issued by the Federal Office of Management and Budget. Links:
This Procurement Policy for Federal Grants applies to all expenditures of monies received through federal grants, whether those monies come directly from a Federal agency or through an intermediary, known as a “pass-through entity.” This Policy does not govern expenditure of funds received from other sources (e.g. research foundations, alumni donations, etc.). While reference may be made from time to time simply to “procurement transactions,” this Policy applies only to such transactions funded with federal monies.
Federal law imposes particular requirements on the use of federal grants. This Procurement Policy is designed to ensure that Central College complies with those requirements. Individual federal grants may contain further requirements that are unique to those grants and in addition to the requirements of this Policy. It is therefore important for the Department receiving the grant to work with the Business Office to ensure compliance with the requirements of each grant.
Scope
This policy applies to any designees authorized to initiate purchases on behalf of a federal grant. This policy is not applicable to the general purchases of the College.
Definitions
Federal Award: Financial assistance received directly from a federal agency or indirectly through a pass‑through entity.
Federal Grant: A federal award providing funding to carry out a public purpose authorized by U.S. law.
Pass‑Through Entity: A non‑federal entity that provides a subaward to another entity to carry out part of a federal program.
Procurement: The process of acquiring goods or services, including solicitation, selection, contract award, and contract administration.
Allowable Cost: A cost that is reasonable, allocable, necessary to the grant, and permitted under the terms of the federal award and applicable regulations.
Micro‑Purchase: A purchase of goods or services with an aggregate cost not exceeding the federal micro‑purchase threshold.
Small Purchase: A procurement method for purchases exceeding the micro‑purchase threshold but not exceeding the Simplified Acquisition Threshold.
Sealed Bids: A formal procurement method in which bids are publicly solicited and awarded to the responsible bidder offering the lowest fixed price.
Competitive Proposals: A procurement method in which written proposals are solicited from qualified sources and evaluated based on price and other factors.
Non‑Competitive Procurement (Sole Source): Procurement through solicitation of a single source when only one vendor is available or when special circumstances justify its use.
Cost or Price Analysis: A review and evaluation of the reasonableness of a vendor’s price in relation to the goods or services being purchased.
Conflict of Interest: A situation in which an employee, officer, or agent has a financial or personal interest that could compromise objectivity in a procurement decision.
Responsibilities
The Grant Recipient is responsible to:
- Determine whether a purchase is allowable under the terms of the federal grant and will ensure purchases are in accordance with this policy.
- Maintain appropriate documentation supporting compliance with the procurement process noted above in accordance with the records retention policy of the College.
- Comply with the requirements of the grant once awarded including but not limited to appropriate spending and recordkeeping.
CFO and Controller: provide guidance related to this policy.
Business Office: Maintain appropriate financial books and records in support of the grant.
Policy Details
Code of Conduct: No employee, officer, or agent must participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a party considered for a contract.
Process: To promote compliance with federal regulations, the College requires purchasers to perform some measure of cost/price analysis when making purchases under federal grants. Purchasers shall avoid purchasing unnecessary and duplicative 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.
Purchasers should 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 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 practical and economically feasible, for such products.
The following chart details what must occur based on the level of aggregate purchase amount:
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Aggregate Purchase Amount
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Federal Policy
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Description
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1. Micro-purchase Up to $15,000
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Purchases may be made without soliciting competitive price or rate quotations.
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The price should be reasonable based on research, experience, purchase history or other information.
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2. Small purchase $15,001 - $350,000
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Price or rate quotes must be obtained from an adequate number of qualified resources. Quotes may be in writing, verbal, or via internet search.
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College policy: Obtain 2-3 price quotes. Forward quotes to the Business Office.
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3. Purchases > $350,000+
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Sealed Bids OR Competitive Proposals:
Sealed Bids: must be publicly solicited. Bids should obtain a firm fixed price and must be awarded to the lowest bidder
Competitive Proposals: Written proposals from 2-3 sources must be solicited
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Sealed Bids: Preferred method for construction. Obtain 2-3 price quotes. Forward quotes to the Business Office
Competitive Proposals: Typically used when conditions are not appropriate for the use of sealed bids
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4. Non-competitive purchases—all purchase levels (under special circumstances)
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Solicitation of only one bid proposal is required (from required or preferred vendor).
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Typically used when changing a vendor would impact results or if only one vendor is available. Approval required from CFO and Controller.
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Last Revision Date: 02/20/2026
Policy Owner: Chief Financial Officer