The Ohio State University is delaying implementation of the new procurement requirements in OMB 2.CFR.200.320 until July 1, 2017. The university will continue to comply with the procurement standards in the OMB guidance at 2 CFR §200.110(a) until that time.
The Procurement department provides valuable purchasing, travel, and property management services to the Office of Sponsored Programs, Ohio State faculty, staff, and research sponsors.
Principal investigators who direct sponsored programs will need to obtain equipment, supplies, parts and services from university and commercial sources to conduct their projects. The Office of Sponsored Programs maintains a federally approved procurement department that is required for purchasing items on federal grants and contracts for use by sponsored projects personnel.
All purchases must be conducted in a manner that will provide open and free competition to the maximum extent practical and consistent with applicable federal cost principles. Departmental procedures reflect the ethical standards of the Office of Sponsored Programs and the university. All university personnel authorized to conduct purchasing activities shall adhere to these principles and standards. Each employee involved in the expenditure of public funds is held to the highest degree of public trust. No employee shall engage in or permit any illegal or improper purchasing practices, including but not limited to the following:
- Submission of equal or rotated bids
- Kickbacks (Reference the Anti Kickback Act and Public Law 99-6334)
- Conflicts of interest
- Acceptance of gratuities
- Participation in any community of financial interest with bidders
- Elimination of competition or restraint of trade
- Violation of minimum wage or payment schedules for construction contracts
- Violation of standard work week, overtime and safety standards for construction contracts
Any employee having knowledge of any of these practices or other unethical or illegal conduct by any employee should immediately report this knowledge to the Director of Procurement. Engaging in or permitting unethical or illegal conduct or the failure to report such conduct constitutes grounds for disciplinary action, including possible termination of employment and/or criminal prosecution.
Terms and Conditions
Policies and Procedures
Small and Small-Disadvantaged Business Subcontracting
The policy of the Office of Sponsored Programs and The Ohio State University is to promote the procurement of goods and services from small, small-disadvantaged, woman-owned, veteran-owned businesses and vendors located in Labor Surplus areas whenever possible. It is the responsibility of both the PI and the Procurement Department to direct purchases toward these types of businesses.
Additionally, Public Law 95-507 requires implementation of a subcontracting plan with established goals for expenditures to small and small-disadvantaged businesses for all federally sponsored contracts in excess of $500,000. The Business Opportunity Development Reform Act of 1988 (Public Law 100-656) requires that a prime contractor pay liquidated damages upon a finding of lack of good-faith effort to meet its small business subcontracting goals. The liquidated damages will be assessed at the actual dollar amount by which the contractor failed to achieve each subcontract goal. The government also has authority to impose other penalties such as cancellation of the contract award. Any monetary penalty will be assessed to the PI’s department.
The U.S. Environmental Protection Agency (EPA) requires that eight per cent of the total dollars available for expenditures on EPA grants and contracts be made to small-disadvantaged and woman-owned businesses.
Subcontracting plans for small and small-disadvantaged business, as required for proposals/awards, should be developed jointly between the Sponsored Program Officer, the PI, and the Director of Procurement. After the award of the grant or contract that includes either a subcontracting plan or EPA Fair Share Goal, Purchasing will screen requisitions for possible placement with a small or small-disadvantaged business, administer the subcontracting plan, and submit reports, as required, to the sponsoring agency or to the U.S. Small Business Administration. Project leaders with subcontracting plans or EPA Fair Share Goals are responsible for effectively implementing small and small-disadvantaged utilization programs. This includes achieving program goals and taking all reasonable action to increase small and small-disadvantaged participation in their project’s purchases.
Purchasing maintains directories and other source information on small, small-disadvantaged, woman-owned, veteran-owned businesses, and vendors located in Hub Zones, “Historically Underutilized Business Zones,” to assist principal investigators in locating such businesses. Additional resources include:
All vendors contracting or selling goods and services to sponsored projects must have completed or have on file in Purchasing, a Vendor Profile/Business Status Certification/Registration Form PR-015 prior to issuance of any purchase order or subcontract. Individuals who are not licensed merchants or do not have a Federal Tax Identification Number are not permitted to receive purchase orders.
Pursuant to Federal Acquisition Regulation (FAR) section 9.4, any vendor/contractor who is debarred from receiving federal procurements or is shown in the “List of Parties Excluded from Federal Procurement or Non-procurement Programs” may not contract with the Office of Sponsored Programs.