GAP 200.372, Purchasing Goods on Sponsored Funds

Contents

1. Purpose
2. Micro-Purchases (<$10,000)
3. Small Purchases ($10,000-$250,000)
4. Ordering Process - SAP Buy@Duke
5. Special Commodities Approval Process
6. Federal Regulations

I. Purpose

This procedure describes the methods and operational procedures associated with purchasing goods and other materials from sources external to Duke University on reportable awards. Reportable awards are projects where invoices and financial reports are submitted by an institutional office (Post Award Financial Management or Treasury Billing Services); and are represented by the 20x-28x, A03, and 30x-38x WBS element ranges.

This procedure relies upon knowledge of Duke’s Purchase Orders (POs) and the PO Approval Process. These use Buy@Duke, a web-based procurement system, which is fully integrated into the SAP financial system portal (Duke@Work). In this system, initiators will create shopping carts, which then pass through funding source (project) and institutional approval points through workflow within Duke@Work.

By using established workflow approval paths in Duke@Work, academic units are able to establish internal protocols, spending limits, and roles; therefore, this General Accounting Procedure (GAP) refers to the roles of Shopper, Submitter, and Approver, roles that may or may not be filled by Grant Managers (GMs) or Principal Investigators (PIs). However, as noted in the Research Policy Manual, the PI bears primary responsibility for the financial management of a sponsored project. The Duke Procurement Services website contains forms and descriptions of how to procure and pay for goods and services at Duke University.

Note: The Office of Export Controls (OEC) provides assistance with activities in embargoed or sanctioned countries, as financial transactions in these countries may be restricted. When making purchases in these countries, contact the OEC at export@duke.edu.

II. Micro-Purchases (<$10,000)

Micro-purchase procedures are appropriate for purchases where the micro-purchase threshold (MPT) (currently set at $10,000 per the Federal FY2017 National Defense Authorization Act (NDAA)) is not exceeded. Please note the aggregate total cost of a purchase may be identified by:

• an item whose individual value does not exceed the MPT;
• an item whose aggregate total cost does not exceed the MPT; or
• a set of items whose aggregate total costs does not exceed the MPT; or
• an asset under construction, where the aggregate total of the component parts is determined to not to exceed the MPT

Please note that purchases of an identical item should only be split between Buy@Duke carts when the scientific programmatic needs of the project require multiple purchases over a period of time. In these scenarios, GMs should proactively work with Procurement Services and their PAFM liaison to determine the appropriate procedures.

These purchases do not require competitive bids if the academic unit finds the price to be reasonable and allowable under Duke’s costing GAPs, such as GAP 200.320 Direct Costing on Sponsored Funds. If the purchases are allowable, the Buy@Duke Carts are routed through appropriate Shopper, Submitter, and Approver workflows as dictated by the academic unit practices.

III. Small Purchases ($10,000 - $250,000)

Small purchase procedures are appropriate for purchases at or above the MPT ($10,000), but below the simplified acquisition threshold (SAT) (currently set at $250,000 per the FY2018 NDAA). This can apply to the purchase of:

• An item whose individual value exceeds the MPT;
• An item whose aggregate total cost exceeds the MPT;
• A set of items whose aggregate total costs exceeds the MPT; or
• An asset under construction, where the aggregate total of the component parts is determined to exceed the MPT

Please note that purchases of an identical item should only be split between Buy@Duke carts when the scientific programmatic needs of the project require multiple purchases over a period of time. In these scenarios, GMs should proactively work with Procurement Services and their PAFM liaison to determine the appropriate procedures.

On purchases exceeding the MPT, the UG requires projects to solicit or collect price or rate quotations from an adequate number of qualified sources. In order to meet this requirement at Duke, a minimum of three (3) price or rate quotations must appear in the Notes and Attachments section of the Buy@Duke shopping cart. Price or rate quotations may take the form of bids, proposals, online listings (screenshot required), or another form approved by the Procurement Office.  This requirement does not apply to purchases where the vendor/supplier appears in the Buy@Duke marketplace (electronic catalogues).

If a minimum of three price or rate quotations are not provided, or if the lowest price quote is not selected, a completed Sole Source Justification / Price Quote Selection form as applicable and described in GAP 200.101, Sole Source Justification for Purchases on Sponsored Funds must appear in the Notes and Attachments section of the Buy@Duke cart.

IV. Large Purchases (>$250,000)

Purchases of more than $250,000 require coordination with Procurement Services. Please contact the Procurement Services for further information.

V. Ordering Process – SAP Buy@Duke

As referenced in Section I, the process for purchasing goods and other materials from sources external to Duke University on reportable awards relies upon knowledge of Buy@Duke and the PO process. Below are the various steps that will occur when using this system to purchase goods and other materials, depending upon the items being purchased and sponsor requirements:

1. A shopper creates a Cart in Buy@Duke, and, following appropriate academic unit workflow and purchase procedures, receives approval and submits for further review as necessary.
2. If central office review and approval are required, SAP Buy@Duke system will automatically route a Cart to the appropriate office, based on the nature of the goods being purchased, as applicable (see Section VI below for complete details). These offices (PAFM, OESO, DLAR) will review for compliance with the terms of the award, and appropriateness of the WBS element and G/L. If the Sponsor required prior approval for the purchase, documentation of this approval should be included with the Cart. Once the Cart has received approval from all relevant offices, it then routes to Procurement Services. (see Section VI below for complete details on these special purchases)
3. Procurement Services reviews the Cart to ensure compliance with University and sponsor purchasing procedures. Upon review and action, Procurement Services will issue a PO.

VI. Special Commodities and Their Ordering Process

The procurement of certain items will require additional documentation and additional approvals beyond existing grant and departmental SAP Buy@Duke workflows. If these goods are purchased using sponsored funds from reportable awards, GMs and PIs must ensure the appropriate documentation is attached to the Buy@Duke cart before submitting it for review:

1. Capital Equipment
   If the purchase is a Capital purchase of more than $10,000 for UNIV and $5,000 for DUHS, the Equipment Screening form must appear in the Notes and Attachment section of the Cart. For further instruction, consult GAP 200.100, Capital Equipment Purchases on Sponsored Projects.
2. Radioactive Substances
   The Radiation Safety Division of Duke’s Occupational & Environmental Safety Office (OESO) must approve purchases of radioactive substances on sponsored funds. Carts with radioactive substances must include the Radioactive Material Order form, complete with authorized users names and numbers. Radiation Safety is responsible for submitting the PO to the vendor, receiving the radioactive materials, and delivering the materials to the Authorized Users indicated on the Order From. For more information, consult the OESO website(link is external).
3. Live Animals
   The Division of Laboratory Resources (DLAR) must review all Buy@Duke Carts for live animals using sponsored funds. Carts with live animals must also have the Animal Order Request form attached. DLAR is responsible for submitting the PO to the vendor, receiving the live animals, and distributing the animals to the individuals listed on the Order Request. For further information, consult the myRESEARCHpath(link is external).
4. Controlled Substances for Animal Use
   DLAR also serves as the purchaser of controlled substances for animal use. Procedures for ordering controlled substances are located on myRESEARCHpath(link is external).

VII. Federal Regulations

This GAP reflects the provisions of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance. The UG became effective as of December 26, 2014, and revised as of November 12, 2020, and all awards issued on or after this date must be managed in accordance with its provisions. It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency.

These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-federal sponsor’s policies and/or procedures.

This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc.