GAP 200.372, Purchasing Goods on Sponsored Funds

  1. Overview
  2. Competitive Bids/Sole Source
  3. Ordering Process – SAP Buy@Duke
  4. Special Commodities and Their Ordering Process


Purchasing on Sponsored Funds requires certain procedures to ensure the University meets requirements imposed by sponsoring agencies. Federal sponsors in particular have stringent purchasing requirements depending on the mechanism Duke is awarded. It is important to understand the requirements of each award prior to making purchases. This policy applies to restricted WBSE (20X-25X, 28X, 30X-35X, 38X).

Federal awards issued prior to December 26, 2014 should be managed in accordance with OMB Circulars A-21, A-110, and A-133. Federal awards issued on or after December 26, 2014 should be managed in accordance with 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance). Note that Duke, as provided in the Federal Register on May 17, 2017 (82 FR 22609) has delayed implementation of the Uniform Guidance Procurement Standards until July 1, 2018. Prior to that date, Duke continues to apply the Procurement Standards outlined in the OMB Circular A-110 to all purchasing on Federal grants and cooperative agreements. It is important to verify the appropriate regulations applicable to your award.  Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency.

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

The purchasing of goods requires specific terms and conditions depending on the funding source and other factors related to the type of good being purchased. This procedure describes the steps required to purchase goods using funds from a sponsored project. Additionally, regarding the purchase of goods in foreign countries, please note that the Office of Export Controls provides assistance with activities in embargoed/sanctioned countries. Financial transactions may be restricted in these countries. Please contact the Office of Export Controls before engaging in any activities involving sanctioned countries at export at or refer to the ORS website for more information.


Competitive bids (3) are required when initiating a purchase request in excess of the simplified acquisition threshold when the order totals $10,000 or more AND is purchased against a restricted WBSE.

If the Requestor initiating the purchase elects not to purchase from the vendor providing the most cost effective quote OR three competitive bids cannot be obtained, a source justification is required. When purchasing supplies covered by a Duke University contract, no competitive bids or sole source justification are required as the University contract has already met competitive bid and justification requirements.

More information can be found in GAP 200.101, Sole Source Justification for Purchases on Sponsored Funds.


  1. Complete the Cart in Buy@Duke. The department is responsible for ensuring that items being purchased are allowable by the Sponsor and funds are available. All charges to Sponsored Funds must be in compliance with GAP 200.320, Direct Costing on Sponsored Funds.  

  2. Once the department has completed and approved the Cart, it will be routed to the Office of Sponsored Programs automatically by the SAP Buy@Duke system. The Office of Sponsored Programs will review the Cart for compliance with the terms of the award, appropriateness of the WBS element used, correct Capital purchase G/L, and availability of funds. If the Sponsor requires prior approval of the purchase, the principal investigator is responsible for requesting such approval. The Sponsor’s approval must be sent to the Office of Sponsored Projects.

  3. If the Cart is acceptable, and it has received all required information, the Office of Sponsored Projects will approve the Cart directly in SAP Buy@Duke. Workflow will route the Cart to other departments (OESO, DLAR, SOM, etc.) as necessary. It will then be routed to Procurement Services.

  4. Procurement Services will follow normal purchasing procedures plus sponsoring agency requirements, if any, when reviewing the Cart. If the Cart is complete and acceptable a Purchase Order will be issued. 


  1. Capital Equipment
    If the purchase is a Capital purchase ($5,000 or greater), attach in the notes and attachments section of the Cart, the Equipment Screening form required in accordance with GAP 200.080, Equipment Screening and Shared Use on Federal Sponsored Projects.

  2. Radioactive Substances
    If a department will be purchasing Radioactive substances using a restricted WBSE, Duke Occupational & Environmental Safety Office’s (OESO) Radiation Safety Division must approve the Buy@Duke Cart. The Requestor is responsible for completing and attaching the Radioactive Material Order Form with Authorized Users Name and Authorized Users Number to all Carts. Radiation Safety will submit the Purchase Order to the vendor, receive the order from the vendor, and deliver Radioactive shipments to the Authorized User. For more information you can go to the OESO website.

  3. Animals
    The Division of Laboratory Resources (DLAR) must review all Buy@Duke Carts for Live Animals being purchased against a restricted WBSE. The Requestor is responsible for completing and attaching the Animal Order Request form to all Carts. DLAR will then submit the Purchase Order to the vendor. Animal orders are delivered to DLAR and they receive and deliver all live animals to the respective Goods Recipient. For more information you can go to the DLAR website.

  4. Controlled Substances for Animal Use
    Controlled substances are purchased through the Division of Laboratory Resources (DLAR). Procedures for ordering controlled substances are located on the Duke Animal Care and Use Program website. The policy is titled "Controlled Substance Procedure – Controlled Substance Use and Management Procedures."