NOT APPROVED YET
922.1 Purpose
The following procedure outlines the federal requirements for making purchases with Federal grant funds. It ensures all procurement activities comply with applicable regulations, promote transparency, and support responsible stewardship of public resources. The procedure that follows summarizes the standards recipients must follow when acquiring goods or services using Federal grant funding.
These procedures are implemented in alignment with CEI Purchasing and Procurement Policy 214, which governs all College procurement activities and provides the overarching policy framework for federal grant purchases.
The College of Eastern Idaho must always follow the most restrictive policies and procedures. When federal, state, local, or internal rules differ, CEI must follow the rule that imposes the strictest requirements to ensure full compliance.
922.2 Definitions
The following definitions apply to this procedure and are provided to ensure clarity and consistency in interpreting the requirements.
· Micro-purchase threshold refers to the maximum dollar amount that can be spent on a purchase without obtaining multiple quotes or conducting a formal competitive process. Purchases at or below this threshold may be completed using simplified, expedited procurement steps.
o The micro-purchase threshold for CEI is $4999.00.
· Simplified acquisition threshold means the maximum dollar amount an organization may spend on goods or services using streamlined procurement procedures rather than a full, formal competitive bidding process.
o The maximum dollar amount that CEI may spend before a formal bid process is required is $250,000.
· Domestic preference refers to federal requirements that encourage, or require, agencies and recipients of federal funds to prioritize purchasing goods, products, and materials that are produced in the United States.
· Recovered materials refer to products and services that, to the greatest extent practicable and consistent with law, should be purchased, acquitted, or used by the recipient or subrecipient when they can be reused, refurbished, or recycled: contain recycled content; are biobased; or are energy – or water-efficient and otherwise sustainable.
922.3 Procedures
Procurement-Federal Updates
Federal Funds Procurement Requirements Subsection
SAM.gov / Debarment & Suspension (2 CFR §200.214)
When purchases are made with federal grant funds, CEI shall not award contracts or subawards to any vendor, contractor, or subrecipient that is debarred, suspended, or otherwise excluded from participation in federal programs. Prior to executing any federally funded purchase order, contract, or subaward, the Procurement Department or designee must verify the entity’s status in SAM.gov, document the verification (e.g., date-stamped screenshot or equivalent), and ensure the documentation is retained in the procurement and grant file. Re-verification is required at least annually or upon contract renewal for multi-year agreements.
Domestic Preference & Recovered Materials (2 CFR §§200.322–323)
For procurements supported by federal funds, CEI will apply domestic preference and recovered materials requirements consistent with 2 CFR §§200.322–323 and applicable federal statutes. When practicable and permitted by law, CEI will provide a preference for U.S.-produced goods, products, and materials and will procure items containing recovered materials in accordance with federal guidelines, while also complying with Idaho Code and CEI sustainability goals. These requirements shall be reflected in solicitation and purchasing documents for federally funded acquisitions.
Affirmative Steps for Small/Minority/Women-Owned Businesses (2 CFR §200.321)
In procurements funded with federal awards, CEI will take all necessary affirmative steps to encourage the participation of small businesses, minority-owned businesses, women’s business enterprises, and labor surplus area firms, as required by 2 CFR §200.321. Affirmative steps may include placing such firms on solicitation lists, ensuring they are solicited whenever they are potential sources, structuring procurements to permit their participation where economically feasible, and requiring prime contractors to take similar steps in any subcontracts.
Procurement History Documentation (2 CFR §200.318(i))
For purchases made with federal grant funds, procurement files must be sufficient to document the full history of the procurement in accordance with 2 CFR §200.318(i). At a minimum, records shall include: the method of procurement used; the type of contract selected and the rationale for that choice; documentation of quotes, bids, or proposals; the basis for contractor selection or rejection; and the basis for the contract price. This documentation is in addition to standard CEI requirements such as purchase orders, invoices, and receiving records.
Cost/Price Analysis (2 CFR §200.324)
When the value of a procurement funded in whole or in part with federal grant funds exceeds the Simplified Acquisition Threshold, or when otherwise required by the funding agency, CEI will perform
and document an appropriate cost or price analysis in accordance with 2 CFR §200.324. The level of analysis will be commensurate with the complexity and risk of the purchase and may include independent estimates, comparison of competitive quotes or bids, and separate consideration of contractor profit when there is no price competition. The resulting analysis must be retained in the procurement file.
Noncompetitive (Sole Source) Procurement Conditions (2 CFR §200.320(c))
When federal grant funds are used, noncompetitive (sole source) procurement may only be used under the limited circumstances permitted by 2 CFR §200.320(c). These include: purchases at or below the micro-purchase threshold; situations where the item or service is available only from a single source; public exigency or emergency conditions that do not allow time for competitive solicitation; express written authorization from the federal awarding agency or pass-through entity; or where, after soliciting a number of sources, competition is determined to be inadequate. All such procurements must be fully justified, documented, and approved in accordance with CEI procedures and retained in the procurement file.
Segregation of Duties (Procurement vs. Cash Drawdowns)
To maintain strong internal controls and comply with federal grant requirements, CEI will segregate duties between personnel who initiate and approve purchases and those who process cash drawdowns or reimbursement requests on federally funded accounts. Individuals responsible for authorizing or approving purchase transactions should not be the same individuals who initiate or approve corresponding federal drawdown requests whenever practicable. The Procurement Department, Business Office, and Grants Administration will coordinate to ensure roles are assigned in a manner that minimizes conflicts and reduces the risk of error or fraud.
Federal Equipment Procurement Requirements (2 CFR §§200.310–316)
When equipment is purchased with federal grant funds, CEI must follow the federal property standards outlined in 2 CFR §§200.310–316. These standards apply in addition to CEI’s general inventory requirements and ensure proper acquisition, use, safeguarding, and disposition of federally funded equipment. (CEI Inventory Policy 402)
· Lease vs. Purchase Analysis (2 CFR §200.318(d))
Before acquiring equipment with federal funds, CEI must conduct and document a lease-versus-purchase cost analysis to determine the most economical option. This analysis must be retained in the procurement and grant file and must be completed prior to initiating the purchase requisition.
· Priority of Use for Federally Funded Equipment (2 CFR §200.313(c))
Equipment purchased with federal funds must be used first for the project or program for which it was acquired and then made available for use on other federally funded projects, as long as such use does not interfere with the original project. When no longer needed for any federal purpose, the equipment may be used for non-federal CEI activities in accordance with federal and institutional policies.
· Federal Equipment Disposal Requirements (2 CFR §200.313(e))
For equipment with a current per-unit fair-market value greater than $5,000, CEI must obtain prior written approval from the federal awarding agency before disposal or sale. CEI must follow the federal agency’s disposition instructions and return any required share of proceeds. Disposal of federally funded equipment must be coordinated through the Procurement Department and Grants Office.
· Loss, Damage, or Theft Reporting (2 CFR §200.313(d))
Any loss, damage, or theft of equipment purchased with federal funds must be reported immediately to the Business Office, Grants Office, and CEI Campus Security. When required, CEI will also notify the federal awarding agency. Documentation of the incident and corrective actions must be retained in the procurement and grant files.
· Subrecipient Equipment Requirements (2 CFR §§200.313 & 200.331)
When federally funded equipment is provided to or purchased by a subrecipient, CEI must ensure the subrecipient adheres to all federal equipment management standards, including safeguarding, tracking, reporting, and disposition. These requirements must be included in subaward agreements and monitored as part of CEI’s subrecipient monitoring procedures.
· Equipment Inventory Frequency (2 CFR §200.313(d)(2))
Federal regulations require that equipment purchased with federal funds be inventoried at least once every two years. CEI conducts an annual physical inventory, which satisfies and exceeds this federal requirement. Procurement and Business Office staff must ensure federally funded equipment is included in CEI’s annual inventory process.