POLICY & PROCEDURE DOCUMENT NUMBER: 3.2690 2.2690 DIVISION: Finance and Administration Research TITLE: Grant Purchasing Policies & Procedures DATE: June 30, 2014 Authorized by: K. Ann Mead, Sr. VP for Finance & Administration Gordon C. Baylis, VP for Research I. Purpose and Scope This policy covers purchasing goods and/or paying for services on a grant index. II. Policy 1. Associated with nearly every restricted project is the procurement of goods. According to OMB, items such as supplies and other expendable property are expected to be used in accordance with the terms and conditions of the award. Auditors are very sensitive to stockpiling or spending lots of money on supplies towards the end of an award. Regulations prohibit the purchasing of unnecessary and duplicative items, or incurring unnecessary or unreasonable expense. 2. The PI is responsible for determining the reasonableness, allocability, and allowability of costs in accordance with the provisions of all applicable regulations and the terms and conditions of each award. The PI must ensure all expenditures charged to restricted accounts comply with applicable federal, state, university, and sponsor regulations. 3. To be allowable, an expenditure must be: a. Justifiable - necessary to meet the goals and objectives of the project; 1 b. Reasonable – cost efficient; is it an action that a prudent person would take under the same circumstances; c. Allocable – identifiable with the project incurred solely to advance its work; d. Timely – needs to be paid as soon as expense occurs; and e. Non-personal – must be business related. 4. OMB Circular A-21(J)(27) states “all material costs charged to a project should only include those supplies actually used in the performance of the agreement”. If an item does not arrive until after the agreement has expired, then it could not possibly have been used in its performance. WKU is required to allocate the costs of goods to the fiscal year in which they are received and services to the year they are rendered. WKU’s fiscal year runs from July 1 to June 30. III. Procedures 1. There are two ways to purchase and/or pay for goods and services: (1) the requisition process, or (2) the procurement card. If something is being purchased internally an interaccount form will be used. 2. Regardless of the method used to procure goods or services, there are certain general policies that apply: a. All restricted accounts must follow university guidelines, see policies 3.5xxx b. All charges are to be coded to the correct account code based on the item; c. The expense must be identified in the sponsor approved budget (supplies, postage, equipment, etc.). For example, if the sponsor did not approve local telephone costs, then local telephone charges cannot be charged to the project; d. Services are to be paid out of the same fiscal year in which the services are rendered; e. Goods are to be paid out of the same fiscal year in which the goods are received; f. Travel is to be paid out of the same fiscal year in which the trip occurs; and g. WKU is a tax-exempt organization. Therefore, no Kentucky sales tax will be paid to vendors. IV. Related Policies All 3.25xx, 3.26xx and 3.27xx policies 2