Policy update - May 18, 2022
May 18, 2022
The following policy document has been updated and is now published and effective. In order to implement a key internal control measure, this document was published through an expedited review process. Community comments are, however, still welcomed and encouraged. Please discuss the document with the appropriate people in your department and send any questions or feedback to email@example.com.
Policy 3201 General Purchasing
- Policy 3201 General Purchasing – Revised
This policy is from the Procurement Department. It was updated in order to implement a key internal control measure. Specifically, the following new language was added regarding the prohibition on transaction splitting:
“It is prohibited to “split” a transaction into multiple transactions to purposely evade any requirement of this or any other University policy. For example, if a purchase of goods and/or services from a Supplier is anticipated to equal or exceed $10,000, it is not permitted to split the goods and/or services purchase into multiple separate transactions of less than $10,000 in order to purposely evade approval thresholds or the requirements associated with the Small Purchase Threshold.
Note: If a transaction is expected to be less than a certain dollar threshold (e.g., $10,000) and later equals or exceeds that dollar threshold (including change orders to POs), the unit making the purchase must fulfill any obligations associated with the new total dollar threshold (e.g., sole source/comparative pricing).”
In addition, this policy received several minor updates for the purpose of clarifying existing language. None of these minor updates substantively changed any previously existing rules or processes. The policy also received a formatting update in the creation of three new sections pertaining to the purchase of restricted or specialized goods and services and additional approvals required for certain purchases. These sections do not create new policy; rather, they replace two formerly existing charts that members of the community found confusing.
Procurement anticipates the potential for incremental revisions to this policy and its related procedures over the next several months as the result, in part, of enhancements to certain internal controls. Those revisions will be rolled out and communicated separately as they occur.
Always check the Policies & Procedures website for the latest revisions of all documents. This will ensure you that are utilizing the most up-to-date version.
If you have any questions, please contact Policy & Compliance Services at firstname.lastname@example.org.