3201 General Purchasing

Responsible Official: 
Chief Procurement Officer
Responsible Office: 
Procurement
Effective Date: 
July 1, 1998
Revision Date: 
July 1, 2017

* This policy has been updated to accommodate Workday Financials business processes and terminology.  Please note the effective revision date.

Note:

  • Guidelines for buying sustainable products or services are posted to the Yale Sustainability website.
  • The Director of Purchasing or designee approves purchase orders between $10,000 and $1,000,000.
  • The Chief Procurement Officer or designee approves purchase orders greater than $1,000,000.
  • The Vice President for Finance and Chief Financial Officer or designee approves purchase orders greater than $5,000,000.
  • Competitive bidding requirements are clarified.

Policy Sections

3201.1 Overview

3201.2 Ethical Practices

3201.3 Purchasing Methods

3201.4 Competition and Supplier Selection

3201.5 Bidding and Cost Analysis

3201.6 Issuance and Authorization of Purchasing Transactions

3201.7 Secondary Authorization

3201.8 Receipt of Goods Acknowledgment

3201.9 Tax Issues

3201.10 Contract Signing Authority

Scope

This policy outlines the practices for purchasing all goods and services at Yale University, except as noted in the next paragraph.  The policy addresses ethical practices, purchasing methods, supplier selection, bidding and cost analysis, approval of purchasing transactions, signing authority, receipt of goods and services acknowledgment, and sales tax issues.    

Purchases not covered by this policy include investment management services, legal, tax, accounting and, external auditing services, architectural, engineering and construction services, insurance, employee travel costs, employee benefit programs, real estate, services relating to intellectual property rights, and subcontracting.  Refer to Table 2 in Section 3201.6 of this document for the appropriate departments to contact for these topics.

Exclusions from Competitive Bidding

While the overall policy must be followed, the specific requirement for competitive bidding or sole source documentation is waived for the following categories of goods and services: investment management services, legal services, lecturers and guest speakers, portrait artists, musical professionals, theatrical artists involved in the production or performance of a live event, publishing fees, museum artifacts and art collections, rare books and other rare collection materials.

IMPORTANT:  All new federal funds (new awards and new monies, such as continuation awards, supplements, etc.) received for existing federal awards with a start date on or after December 26, 2014, are subject to 2 CFR Part 200 (OMB Circular A-81, commonly referred to as Uniform Guidance or 2 CFR Part 200).  To assist with transitioning, OMB has granted an extension to July 1, 2018 for Yale’s implementation of A-81’s Procurement requirements.  Therefore, between now and June 30, 2018, Yale’s current policy will remain in effect and is in compliance with the requirements of OMB Circular A-110.

Contact the Office of Sponsored Projects for guidance regarding purchases related to sponsored awards at (203) 785-4689 Fax (203) 785-4159.

Policy Statement

Yale University personnel shall purchase goods and services using practices that are compliant with federal and state laws and aligned with Yale’s best business practices.  Furthermore, goods and services purchased with sponsored funds must comply with sponsor terms and conditions.  Finally, whenever possible, Yale University personnel must purchase goods and services using the suppliers in the Yale’s e-procurement solution thereby maximizing the University’s buying power.

Definitions

Certificate of Insurance
Proof of insurance provided by a supplier.

Competitive Bidding Threshold
The amount at which competition via bids and quotes from multiple suppliers is required before purchase of a good or service.  The University’s competitive bidding threshold is $10,000. 

Contract 
An agreement between Yale and a single supplier that may include pre-negotiated pricing, terms, and conditions for the purchase of specific goods/services.

Diversity Suppliers
Suppliers who can certify that they meet the standards for small, disadvantaged, minority, and/or women-owned suppliers set by the federal Small Business Administration.

Environmentally Preferable Purchasing (EPP)
The purchases of products and services that have a reduced effect on human health and the environment when compared with competing products that serve the same purpose.  This comparison should consider raw materials acquisition, production, manufacturing, packaging, distribution, reuse, operation, maintenance, or disposal of the product.

Internal Service Providers (ISP)
Units within the University that provide goods/services to other departments within the University.

Purchase Order
An offer to purchase and a legal commitment to supply the University with goods and/or services.

Purchase Requisition
The Yale department-generated source document required to initiate a purchase order.  Purchase requisitions include a description of customer requirements, valid charging instructions and delivery instructions, and the required departmental approval.

Purchasing Card (PCard)
The Yale PCard is a University-sponsored credit card program that is used for the facilitation of and payment for Yale travel-related services and the purchase of miscellaneous small dollar goods and services, necessary to conduct Yale business.

Purchasing Conflict of Interest
A Purchasing Conflict of Interest exists when the Yale employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a supplier considered for a Yale purchasing transaction.

Receipt Acknowledgment
The acknowledgement of the receipt of goods or completion of services.  When required, this step is necessary before supplier payment.

Sole Source Justification
Required when goods to be procured are unique or proprietary, or a supplier has an exclusive or territorial agency and competition cannot be facilitated.

Supplier Contracts
Special agreements that Purchasing Services has established with a small population of suppliers to maximize the purchasing power of the University and reduce the overall cost of goods and services.  These contracts offer numerous features and provide an overall best value for the University.  Departments using these agreements do not have to perform competitive bidding as this has been completed by Purchasing Services.

Supplier
A person or organization that provides goods or services to the University.  The term supplier is used interchangeably with the term vendor.

Vendor
A person or organization that provides goods or services to the University.  The term vendor is used interchangeably with the term supplier.

Yale’s Expense Management Solution
Yale’s expense management solution includes the processing, creation and submission of expense reports for the following expenditures: travel expenses, reimbursements for materials or supplies purchased with or without a PCard, out-of-pocket reimbursements, or requests for cash advances.

Yale’s E-Procurement Solution
The Workday Create Requisition function replaces SciQuest as Yale’s e-procurement solution as of July 1, 2017.  SciQuest catalogs and contract pricing are available via the Connect to Supplier Website option.

Purchases for University business must be made using specified methods, as stated in Section 3201.3.  The University’s competitive bidding threshold is $10,000.  Purchases at or above this threshold require competition via bids and quotes from multiple suppliers before the purchase of a good or service.  The $10,000 level is determined by the total value of the requisition or based upon the quote received from the supplier.  Purchasing Services may be used as a resource or for guidance as needed. 

All University employees involved in the purchasing process must follow the requirements set forth in the University’s Standards of Business Conduct and Policy 2201 Gifts from External Parties to Employees. Any situation that compromises, or appears to compromise, any personnel involved in the procurement process must be reported immediately to the Chief Procurement Officer or Director of Purchasing Services.  Violation of the requirements noted above will lead to disciplinary action, up to and including termination of employment.

 Conflict of Interest

A.  Purchases related to federal awards or federal pass-through subawards

All University employees who participate in the selection, award, or administration of a purchasing transaction (e.g., Purchase Orders, Purchasing Agreements, Purchasing Contracts, PCard Transactions or others) related to a federal award or federal pass-through sub-award must be free from real or apparent Purchasing Conflicts of Interest (as defined in the Definitions above).  If such a conflict exists, the purchase of goods or services from the supplier directly or indirectly (e.g. buying from a supplier through an intermediary company) is prohibited.  This policy does not apply if the financial interest in the supplier is not substantial.  

B.  Purchases from all other non-federal University funds

For purchases using non-federal University funds, including but not limited to, gifts, endowment, and non-federal sponsored funds, no Yale employee, officer or agent who has a Purchasing Conflict of Interest (as defined in the Definitions above) may be involved in the selection, award, or administration of a purchasing transaction (e.g., Purchase Orders, Purchasing Agreements, Purchasing Contracts, PCard Transactions or others) without the approval of the relevant chair, department head, or dean, and the approval of the Chief Procurement Officer or the Director of Purchasing Services.  Any such approval must be obtained prior to placing the order or entering into any contractual arrangement with the proposed supplier.

Confidentiality

When discussions arise between suppliers and University departments, University personnel involved in the procurement process may only discuss the specifics of applicable policies and standard procedures as they impact specific orders.

To protect a supplier’s right to confidentiality and the University’s interests, competing suppliers must not be told the prices, terms, or conditions quoted by other suppliers.  All University personnel must respect confidentiality in all procurement activities.

Gifts and Business Meals

University personnel and members of their immediate family may not accept personal gifts or entertainment from any supplier by any means, directly or indirectly, at any time of the year.  This includes, but is not limited to, items of value, quasi-social invitations, credits for supplier promotions, etc.

A business meal may not be paid for by a supplier except in the following situations:

  • When individuals authorized to issue purchase orders visit the supplier’s business as part of a review of the supplier’s capability to service the University or to review a new product or new facilities; or
  • When individuals perceive that continuing discussions with a supplier through mealtime has merit, they may continue the meeting at the expense of the supplier or the expense of the authorized employee.  Repetitive mealtime meetings are not appropriate and should be discouraged.

Separation of Duties

Departments must separate the duties of purchasing, receiving, and authorizing payment for goods and services by distributing these duties among two or more people.  If staff limitations require one person to be responsible for these functions, a supervisor must accept responsibility for monitoring and verifying the transactions.

The University uses electronic purchase requisitions and PCards as the preferred and recommended methods for obtaining most goods and services.  Refer to Procedure 3201 PR.01 Purchase Requisition Process and the University Buying Guide website for guidance on the appropriate purchasing methods.

Purchase Requisitions

Electronic purchase requisitions are required for procuring most common goods and services.  See the University Buying Guide  for a list of commodities and the recommended purchasing methods.

Important Note: Purchase Requisitions should not be created after goods or services have been received in full.  These orders carry Yale’s terms and conditions and are not valid unless accepted by the supplier “prior” to providing goods or performing services.  If all goods or services have not been received in full and additional goods or services remain to be received for a specific transaction, it is appropriate to create a Purchase Requisition to cover the remaining goods or services.  In these situations, it is the responsibility of the lead administrator to remind transaction requesters of their responsibility to create a Purchase Requisition before goods or services are delivered.

Yale Purchasing Card (PCard)

Individuals authorized to use a Yale Purchasing Card (PCard) may use the card to pay for travel and entertainment expenses in accordance with their transaction limit and authorization level.  In limited exceptions, individuals authorized to use a PCard may use the card to pay for miscellaneous small dollar business-related goods and services (<$2000).

All PCard transactions must be processed and approved in a timely manner using Yale’s expense management solution. Refer to procedure 3215 PR.01 Yale Purchasing Card for more details.

Contact Supplier Directly (Non-PO Invoices)

Non-PO invoices should not be used when suppliers are available in Yale’s electronic requisitioning system.  Non-PO requests for payments may:

  • cause the service to be suspended;
  • cause a delay in payment to the supplier; and/or
  • require review and approval by the lead administrator.

Personal (Out-of-Pocket) Funds

In very limited circumstances, small dollar purchases may be made using personal funds.  Reimbursement for purchases of this type should be done via Yale’s expense management system.

The University requires and encourages competition among suppliers in providing goods and services to the University.  Competition assures a mix of quality, service, and price that matches the stated needs of the University.  Accordingly, those involved in supplier selection have the responsibility to search broadly and completely for viable suppliers.  Purchasing Services is available to assist in the supplier selection process.

Competitive Bidding Requirements

Purchases from Non-Contract suppliers, where the dollar value of the purchase is between the University’s competitive bidding threshold of $10,000 and the Federal Government Micro-Purchase Simple Acquisition Threshold of $150,000, must fulfil the following guidelines:

  • Provide 3 Written Quotes
    • Quotes documentation must be in writing and from a supplier price list, supplier website, or provided by the suppliers, or
  • Perform Competitive Bidding
    • Bids documents must be from the supplier, in writing, and be responsive to an RFP or RFQ solicitation, or
  • Justify No-Bidding via Sole Source Justification
    • Use Form 3205 FR.03 Explanation for Sole Source Supplier

Purchasing Services must perform the bidding process (or validate the department’s sole source justification) for all purchases with Non-Contract suppliers greater than the Simple Acquisition Threshold of $150,000. 

Important Notes: 

  • Competitive bidding has been performed by Purchasing Services for purchases from Contract suppliers (listed in the Buying Guide).  Departments do not have to perform bidding for purchases with these suppliers.
  • Departments may request assistance from Purchasing Services with any transaction, regardless of dollar amount.
  • Simplified acquisition threshold means the dollar amount below which a non-Federal entity may purchase property or services using small purchase methods.  Non-Federal entities adopt small purchase procedures in order to expedite the purchase of items costing less than the simplified acquisition threshold.  The simplified acquisition threshold is set by the Federal Acquisition Regulation at 48 CFR Subpart 2.1 (Definitions) and in accordance with 41 U.S.C. 1908.  As of the publication of this Part, the simplified acquisition threshold is $150,000, but this threshold is periodically adjusted for inflation.

Unless assistance is requested, all requisitions that require competitive bidding that are submitted to Purchasing Services that do not have the above-mentioned documentation will be returned to the department for completion.  This documentation, sole source, or bidding documents, is also required if the department is adding more than $10,000 to an existing order.  Once all documentation has been attached, the department may resubmit to Purchasing Services for review.

Diversity Suppliers

Every effort must be made to utilize diversity suppliers.  These are suppliers who can certify they meet the standards for small, disadvantaged, minority, and/or women-owned suppliers set by the federal Small Business Administration.

Sustainable Procurement

Please refer to the Yale Sustainability website for the latest guidance on the University’s efforts to monitor and reduce the University’s environmental impact.  This site identifies products with reduced environmental impacts.  Please review the guidance provided before making purchasing decisions and supplier selections and consider the Sustainable Procurement Standards guidelines for buying sustainable products or services.

Internal Service Providers

Yale’s internal service providers (ISPs) furnish a substantial number of goods and services to the University.  ISPs may be selected to provide goods or services in keeping with the University’s supplier selection criteria and competitive bidding process, as required.  In addition, ISPs must be selected in cases where University labor contract obligations preclude the use of other suppliers.

Restricted Suppliers

Federal guidelines (FAR 9.405-2 and FAR 52.209-6) prohibit subcontracting of federal funds more than $30,000 to an organization or individual who is debarred, suspended, or proposed for debarment unless there is a compelling reason to do so. 

Bidding Process

Federal regulations require that awards be made to the bidder or offeror whose bid or offer is responsive to the solicitation and is most advantageous to the recipient.  Price, quality and other factors are considered.  Therefore, at least three written bids or quotes are required for purchases of goods and services from suppliers in excess of the University’s competitive bidding threshold.  Bids and quotes submitted to the University must be held in strictest confidence and under no circumstances should suppliers be given information about bids or quotes from competing sources.

Documentation

All bids and or quotes received must be attached to the purchase requisition as an essential part of the purchasing transaction record.  For contract suppliers, this documentation is maintained by Purchasing Services.  For more details on Competitive Bidding, refer to procedure 3201 PR.02 Competitive Bidding Process.  Additionally, the purchase transaction documentation must identify any conflicts of interest between any University employee involved in the procurement process and the supplier in accordance with section 3201.2 Ethical Practices of this policy.

Departmental Authorizations

Department Administrators (or their designees) and/or PCard holders may purchase items and services directly from a supplier or using purchase requisitions up to the dollar limit specified in the Controller’s Office Fact Sheet, except for those goods and services listed in Table 1 below or restricted under Policy 3220 Purchase of Restricted Items.

Table 1: Restricted Purchasing Authorities

Certified Purchasing Delegations

Good or Service

Sole Authorized Purchasers:

Alcohol for research (purchased under license, held by stockroom manager, and released per Department request)

Traffic, Receiving, and Stores

Animals and animal cages for YARC (refer to Policy 3220 Purchase of Restricted Items)

Yale Animal Resources Center (YARC)

Architectural and engineering services

Office of Facilities

Construction and contractors

Office of Facilities

Equipment Maintenance

Purchasing Services

Furniture, carpeting, and window coverings

Purchasing Services

Telecommunications services and equipment

Purchasing Services

Boats

Purchasing Services

Biological hoods

Purchasing Services

Leased or rented equipment

Purchasing Services

Financed agreements

Purchasing Services

Fuel (oil and natural gas)

Purchasing Services

Hazardous materials, Chemicals and radioisotopes

Purchasing Services

Office of Environmental Health and Safety

Pharmaceuticals and controlled substances

Purchasing Services

The departments listed in Table 2 below are authorized to create departmental orders for the specific goods and services delegated to them as follows:

Table 2: Purchasing Authority Delegations

Purchases Not Covered

Department & Contact Information

Investment Management Services

Yale University Investments Office

203-432-0120

Legal Services

Office of General Counsel

Tax Services

Tax Compliance and Planning

Accounting Services

General Accounting & Accounting Services 

Auditing Services

Auditing 

Architectural

Facilities 

Engineering & Construction Services

Facilities 

Insurance

Risk Management

Employee Travel Costs

Yale Travel Management

Employee Benefits Program

Benefits

Real Estate

University Properties

Intellectual Property Rights

Office of Cooperative Research

Subcontracting Services

Office of Sponsored Projects

203-785-4689; Fax 203-785-4159

Purchase Requisitions

Purchase Requisitions with an aggregate value greater than $100,000 must be approved by the lead administrator.

Purchase Requisitions with a value greater than $10,000 or for Professional Services and Contracting Agreements (PSCA) charged to Sponsored Projects must be approved by Office of Sponsored Projects if:

  • The PSCA exceeds $10,000 (including all amendments);
  • The Consultant is identified as being responsible for the design, conduct or reporting of the research (regardless of the dollar threshold of the PSCA); or
  • The scope of work covered by the PSCA involves human or animal subject research (regardless of the dollar threshold of the PSCA).

Purchase Requisitions for restricted items must be approved by the office of Environmental Health and Safety.

Purchase Orders

Purchase orders with an aggregate value between $10,000 and $1,000,000 must be approved by the Director of Purchasing Services or his/her designee.  All purchase orders with a value greater than $1,000,000 must be approved by the Chief Procurement Officer or his/her designee.  Purchase Orders with a value greater than $5,000,000 must be approved by the Vice President for Finance and Chief Financial Officer, or his/her designee.

Deposits and Prepayments

All deposits, down payments and prepayments equal to or greater than $25,000 must be approved by the Director of Purchasing Services.

Departments are responsible for verifying the actual receipt of goods and services.  Receipt of goods acknowledgement confirms that purchased goods and services have been received in the manner and quantity ordered.  The department lead administrator or his/her designee is responsible for receipt verification and acknowledgement where required before payment is authorized.

Receipt of Goods

< $5,000

=/> $5,000

Documentation:
How approver should record/document that goods have been received

Not required

Packing slip, e-mail, written record of direct knowledge/observation

Confirmation:
How approver should satisfy him/herself that goods have been received

Assumed with payment approval

Packing slip, verbal confirmation, e-mail, direct knowledge/observation

Acknowledgement:
How approver should tell Shared Services (AP) that goods have been received

No acknowledgement required

Invoice approval

Submission and approval of an Expense Report

In general, the local business process for confirmation of receipt of goods may include a review of documents that confirm receipt of goods (e.g. the packing slip or other documents confirming that the goods or services have been received), physical inspection of goods or verbal confirmation for services and in the absence of other documents.  Packing slips and other receipt confirmation documents do not need to be forwarded to Accounts Payable or retained in department files.

Yale University qualifies for sales tax exemptions in many states on purchases of goods or services, including meals and lodging.  For guidance on the available exemptions, buyers (or any other University employees involved in the purchasing process) should refer to the University Tax Department website.

Note: To obtain an exemption, the University must make the payment directly to the supplier using a PCard or check.  The sales tax exemption will not apply if a traveler makes the payment using a personal credit card.  See the University Tax Department website for guidance on sales tax.  If a personal credit card is used for travel and small expenses, the University will reimburse for sales tax paid.

Only Yale officers or employees who have been assigned or delegated signature authority by the Yale Corporation can sign contracts, agreements, or other official documents to purchase goods or services on behalf of the University.

Please refer to Policy 1104 Signature Authority, Delegation Approval Authority and Access for Financial Transactions.  Please also refer to the online Signature Authority Tool.

Violation of Policy

This University policy is intended to maximize the University’s buying power, streamline business practices and reduce potential institutional risks associated with contracting and other procurement related activities.  Violation to University policies may carry disciplinary consequences, up to and including dismissal.

If a Yale University employee believes that his/her actions have, or may have, violated University policy, he/she is advised to disclose the policy violation to his/her supervisor at the earliest possible opportunity.  The supervisor is then further advised to consult with one of the Purchasing Policy Oversight Offices, listed below, to review and address the issue.

If a Yale University employee suspects that a violation of policy has been committed by another employee or a Yale University supplier, he/she is advised to promptly and confidentially report the concern to one of the Purchasing Policy Oversight Offices listed below.  The suspecting employee is advised NOT to confront the individual concerned directly.  By following this process, confidentiality will be maintained and the matter will be investigated promptly and appropriately.

Purchasing Policy Oversight Offices:  Office of the Chief Procurement Officer; Controller’s Office.

Special Situations/Exceptions

Exceptions to this policy must be approved by the Controller’s Office, in consultation with the Provost’s Office, General Counsel, or an Officer of the Corporation, as appropriate.

Roles and Responsibilities

Approver
Approves the purchase of goods or services.  Through the approval process, the approver acknowledges that the goods or services are in accordance with University policies and procedures and are charged to the appropriate account.  The approver also verifies, through inquiries or direct knowledge, that the goods were received or the services were performed.

Buyer
Performs supplier analyses, obtains bids and quotes, and approves purchase orders based on internal approval limits.

Chief Procurement Officer
Oversees all activities across Purchasing Services, and Electronic Commerce.  Approves purchase orders and professional service and other agreements.

Lead Administrators or Operations Managers
May initiate, approve, and delegate purchasing transactions, on behalf of their department, for the dollar limits defined in the Controller’s Office Fact Sheet.  Assures that receipt verification and acknowledgement occurs and is documented within his/her department.

Office of Sponsored Projects
Provides guidance and approvals regarding purchases related to sponsored awards.

Requester
Documents the need for goods or services and determines that the costs are reasonable and allowable.

Office of Risk Management
Provides guidance regarding insurance requirements for suppliers.

Initiator
Prepares or places orders for goods and services based on direction from the requester.

Principal Investigator
Initiates, and delegates purchasing transactions related to sponsored project awards.

Purchasing Services Director
Oversees daily operations within Purchasing Services.  Approves purchase orders and requisitions for the dollar limits defined in the Controller’s Office Fact Sheet.

Purchasing Services Office
Provides purchasing expertise and support to the Yale community, including negotiating strategic and other contracts on behalf of the University, reviewing required documentation, and issuing authorized purchasing orders.

Supplier Compliance Unit
Establishes and maintains the supplier database.

Yale’s E-Procurement Solution
The Workday Create Requisition function replaces SciQuest as Yale’s e-procurement solution as of July 1, 2017.  SciQuest catalogs and contract pricing are available via the Connect to Supplier Website option.

Yale’s Expense Management System
Yale’s expense management solution includes the processing, creation, and submission of expense reports for the following expenditures: travel and business related expenses and miscellaneous small dollar purchases incurred on a University PCard or with personal funds (cash out-of-pocket (OOP)).  The expense management solution supports requesting and clearing of cash advances for travel and expenses as well as study subject advances.