Notice of Adoption
Connecticut College has adopted the new Uniform Guidance procurement regulations but will delay implementation of the Uniform Guidance procurement section as provided by the waiver of procurement rules stated in the Federal Awarding Agency Regulatory Implementation of the Uniform Guidance, Part 200.110, released December 19, 2014. Connecticut College will delay implementation until July 1, 2018 and in the interim will follow the guidance of the old standards (A-110).
Purchasing with Federal Grant Funds
Purchases funded by federal grant funds must adhere to regulations found in OMB Circular A-110, which details the administrative requirements for colleges with federally funded grants and agreements. Section e_40-48 outlines the required purchasing standards. Purchases made with Federal funds are reviewed for compliance with the Federal Acquisition Regulation and the Office of Management and Budget Circular A-110.
The College requires the issue of a purchase order for all transactions $10,000 and above whether grant-related or not. To the extent practicable, a non-federal entity must distribute micro-purchases equitably among qualified suppliers and must comply with the method of procurement to be followed under CFR 2014 Section 200-320-1. All buyers should consider coordinating all such purchases through Procurement Services.
Export Control: Procurement Process
The process for the purchase of ITAR (International Traffic in Arms Regulations) instruments used in the Sciences is to contact Procurement Services prior to requesting a quotation(s) from a supplier(s). Procurement Services will then guide a buyer through each phase of the process to ensure compliance with Export Control Regulations and documentation retention. EAR (Export Administration Regulations) provides the rules used to determine whether items and activities are subject to the EAR and the steps in determining the Colleges' obligations under the EAR. In particular, EAR technology (dual use) is export controlled with reference to the 9a515 set of classifications (Summary PDF is for reference guide only).
Conflict of Interest
Connecticut College Conflict of Interest Policy
National Science Foundation NSF Conflict of Interest Policy
National Institute of Health NIH Conflict of Interest Policy
Access to important Sponsored Research links.
NSF Grants and Funding
NSF Grantee Standards including Procurement Standards
OMB Circulars
Circular A-21 Cost Principles for Educational Institutions
This Attachment provides principles for determining the costs applicable to research and development, training, and other sponsored work performed by colleges and universities under grants, contracts, and other agreements with the Federal Government. These agreements are referred to as sponsored agreements.
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A21/a21_2004.pdf
Circular A-110 Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations
This Circular establishes uniform administrative requirements for Federal grants and agreements awarded to institutions of higher education, hospitals, and other non-profit organizations.
http://www.whitehouse.gov/omb/circulars_a110/