Effective December 26th, 2014, OMB Circulars A-21, A-110 and A-133 will be replaced by regulations under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (also known as the Uniform Guidance). Please refer to the University’s Uniform Guidance website http://spa.columbia.edu/uniform-guidance for further details that may supersede information outlined in this policy. Please be advised that Procurement regulations under Uniform Guidance will become effective July 1, 2016 and should revised policies be required, they will be posted once available.
Any individual at the University making a purchase under a Federal government contract (as opposed to a grant or cooperative agreement) must comply with the Federal Acquisition Regulation ("FAR"). Numerous FAR contract clauses and FAR certifications may be required for such a purchase. For this reason, the applicable FAR provisions are referenced on Columbia's Purchase Order forms and in its standard contracts. A current version of these provisions as of the date of publication of these Guidelines is provided in Appendix 2, Special Terms and Conditions, Federal Acquisition Regulations.
Any individual at the University making a purchase with funds from a Federal grant or cooperative agreement must comply with the sponsoring agency's regulations that implement OMB Circular A-110. (Individual Federal sponsoring agencies are required to incorporate the provisions of OMB Circular A-110 into their own agency regulations.) OMB Circular A-110 contains the uniform administrative requirements for institutions of higher education, hospitals, and other non-profit organizations with Federally-funded grants or cooperative agreements., OMB Circular A-110 at § __.40-__.48, sets forth the specific procurement standards the University must follow when purchasing supplies and other expendable property, equipment, real property, and services with Federal funds. Appendix A to OMB Circular A-110 contains mandatory procurement provisions—also known as flow down clauses—for contracts, including small purchases that do not meet the simplified acquisition threshold, awarded by recipients of Federal grants and cooperative agreements. A current version of this document as of the date of publication of these guidelines is provided in Appendix 1. Moreover, OMB Circular A-110 § __.48 requires the University to include additional provisions in contracts when certain circumstances are met. These provisions, which also must be applied to subcontracts, are listed below.
The above bulleted section applies solely when a direct expenditure of Federal funds is involved.
All negotiated contracts—except those for less than the simplified acquisition threshold, which is currently $100,000 under 41 U.S.C. § 403 (11)—awarded by recipients shall include a provision to the effect that the recipient, the Federal awarding agency, the Comptroller General of the United States, or any of their duly authorized representatives, shall have access to any books, documents, papers and records of the contractor which are directly pertinent to a specific program for the purpose of making audits, examinations, excerpts and transcriptions.