I. PURPOSE To explain the procedures and policies to be followed in the procurement of all goods and services – particularly acquisitions under $19,400. This policy applies to all schools, colleges, divisions, departments, programs, funds and cost centers unless otherwise noted.II. GENERAL (summary)
A. Purchases under $19,400
• Purchases under $19,400 shall not require competitive bidding.
• Prudent business practices must be followed regarding all purchases under $19,400.
• University Legal Counsel must review all contracts that exceed $5,000.
B. Purchases over $19,400
• Purchases over $19,400 must be bid competitively under established business practices.
It is the personal responsibility of each department manager to control all transactions against their assigned budget accounts to ensure that they conform to policies of the Commonwealth, the Pennsylvania State System of Higher Education, and the University. This responsibility includes, but is not limited to, all requests for purchases (of goods or services) and all requests for payments (disbursements of any kind, regardless of funding source). Authority to sign purchase requests or payment requests (in any form or format) may be delegated to a limited number of employees. Such delegations must be reported in writing to the Assistant Vice President of Finance, Budget, and Business Services or designee. This delegation and/or authority may be revoked for violations of the policies contained or referenced herein, and appropriate disciplinary action taken for any fraudulent or misappropriated use of tax dollars or University funds. The University has established the following business practices for compliance with this policy and Commonwealth regulations:
The University President has the power and duty under Act 1982-188, Section 2010-A, Subsection (10) to "...negotiate and award all contracts for equipment, services and supplies...." in accordance with the above stated limitations. The University President has been designated as "Fiscal Officer and Contracting Officer", and has further delegated power and authority to those individuals identified on the attached delegation documents. The University President has approved the following procedures.
Procurements in amounts of $1,000 or less will be handled by the University’s Purchasing Card whenever possible and appropriate, as defined under separate policy document for that program. Procurements in amounts up to $5,000, solicitation of quotations/bids is encouraged. Depending on the circumstances, discretion may be exercised by either the Purchasing Office or Construction Procurement Office with regard to the need for quotations/bids. Managers for those respective offices are accountable for exercising professional due diligence by soliciting written, fax, electronic or telephonic quotations (i.e. documentation) when appropriate. Procurements for amounts more than $5,000 but less than $19,400 require that either of the Purchasing Office or Construction Procurement Office must obtain, or receive from requesting Departments a minimum of two (2) telephone quotations (or comparable method of receiving price quotation, e.g. in writing, fax, e-mail, etc.) before purchase authorization may be granted by either of those procurement offices. All procurements under $19,400 must be authorized in advance by either the Purchasing Office, Construction Procurement Office, or by way of issuance of a Purchasing Card up to the level of spending authorization specifically authorized for each individual card holder. Procurement for amounts over $19,400 require competitive sealed bids/proposals to be solicited by either the Purchasing Office or Construction Procurement Office, with appropriate public notice (advertising). Decentralized solicitation of bids for this level is prohibited. Adherence to the following policies and conditions apply to all purchases, regardless of dollar amount:
Act 57 of 1998, known as the Commonwealth Procurement Code
Board of Governors Policies:
1998-04, Procurement of Goods, Services, Supplies, and Construction 1998-04-A, Delegation of Authority for Undertaking Design, Construction, Repair, Renovation, and Maintenance Projects
1990-07-A, Professional Services Contracting
(above policies on file in the Purchasing and Contract Services Office)
*(WCU) Use of Public Funds Policies
*Contracting at WCU Policy
*WCU Purchasing Guidelines
*WCU Promotional Items and Gifts Policy
*Adverse Interests Act (on file in Business Services Office)
*State Ethics Guidelines (http://www.ethics.state.pa.us/)
*Prohibited Purchases List (see WCU Purchasing Guidelines)
*WCU Purchasing Card Policy
These detailed, written policies are available upon request and can also be accessed at the West Chester University Finance and Business Services web page.
Waivers or Exceptions: Only the "Contracting Officers" designated herein may waive (up to the limit of their delegated authority) bid requirements, public notice requirements, bond requirements, insurance requirements, or additional approval requirements. All such waivers must be justified in written documentation that shall be subject to annual audit requirements.
Emergencies: Only the President or Vice President for Administration and Finance may authorize "emergency" procurements. All "emergencies" must be justified in written documentation that shall be subject to annual audit requirements.
Additional Internal Approvals: All purchases that normally require additional approvals (aka "technical standards approval" under the Purchasing Guidelines) shall continue requiring such approvals, regardless of dollar value. Examples include, but are not limited to:
Item or Service Additional Approval by: Computer Hardware / Software Information Services Hazardous Materials or Related Services Enviornmental Health & Safety Office Publication - Use of Logo, Seals, etc. Publications Office Grants and Sponsored REsearch Restricted Funds Office
Additional External Approvals: Only the President or Vice President for Administration and Finance may seek advance approval or exemptions from approval from those external approving authorities that may be required for any procurement or disbursement transaction.
Employees are reminded that, under these provisions, it is their responsibility to:
Ensure purchase costs are reasonable. Employees must take whatever action is necessary to ensure the reasonableness of costs, including - as a minimum - the comparison of pricing from more than one vendor. Obtain purchase order authorization from either the Purchasing Office or Contract Services Office before committing the University to a purchase. Adhere to the Principles of Public Notice, including responsiveness (satisfying the objectives and policies of the University while promoting community understanding of purchasing procedures and requirements), accountability, fairness and openness to all firms or individuals seeking economic business opportunities with the University. Protect public funds as if they were your own. All purchases are subject to public scrutiny and audits by authorities. Maintain records for audits and be responsive to University assigned transaction monitors and auditors. Report inappropriate sales or purchase activities immediately to the appropriate University officials. Adhere to General Ethical Standards, which include:
• No attempt to realize personal gain
• Cannot require use of a particular surety company, agency or broker
• Avoid conflict of interest (or appearance of same)
• No improper use of confidential information
•(Please note: Any breach of standards requires mandatory reporting to the State Ethics Commission and Attorney General)
Please contact Marianne Peffall, Director of Business
Services (x2705) if there are any questions regarding this policy
and required practices.
For more detailed information about the procurement policy, please go to the full Purchasing Policy.
References: Amendments to Act 188 and changes to Policy 1983-02 regarding Purchasing adopted by the Board of Governors for the State System of Higher Education