2.2.1. Purchasing Property
Title and Authorization: Capital (permanent) equipment is purchased by the university online through CU Marketplace. When purchased by Sponsored Projects, OCG reviews Marketplace requisitions having a value equal to or greater than $5K to confirm where title will vest and ensure that authorization to purchase the property has been obtained.
Marketplace Approval Process: Purchasing with sponsored project funds requires three sequential approvals after the PI and the department initiates a requisition: (1) Financial (department), (2) Sponsored Projects (OCG/CCO), and (3) Purchasing (PSC). Some capital equipment may, and Government titled property purchases do require specific sponsor pre-approval before any requisitions can be processed. LASP and CIRES are permitted to submit requests directly to the sponsor for prior approval; all other departments OCG submits prior approval request to the sponsor.
At the time of request, the PI justifies why the equipment is necessary. If federally funded the PI certifies that either the CU Boulder Surplus site and/or the Core Facilities and Shared Instrumentation were checked to ensure that no other compatible equipment is available on campus for use on the project. Once a requisition has received all approvals, a purchase order is created by PSC and submitted to the vendor.
Federal regulations require that any purchases direct charged to a sponsored project must directly benefit that project in proportion to the amount charged. Equipment and non-capital property purchases being made within the last 90-120 days before the project end date are generally unallowable because they do not support the project during its period of performance.
- PI and Department Initiate Requisition: Based on project need and the scope of work, a department submits a requisition through CU Marketplace to purchase property. The requisition must include accurate information and all necessary substantiating documents, including sponsor pre-approval. Incorrect or incomplete requisitions delay the approval process.
- Financial Approver: The department is responsible for the financial review and approval of a requisition with a value >$10K. During the review, the financial approver should ensure that there is sufficient funding available for the purchase, that the purchase is occurring appropriately within the project period of performance, and that the requisition is complete, accurate, justified and includes all supporting documentation.
- Central Office Approval: Requisitions with charges to either a Fund 30 or 31 are reviewed by either OCG or CCO when the total cost of the requisition is at least l$10,000. Whether the requisition is routed to OCG or CCO for Sponsored Projects review depends on the account codes used. OCG Compliance reviews requisitions that use account codes 500800, 500900, 501000, 501100, 501200, 501400, 501600, 502000, 537600, 537601, 537602, 700300, 702200, 810100, 810200, 810300, 810700, 810800, and 810900 to determine if the award terms and federal regulations are met. In particular, the approver examines the terms of the award, the project period of performance, the Needs Statement to confirm the requisition meets all of the required approval standards, and certification that CU inventory was checked for possible availability. The approver also determines where title vests for the item(s) being purchased.
- PSC Approver: The purchasing review is completed by PSC when they create a purchase order for the requisition and initiate the purchase from the vendor.
Marketplace Tools and Attachments: Requisitions in CU Marketplace are part of the property award records and there are a number of tools available in the system that help archive the needs and justifications for property purchases required by federal regulations.
Comments Tab: This tab in the purchase requisition may provide additional information required for approval. For example, when creating a requisition for an equipment upgrade, the tag number of the original equipment and a brief explanation of the upgrade should be referenced in the Comments section.
Internal Notes and Attachments: To expedite approval, all supporting documentation and additional information should be attached to the requisition. It is best practice to provide:
- Sponsor Documents: When sponsor pre-approval is required for the purchase, the approval is attached directly to the purchase requisition by the department or OCG depending on who obtained the approval.
- Vendor Quote: A quote for the requisitioned item(s) from a non-preferred PSC vendor is required.
- Needs Statement: If not included in the Sole Source Justification, a needs statement for the equipment should detail the anticipated use of each item on the project and justify its research purpose.
- Relevant correspondence: Any correspondence with either the vendor or the sponsor that explains what is being purchased, its research purpose, and/or sponsor authorization to proceed.
Sole Source Justification (SSJ): In most cases, PSC requires the SSJ form for purchases greater than $10,000 be attached to the requisition. Other information can be incorporated into the SSJ such as the needs statement and/or a statement certifying sites have been checked for available equipment.
NOTE: Approval of a purchase requisition that allocates the cost to multiple SpeedTypes may require additional review if the terms and conditions of one or more SpeedTypes require sponsor prior approval of equipment purchases.
Receipt of Purchased Property: When property is physically delivered to the department, the department property manager, or other designated person, thoroughly inspects the delivery to ensure the total order is received and there is no damage or shortages in the delivered items. Any shortages, overages, damages, or inadequacies are noted in their equipment records and PSC is notified within a reasonable amount of time.
University titled equipment: When the purchase has booked to the project financials, PAO enters information into the property management records (PSAM) and prints a CU tag for the property. The department must affix the property tags within 30 days of receipt of the printed tag from PAO; exceptions to this may only be coordinated with PAO.
Government titled equipment: The department must notify OCG immediately when the purchased equipment is received. OCG works with PAO to enter information into the property management record and print a 0F tag. OCG coordinates with the department property manager to affix the tag, and verify campus location, property serial numbers, property condition, and any manufacturer maintenance requirements within three business days. OCG also notifies PAO of receipt so CU campus official records for government titled equipment are correct and complete.
*Please see 3.2 Tagging and Record of Property or the ISOP: Tracking Government Property for more details.