The Catholic University of America

Responsibilities of the Associate Vice President, Strategic Sourcing and Business Services

The AVP, Strategic Sourcing and Business Administration, is responsible for compliance with the following regulations:

OMB "Super Circular"

(Formerly from OMB A-110).  The Super Circular requires the following:

Procurement Requirements.

Written procurement procedures including vendor justification and specific documentation provisions

Documentation of cost and price analysis

Maintenance of procurement records for purchases in excess of the $25,000 small purchase threshold

Provision of open and free competition to the extent possible, and positive efforts to utilize small firms and disadvantaged business enterprises.

Debarment Certifications.  Recipients of federal awards shall comply with the non-procurement debarment and suspension common rule, which restricts sub awards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Circular requires obtaining certifications from subcontractors and employees on sponsored projects that they have not been debarred from federal procurements.  See also Executive Order 12549, Debarment and Suspension. 

Underutilized Businesses

As a federal contractor the University must agree to use its best efforts to give women-owned small businesses and historically underutilized business in HUB Zones the maximum practicable opportunity to participate in subcontracts that it awards to the fullest extent consistent with efficient performance of the government contract.  [Note:  While not specifically stated in the Veterans Employment Opportunities Act of 1998 (Public Law 105-339) or in the Veterans Benefit Act of 2003 (Public Law 108-183), veteran and disabled veteran-owned business have been included in overall federal programs for small businesses, and should be included in the University's efforts to use underutilized businesses]. 

Federal Acquisition Regulations (FAR) - Subcontractor Requirements

The FAR regulates procurement integrity (for contracts only) and sets out criteria for subcontracts including but not limited to: 

Technical justification for goods or services

Adequacy of alternate proposal assessment

Price competition and cost analysis

Efforts to utilize small business enterprises

Not using subrecipients who are on the Excluded Parties List System

The foregoing requirements flow down to subcontractors.

Sales Tax (Purchases)

Institutional purchases of tangible personal property or services are exempt from sales tax.  The exemption does not extend to employees, and misuse of can lead to revocation of University's tax exempt certificate.  Payment of otherwise exempt tax that is then charged to a federal grant constitutes an unallowable charge due to the University's tax exempt status. 

Fly America Act  

Federal contractors and grantees flying to, from, between or within a country other than the U.S., where a portion of the expense of the travel will be assisted by federal funding, must use a U.S.-Flag air carrier (a carrier holding a certificate under §401 of the Federal Aviation Act of 1958, 49 USC App 1371) if service provided by such a carrier is available.

Related Policies

Corporate Travel Card Policy

Gifts from Contractors/Vendors Policy

Honoraria Policy

Non-Discrimination, Equal Opportunity and Affirmative Action Policy

Prohibited Transactions

Procurement Card Policy

Procurement Policy

Revenue Recognition Policy

Standardization Policy

Tax Compliance Policy