Purchasing Policy for Sponsored Research

Purpose

This policy ensures the prudent expenditure of funds and requires all employees who authorize such expenditures to exercise good judgment regardless of the source of funds.

Scope

This policy applies to the University of Dayton’s college, schools, departments, and Research Institute conducting sponsored research.

Policy History

I. Effective Date:  September 1984

II. Approval:  October 4, 2024

III. History: 

• Approved in its original form: September 1984 (Title:  Purchasing Policies and Procedures)
• Approved as amended:  July 2012
• Approved as amended:  January 8, 2015
• Approved as amended:  October 4, 2024

IV. Maintenance of Policy: Director, RI Procurement and Property Management, University of Dayton Research Institute

Policy

The University considers the prudent expenditure of funds to be an important responsibility and requires all employees having such authority to exercise good judgment in authorizing such expenditures, regardless of the source of the funds.  Expenditures under this policy will be in compliance with all applicable regulations, including the Anti-Kickback Act of 1986 (Title 41 U.S. Code 8701-8707), Federal Acquisition Regulations (FAR) 52.2198-8 Utilization of Small Business Concerns (SEP 2023), FAR 31.104 and 31.3 Contracts with Educational Institutions and 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.   Expenditures will also be in compliance with the requirements of ISO 9001:2015 related to the purchasing function.

The Anti-Kickback Act of 1986 prohibits any person from providing or accepting kickbacks or including the amount of the kickback in the contract price.  A kickback is money or anything of value which is provided for the purpose of improperly obtaining or rewarding favorable treatment in connection with a contract or subcontract. The Act imposes criminal penalties on any person who knowingly and willfully engages in prohibited conduct. The Act also provides for the recovery of civil penalties by the United States Government from any person who knowingly engages in such prohibited conduct and from any person whose employee, subcontractor, or subcontractor employee provides, accepts, or charges a kickback. Any such violation should be promptly reported to the University's cognizant administrative contracts office, Office of Naval Research-Chicago Region, at usn.pentagon.cnr-arlington-va.mbx.onr-chicago@us.navy.mil.

It is the policy of the University of Dayton to provide all Small Business concerns – Small (SS), Small-Disadvantaged (SD), Women-Owned Small (SW), Veteran- Owned Small (VO), Service Disabled Veteran-Owned Small (DV), and HUBZone (HUBZONE) certified – the maximum practicable opportunity to participate in the performance of contracts which have been awarded by any federal agency.

RESPONSIBILITY FOR ENFORCEMENT, REMEDIES, SANCTIONS

The Research Institute Purchasing Office implements and performs the purchasing function for all accounts administered by the Research Institute.  The Director, RI Procurement and Property Management is responsible for reviewing and approving changes to the policies and procedures document.

Reference Documents

1. UDRI Purchasing Procedures  (Login Required)
2. ISO 9001:2015 Quality Manual    (Login Required)
3. Policy Prohibiting Illegal, Fraudulent, Dishonest, and Unethical Conduct

Applicable Federal Regulations

1. Anti-Kickback Act of 1986 (Title 41 U.S. Code 8701-8707)
2. FAR 52.219-8 Utilization of Small Business Concerns
3. FAR 31.104 and 31.3 Contracts with Educational Institutions
4. 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards