Federal Grants Purchasing Policies

Notice of Adoption

Mount Holyoke College has adopted the new Uniform Guidance (CFR Title 2: Grants and Agreements PART 200) as of 12/26/14, but chooses to postpone the adoption of the procurement regulations until July 1, 2018 (FY2019). MHC is utilizing the three year grace period to implement the new purchasing standards under the Uniform Guidance.  The College is currently following the regulations in A-110 until implementing the Uniform Guidance regulations at the end of the grace period: July 1, 2018.

 Existing Federal awards are governed by the terms and conditions under which they were awarded.

Grants with start dates on or after December 26, 2014 follow the federal guidelines outlined in 2 CFR Part 200.  Grants which received funding amendments on or after December 26, 2014 also follow these guidelines.  The entire guidance is available here.

Purchasing With Federal Grant Funds

Purchases funded by federal grant funds must adhere to regulations found in OMB Circular A-110 which details the administrative requirements for colleges with federally funded grants and agreements. Section e_40-48 outlines the required purchasing standards.  Purchases made with Federal funds are reviewed for compliance with the Federal Acquisition Regulation and the Office of Management and Budget Circular A-110. 

The College requires the issue of a purchase order for all transactions $10,000 and above whether grant-related or not.  To the extent practicable, a non-federal entity must distribute micro-purchases equitably among qualified suppliers and must comply with the method of procurement to be followed under CFR 2014 Section 200-320-1.  All buyers should consider coordinating all such purchases through the Purchasing Department.

Export Control: Procurement Process

MHC Export Control Policy

The process for the purchase of ITAR (International Traffic in Arms Regulations) instruments used in the Science Center is to contact the Purchasing Department prior to requesting a quotation(s) from a supplier(s).  Purchasing will then guide a buyer through each phase of the process to ensure compliance with Export Control Regulations and documentation retention.  EAR (Export Administration Regulations) provides the rules used to determine whether items and activities are subject to the EAR and the steps in determining the Colleges' obligations under the EAR. In particular, EAR technology (dual use) is export controlled with reference to the 9a515 set of classifications (Summary PDF is for reference guide only).

Conflict of Interest

Mount Holyoke College Conflict of Interest Policy

Office of Sponsored Research link to Federal Agency Conflict of Interest individual policies.

NIH Grants and Funding

Equipment purchase guidelines under NIH Grants and Funding

NASA Grant Regulations

NASA Grants Regulations, Handbooks, Delivery Service Guides

NSF Grants and Funding

NSF Grantee Standards including Procurement Standards