Federal Grants Purchasing Policies

Notice of Adoption

Mount Holyoke College has adopted the  Uniform Guidance (CFR Title 2: Grants and Agreements PART 200) standard effective 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 on the Electronic Code of Federal Regulations.

Purchasing With Federal Grant Funds

Purchases funded by federal grant funds must adhere to Uniform Guidance which details the administrative requirements for colleges with federally funded grants and agreements. 

The College requires the issue of a purchase order and/or consultation with Purchasing for all transactions $10,000 and above whether grant-related or not.  It is also recommended that three quotes be obtained for orders over $10,000.  See below for Federal Grant Requirements.

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 Uniform Guidance.  All buyers should consider coordinating all such purchases through the Purchasing Department.  Below are the Procurement Sourcing Thresholds outlined in the current Uniform Guidance Requirement:

  • For purchases up to $9,999 the Micro Purchase guideline 200.67 must be followed
  • For purchases 10K to $149,999 the Simplified Acquisition Threshold and Small Purchase Method (3 Quotes) must be followed
  • For purchases over 150K Competitive Proposals are required

In some circumstances a cooperatively bid and awarded contract may meet these requirements

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:   Any equipment purchases that may be affected by Export Control regulations must be reported to the Export Control Task Force for review prior to purchase.  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.

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