Re: debarment checks Kristy Ford 27 Jul 2007 12:05 EST

I would think that in a small school that does not have its own purchasing department, OSP would need to be responsible for checking vendors.  Since you are ultimately responsible for managing and tracking the grant funds according to regulation and institution policy, you would want to provide that oversight to protect your OSP and institution.  If you leave it to the faculty or other staff to check the vendors, it becomes extremely difficult for OSP to oversee appropriate use of grant funds.  You could very easily end up learning about a purchase from a debarred vendor after the fact.  At that point, it becomes frustrating for the faculty who needs the materials for his/her project but cannot use it for those purposes.  If a vendor is on the debarred list, anything purchased by your institution from that vendor cannot be used for funded projects.  OSP would then have to help that faculty find a different vendor to purchase from, and the purchasing process has to start all over again.  Plus, since the grant cannot fund the materials/supplies already purchased from the debarred vendor, you go through the trouble of determining who at your institution will eat the cost instead of the grant.  Seems easier to just take on the extra responsibility at the front-end of things.

This is what makes sense to me, anyway.  Hope this helps!
Kristy:)

Kristy Ford
Grant Management Manager
Office of Sponsored Programs/MHUMC
4750 Waters Ave. Suite 212
Savannah, GA  31404
(912)350-6379

>>> Laura Kubec <xxxxxx@KGI.EDU> 7/27/2007 12:46 PM >>>
Ours is a small school without a Purchasing department.  Typically the
faculty member, postdoc, or research assistant makes the purchases of
materials and supplies.

Where do you believe the responsibility lies for checking on the
vendors?

Thanks.

Laura L. Kubec

Director of Sponsored Research Services

Keck Graduate Institute

535 Watson Drive

Claremont, CA  91711

909-607-9313

 _____

From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Brady, David
Sent: Friday, July 27, 2007 6:59 AM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] debarment checks

Mike,

There is an export control software from E-Customs called Visual
Compliance that has the capability to screen indivuduals and
companies/entities against the debarred parties list. It has both
phonetic and  fuzzy logic search options so that it can screen for "near
misses" or close approximations to the name actually on the debarred
parties lists. It also can screenagainst 56 other government restricted
party lists, whcih is useful for OSP to assess risk of new sponsors,
subcontractors, and consultants. . This software is extremely useful to
manage export control risk at our university.

We initially bought a one seat license (~$2800/yr),  but this past year
in collaboration with UVA and other universities in our state system
purchased a statewide system license (unlimited seats),. I am currently
training OSP contracts and grants administrators on its use for
screening against the debarred parties list, as it is faster than other
methods. Feel free to contact me if you have questions or need futher
information.

David Brady
Director
Office of Export and Secure Research Compliance
2000 Kraft Drive, Suite 2000
Blacksburg, Virginia 24060
540-231-3801
540-231-0959

 _____

From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Warnock, Michael J.
Sent: Friday, July 27, 2007 9:39 AM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] debarment checks

Friends,

I am curious (because we will have an audit finding for this) how
institutions are handling the requirement for debarment/suspension
checks on expenditures of federal funds.  I am not so interested in the
monitoring that all of us are routinely doing for subrecipients.  My
primary interest is for those expenditures for equipment, supplies, etc.
that may not be screened beforehand by the sponsored programs offices.

I know that there are programs that can be purchased to screen an
institution's vendor database.  Is this what everyone is using?  If so,
can you recommend a product?  Are you using something else?

I appreciate any and all advice and counsel.  If you wish to reply
privately, please do so.  After a few days of responses, I can send a
global (i.e., without providing any institutional or individual detail)
summary to the list.

Thanks.

Mike

Michael J. Warnock, Director
Office of Sponsored Program Administration
310 Jesse Hall
University of Missouri
Columbia, MO  65211
voice 573 882-4329
fax 573 884-4078

xxxxxx@missouri.edu

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments
may contain confidential and privileged information for the use of the
designated recipients named above. The designated recipients are
prohibited from disclosing this information to any other party without
authorization and are required to destroy the information after its
stated need has been fulfilled. If you are not the intended recipient,
you are hereby notified that you have received this communication in
error and that any review, disclosure, dissemination, distribution or
copying of its contents is prohibited by federal or state law. If you
have received this communication in error, please notify me immediately
by telephone at (573) 882-9582 and destroy all copies of this
communication and any attachments.

======================================================================
Instructions on how to use the RESADM-L Mailing List, including
subscription information and a web-searchable archive, are available via
our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================

--
This message has been scanned for viruses and
dangerous content by MailScanner <http://www.mailscanner.info/> , and is

believed to be clean.

======================================================================
Instructions on how to use the RESADM-L Mailing List, including
subscription information and a web-searchable archive, are available via
our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================