TL;dr – Aggregating costs over the whole project period is overly cautious, administratively burdensome, and doesn’t make much sense other than from a risk avoidance perspective. A one-year threshold makes far more sense, but any policy should also be cognizant of the fact that different circumstances require different procedures.

This is one of those areas in research administration where I think a policy needs to have distinct categories or else at least a bit of justifiable wiggle room. A chemist or biologist, particularly in the startup phase of a lab or a project, can blow through $5,000 of materials and supplies in under a week without breaking a sweat, where a historian, a linguist, or a social scientist might not even need that much in materials and supplies for a full three-year project. That’s purely a factor of what is needed to carry out research work in those disciplines, and the costs of the things they need to do the research.

It might even all go to a single vendor in the sciences, because of the common practice of negotiating open order arrangements between institutions (or departments within an institution) with the bigger scientific supply houses like Fisher or Sigma-Aldrich. Those agreements allow orders to be placed and fulfilled quickly and with a minimum of fuss or bother on all sides, and often provide the best available prices for the items needed, which is encouraged under 2 CFR §200.318(d)-(e). But in many cases, those vendors are also likely to be the only, or one of only a very few, sources for the materials in question, so a bid process would not even be possible or else would be far more time-consuming and burdensome than the value it might provide, since any smaller vendor would be unlikely to be able to meet the pricing or the speed of service that the bigger places can provide. I could see restricting such purchases (or at least providing for increased oversight around them) in the final six months or so of an award period, where the concern would be that the investigator was merely stocking up to spend down remaining funds, rather than buying materials that really were needed for that particular project. But if they are continuing to do work right up to the end of the project period, those purchases would be entirely justifiable.

In other cases, I would argue that the maximum time over which to cumulate orders for triggering the purchase or micropurchase threshold should be not more than one year (calendar or fiscal). That strikes me as a reasonable time horizon to consider for most projects, given that the need for materials and supplies is often greater at the beginning of a project and again at the beginning of each subsequent project or fiscal year, and may fluctuate over time before declining as the project winds down. Further, in many instances it would be difficult to determine the precise point at which the purchase threshold was likely to be exceeded, making it difficult to plan for an appropriate procurement process

Michael Spires, M.A., M.S., CRA
Research Development Officer, Sciences

The Research Office

Oakland University

256 Hannah Hall

244 Meadow Brook Road

Rochester, MI 48309-4451

(248) 370-2207

xxxxxx@oakland.edu

Past President, National Organization of Research Development Professionals

I will be on vacation December 18-21.

Oakland University will be closed for the winter holiday December 22-January 1.

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Kris Wolff
Sent: Thursday, December 06, 2018 11:32
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] UG procurement standards and timing of purchases

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