Technically, it is acceptable, if the policy meets all federal requirements
(see A-110).

However it seems a poor business practice.  Your procurement policy should
be "tight" enough to prevent fraud and waste, as part of your
responsibility in operating an honest, open, tax-exempt organization, and
this is the underlying goal of the A-110 requirements.

More typical is a good institutional procurement policy which may have a
FEW special add-ons to cover details in A-110 that differ from what the
basic institutional policy needs.

Feel free to respond off line if you want to discuss matters that might not
be needed in your institutional policy but are required to meet federal
expectations.

Chuck

At 10:32 AM 2/2/2005, you wrote:
>Quick question --
>To satisfy audit requirements, is it acceptable to have a procurement
>policy that applies only to grant funds (or separate procurement policies
>for grant-funded purchases and those made with institutional funds)?
>
>Frances Vinal Farnsworth
>Coordinator of Sponsored Research
>Middlebury College
>Middlebury, VT 05753
>
>Tel:  802-443-5889
>Fax:  802-443-2081
>Email:  xxxxxx@middlebury.edu
>Web:  http://www.middlebury.edu/offices/grants/
>
>
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Herbert "Chuck" Chermside, CRA
Director Emeritus, VCU Sponsored Programs
Executive Director, Research Administrators Certification Council
1915 Robindale Rd.
Richmond, VA 23235-3931
804-320-5502
xxxxxx@verizon.net

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