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. 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