Procurement Suspension and Debarrment

This policy responds to all applicable government procurement regulations as contained in the Federal Acquisition Register (FAR); Office of Management and Budget’s uniform administrative requirements as codified under the Code of Federal Regulations (C.F.R.) at 2 C.F.R. Part 200 (Uniform Guidance), as well as any additional regulations or procedural formalities required by the contracting agency, as specified in the Notice of Award

Reason for the Policy

To maintain strong business practices and ensure compliance with various regulations that the University is obligated to remain consistent with through its procurement practices. This policy promotes access to suppliers for the purpose of supporting the mission of the University

Primary Guidance to Which This Policy Responds

This policy responds to all applicable government procurement regulations as contained in the Federal Acquisition Register (FAR); Office of Management and Budget’s uniform administrative requirements as codified under the Code of Federal Regulations (C.F.R.) at 2 C.F.R. Part 200 (Uniform Guidance), as well as any additional regulations or procedural formalities required by the contracting agency, as specified in the Notice of Award

Responsible University Office & Officer

Responsible University Office: Purchasing

Responsible University Officer: Vice President for Procurement Services

Who Is Governed By This Policy

Faculty and Staff authorized to purchase and/or pay for goods and services for their department or school using government, grant or University funds.

Who Should Know This Policy

All persons governed by this Policy such as Department Administrators and other department staff.

Columbia requires that faculty, staff, researchers, students, or other individuals who plan for or purchase products, equipment, supplies, and services with University funds, base purchases on sound business practice, best value, accountability, and compliance with donor, sponsor and regulatory requirements. Individuals planning for or making purchases must follow this and other established Columbia policies and procedures.

Columbia is required to make payments only to suppliers who are in good standing with the federal government. As a result of this requirement, the University cannot procure or pay any supplier who is debarred from doing business with the Federal Government. The federal government classifies these suppliers as "debarred or excluded". This same requirement also prevents the University from reimbursing any individual for goods or services obtained from a debarred or excluded supplier.

This applies to all procurement and disbursement transactions including, but not limited to, payments to external consultants, independent contractors for professional services, entertainers and performers, one-time lecture fees and construction and renovation.

All suppliers listed in ARC have been pre-screened using Visual Compliance and are not in the federal "debarred and excluded" listings. Therefore, using one of these suppliers requires no additional work on the part of schools and departments.

If Vendor Management receives a supplier setup request for a "debarred or excluded" supplier the departmental contact will be notified.

Any suppliers of record that are flagged by Visual Compliance will be reviewed by Vendor Management to determine if the supplier qualifies as debarred or suspended. If they are identified as such, the supplier will be placed on hold pending further review and no payments will be disbursed.