Transcript Accounts Payable/Purchasing

Accounts Payable/Purchasing
RF Symposium
March 2015
Dave Martin – Campus Financial Services Manager
Megan Moran – AP/Purchasing Supervisor
Ned Gellner – Corporate Payment Compliance Manager
Topics
 RF Foreign Entity process - FATCA
 OMB Uniform Guidance – summary of new
procurement related requirements
 Travel – RF Travel Handbook
 Open discussion on other AP or Purchasing topics
FATCA
 Foreign Account Tax Compliance Act – enhanced
reinforcement of U.S. compliance rules for entities
 Financial (FFI) versus Non-Financial (NFFI)
 FATCA main focus is information not tax
 FATCA comes first
 Requires foreign entities to report information –
otherwise potential withholding in some situations
New RF Process to meet U.S. Tax and
Reporting Rules
 Determine the supplier - IRS “Sourcing”
 U.S. Source OR
 Foreign Source
 If U.S. Source, apply further rules
 30% withholding general default rule
 Unless other exclusions or exemptions exist
OMB Uniform Guidance
 Procurement Standards contain arguably the biggest
changes for campuses
 OMB has granted institutions an optional one year
grace period for implementing changes
 RF opted to continue to comply with A-110 through
FY16 and has documented in the procurement policies
 Effective date of new requirements is July 1, 2016
Defined Procurement Methods
(1) Procurement by Micro-Purchases (up to $3,000) – no need to
solicit competition if price deemed reasonable
(2) Procurement by Small Purchase Procedures ($3,000 to
$150,000) – requires solicitation of quotations from an “adequate
number” of sources
 This is the biggest & potentially most onerous change
 Current RF policy requires competition at $50,000
 Could potentially require significant additional effort resulting in
delays in acquiring goods and services
Procurement Methods (cont.)
(3) Procurement by Sealed bids (more than $150,000) – preferred in
construction or other purchases where price is the major component
(formal advertising required)
(4) Procurement by Competitive Proposals (more than $150,000) –
RFP must be publicized and awarded to most advantageous offer with
price and other factors considered
(5) Noncompetitive purchases (single source) – used when product
or service is only available from one source or in other limited instances
Procurement Standards (cont.)
Other changes of interest include:
 Listing of detailed “affirmative action steps that must be taken” to assure
that MWBEs and labor surplus firms are used when possible
 Cost or price analysis required for all procurements above the simplified
acquisition threshold ($150k)
 Negotiation of profit required for each contract over $150k in which there
is no competition (single source procurements)
 Must maintain records sufficient to detail the history of the procurement
(rationale for the method of the procurement, selection of contractor
type, reasons why contractors selected and basis for the contract price)
Procurement Standards (cont.)
 Only apply to procurements charged directly to a
federal award
 Campus team is reviewing proposed revisions
which include revising RF Procurement Policy to
account for purchases using other funding sources
 Push back from higher-ed community may result in
$3,000 threshold being increased
RF Travel Handbook
 Consolidation of 25 travel guidance documents
 Efficient and user friendly access to travel
procedures and information
 Updated to include Uniform Guidance language that
travel dependent care costs are an allowable
charge to grants but must be consistently applied
Questions?