Advancing Veteran and public health
through innovative research

Acquisition of Goods and Services

I. PURPOSE: To define the requirements for PAVIR support for goods and services.

II. POLICY: It is the policy of PAVIR that acquisition of goods and services will be accomplished for appropriate research and educational activities and that payment for such goods and services will be made in a timely and responsible manner.

III. REQUIREMENTS: The following are requirements for expenditures made from PAVIR funds:

  1. All goods and services must have a research or education relation. Additionally, project, activity or program specific expenses require Research & Development Committee or Education Committee approval of the associated project, activity or program.
  2. There must be sufficient funding to support the request.
  3. Micro Purchases for goods and services up to $3,000 can be processed without obtaining formal quotes. Competitive bids are required for purchases in excess of $150,000. 
  4. All requests for payment or reimbursement must be made in a timely manner. PAVIR reserves the right to deny payment for invoices that are more than 90 days old. Reimbursement requests submitted more than 60 days after the expense was incurred must include a completed Justification for Late Submission form and may be denied. If PAVIR accepts the requestor's justification for late submission and does not deny reimbursement, the reimbursement must be reported as taxable income to the requestor.
  5. PAVIR is not exempt from sales and excise taxes. PAVIR must pay tax on all tangible goods purchased for use in California. If sales tax is not charged, PAVIR is required to pay use tax to the state.
  6. There must be a Signature Authority Delegation on file for anyone other than the Principal Investigator to approve expenditures. Signature stamps are not acceptable.

IV. RESTRICTIONS: Described below are restrictions on use of PAVIR funds:

  1. Purchases considered to provide predominantly personal benefit are not allowed.
  2. PAVIR does not provide discretionary spending accounts or tax indemnification and gross up payments.
  3. No expenditure will be authorized for personal housing expenses, business use of personal residence, health or social club dues or initiation fees, or personal services (e.g., maid, chauffeur).
  4. Expenses related to professional licensure (annual fees, Board certification courses, etc.) are not allowable, regardless of source of support.
  5. No purchase which may result in the appearance of a conflict of interest will be made.
  6. No expenditure will be authorized for memberships with PAVIR funds unless it includes a publication which furthers the VA’s research or education mission.
  7. No expenditures will be authorized for donations.
  8. No expenditures will be authorized for lobbying or political activities.
  9. PAVIR is not responsible for upgrade, repair or maintenance of VA or Stanford owned equipment. However, if such are allowable and appropriate, PAVIR funds may be used for such support.
  10. Business meetings may be appropriate for PAVIR support. If there is any question about what will or will not be allowed, pre-approval is strongly suggested. This approval can be obtained by email with PAVIR Administration.
  11. Foreign vendors are discouraged, unless the requested goods or services are unavailable within the US.
  12. Reimbursement for meals for business meetings (not associated with travel), including recruitment, scientific review with external colleagues, or other appropriate activity, will be limited to $30 per person for lunch and $50 per person for dinner. A Business Meeting Expense Request must be submitted for reimbursement. Such activities should be infrequent. (An exception to the infrequent requirement, for example, would be recruitment for an academic position involving dinners with several final candidates in a short period of time)
  13. Support of meals for frequently recurring staff meetings, journal clubs, lab review discussions, etc. is not an appropriate cost.
  14. Honoraria may be paid to invited lecturers. Honoraria will never include tax indemnification and gross up payment. Any associated travel support will be provided in accordance with the PAVIR travel policy. Payment for honoraria can be requested via a Check Request, which must be accompanied by a written invitation to the speaker/presenter, including date, purpose, and amount of payment. Any honoraria payment greater than $1,000 would require PAVIR’s CEO approval.  Special provisions govern payment of honoraria to VA-paid employees.
  15. A test of reasonableness will prevail in any acquisition for goods or services, including personal services, supported by PAVIR.
  16. Support for tuition must be reported as taxable income to the student. Therefore, the student must pay the fees and request reimbursement. Any reimbursement will be reported to the IRS, and the student will receive an IRS Form1099-MISC.
  17. Support for such things as food, drink or decorative items for personal use or benefit is not an appropriate cost. Only project specific items of this sort will be approved for purchase or reimbursement.

V.  PROCEDURES: PAVIR pays for goods and services through two mechanisms, either a Purchase Order or a Check Request (which includes a variety of specially tailored request forms, e.g., Travel Reimbursement Request, Animal Requisition Form, etc). Items requested by Purchase Order are reviewed by PAVIR Administration for allowability, reasonableness and availability of funds before any commitment is made; this is the preferred method for procurement of goods and services. A Check Request (or other reimbursement request) does not provide the same protection; an individual may make a commitment for which support is later denied by PAVIR.

PAVIR is not responsible for commitments (verbally or in writing) which are not accompanied by an authorized PAVIR Purchase Order.

PAVIR Accounting sets up all new vendors prior to the first order being placed. As a part of this process, Accounting ensures that the vendor is not on any federal or state excluded, suspended, or debarred list. In addition, PAVIR may prohibit the use of certain vendors if past experience, legal action, or other factors warrant an exclusion.

  1. Submission of a Purchase Requisition
    1. It is not allowable to split orders to avoid the need for competitive bids or sole source justification.
    2. To the extent possible, allow ample planning time for purchase of the goods or services. If the items are time sensitive clearly indicate this on the requisition.
    3. Requisitions should include factual, auditable statements of need.
    4.  Groups who order frequently, for example wet labs, will be set up to place requisitions through PAVIR’s online requisition system, ReQlogic, which automates the approval process for ordering.
    5. For those not on ReQlogic, a signed, completed Purchase Order should be submitted to the PAVIR office for each vendor from whom you wish to order. Incomplete information will delay the ordering process.
    6. Associated vendor quotes (e.g., discounted prices, special orders) will only be recognized if made out to PAVIR.
    7. Orders will usually be placed by PAVIR within two business days of receipt.
    8. Every effort will be made to achieve delivery as requested in the “Date Required” field. The PAVIR account listed will be charged for any increased shipping costs resulting from rush orders.
    9.  Any questions or problems with the order, e.g., significant price difference (20% or higher), back orders, discontinued products, will be conveyed to the person named as “Recipient” prior to placement of the order.
    10.  PAVIR reserves the right to substitute the vendor listed on the form with one from whom the same product is available at a lower price. The vendor may also be substituted if PAVIR does not have an account with the suggested vendor, and the same item is available through an established PAVIR vendor. In either case the recipient will be notified prior to commitment.
    11.  If an order is not received within the expected time frame the recipient should notify PAVIR Purchasing for follow up regarding anticipated delivery.
    12. Procurement of Goods and Services in excess of $150,000 require additional information as detailed in the section titled “Acquisition of Goods and Services in excess of $150,000.”
  2. Submission of a Check Request
    1. The Check Request (or pertinent Request document) is used for goods, services and other expenditures not procured through the use of a Purchase Order, including:
      1. Reimbursements;
      2. Goods or services acquired and invoiced “on account” to an individual or other entity;
      3. Orders which require a check, e.g., for reprints or a subscription.
    2. The following backup documentation is required with the signed, completed Check Request:
      1. Itemized detail - A company invoice, order form, or receipt indicating the items purchased or to be purchased, the price of each item and total cost. Quotes, Statements of Account, credit card slips and credit card statements do not fulfill the requirement for itemized detail.
      2. Proof of payment – Required if the Check Request is for a reimbursement. Standard retail cash register receipts, invoices marked “paid” or “credit card,” statements or invoices showing a zero balance, or printouts from bank or credit card accounts showing the payee and amount are all sufficient proof of payment.
      3. In some cases when an invoice or receipt carries no descriptive information, further documentation may be required.
  3. Acquisition of Goods and Services in excess of $150,000
    1. PAVIR requires three (3) formal bids through the Request for Proposal (RFP) process on all purchases of $150,000 or more.
      1. Bids of $150,000 or more shall be secured or confirmed in writing by a PAVIR Purchasing designee and reviewed and authorized by the CFO or CEO.
      2. All information necessary to prepare and submit bids/quotations shall be given equally to all suppliers solicited.
      3. The RFP description or specification must not favor one brand or trade name article, manufacturer or supplier over others.
        The right shall be reserved to accept or reject bids/quotations on each item separately or the bid/quotation as a whole. If the requisitioner, typically the Principal Investigator or designee, obtains bids from vendors, those bid documents must be submitted with the requisition. PAVIR Purchasing must assure that the vendors submitting bids are as qualified as the vendor of choice.
    2. To justify sole source on purchases for goods and services in excess of $150,000, the requisition must be accompanied by a Sole Source Justification form describing the features of a brand or trade name that only that product or service will fulfill, to the exclusion of all others. All such statements become a part of the purchase contract file and must be defensible at time of audit.
      1. Reasons must be specific and based on factual information that relates to the use of the item or service in the requisitioner’s work or research.
      2. Single source vendor quotations will be compared to quotations received from vendors of the same or comparable equipment; the requisitioner will be asked to prepare justification in terms of paying higher costs for the specified item/service.
      3. Sole sources are:
        1. A vendor, or a distributor, given an exclusive right to sell in a geographic area;
        2. A vendor who supplies equipment to a requisitioner who needs matching or coordinating equipment.
      4. Sole sources are not:
        1. A manufacturer or distributor supplying goods or services not essential to research, in competition with other manufacturers of like goods or services of equal quality;
        2. A vendor of personal choice or convenience
    3. For goods or services in excess of $150,000, PAVIR Purchasing will document the industry or markets involved, and/or document their opinion of the reasonableness of the requirement's cost provided by the requisitioner. Appropriate documentation includes:
      1. Comparison of the requirement to analogous items or items containing the same or similar components, or
      2. Consideration of the cost of development or of the singular benefits to be obtained by the requisitioner, as supplied within the requisition.
    4. PAVIR Purchasing may determine that insufficient evidence has been provided to justify the requisitioner's instructions to buy from a sole source. In that case, details of the transaction, together with details of possible alternatives, may be sent to the CFO or CEO for specific approval or additional documentation prior to issuing the order.
  4. Procurement of Animals
    1. Animals may be procured only by submission of a signed, completed Veterinary Medical Unit (VMU) Animal Requisition. This request must be submitted to the VMU designee in VA Research Administration (151) for review and approval.
    2. The requisition will be sent by the VMU designee to PAVIR upon approval. If not approved, the VMU designee will contact the requestor.
    3. PAVIR Purchasing will follow the standard purchasing procedures upon receipt of the VMU Animal Requisition from the VMU designee.
    4. All animal orders will designate the VMU as the delivery point.

VI. DONATION OF CERTAIN PURCHASES TO VAPAHCS

  1. To comply with certain regulatory requirements in carrying out its mission of facilitating research and education activities at VAPAHCS, PAVIR utilizes some facilities and reporting mechanisms of VAPAHCS.
  2. Within the requirements of the law and to eliminate duplicate registration, review and reporting activities, it is PAVIR policy that all animals purchased are donated immediately upon receipt to and become the property of VAPAHCS.
  3. Within the framework discussed above, PAVIR also utilizes VAPAHCS resources for such activities as handling and removal of medical and laboratory waste, including radioactive and other hazardous or controlled materials. To ensure conformance with legal and regulatory requirements and to eliminate duplication of activities it is PAVIR policy that all expendable supplies purchased by PAVIR for use in approved research or educational activities are donated immediately upon receipt to and become the property of VAPAHCS.

  Sole Source Justification Form

  This form justifies utilization of a sole source vendor.
Approved by PAVIR Board of Directors: January 14, 2015

Last Modified: December 9, 2016 1:19am