Procurement Policy

The federal government has set forth standards for use by recipients in establishing procedure for procurement of supplies and other expendable property, equipment, real property and other services. Williams College follows the federal government policies listed below.

Procurement Standards

  • Recipients shall avoid purchasing unnecessary items.
  • Where appropriate, an analysis will be made of lease and purchase alternatives to determine which would be the most economical and practical procurement for Williams College.
  • Recipients shall not do business with a suspended or debarred vendor or sub-recipient.  Recipients shall refer to the Excluded Parties List System (EPLS) at https://www.epls.gov/ for any purchase made of $25,000 or more, or for any sub-contract agreement (regardless of the dollar amount).
  • Solicitations for goods and services provide for all of the following:
    • A clear and accurate description of the technical requirements for the material, product or service to be procured. In competitive procurements, such a description shall not contain features which unduly restrict competition.
    • Requirements which the bidder/offeror must fulfill and all other factors to be used in evaluating bids or proposals.
    • A description, whenever practicable, of technical requirements in terms of functions to be performed or performance required, including the range of acceptable characteristics or minimum acceptable standards.
    • The specific features of “brand name or equal” descriptions that bidders are required to meet when such items are included in the solicitation.
    • The acceptance, to the extent practicable and economically feasible, of products and services dimensioned in the metric system of measurement.
    • Preference, to the extent practicable and economically feasible, for products and services that conserve natural resources and protect the environment and are energy efficient.
  • Following is a list of common unallowable costs.  Please also refer to OMB Circular A-21 for the complete list, as well as further guidance & explanations.
    • Alcoholic beverages
    • Bad debt
    • Bonding costs
    • Compensation for personal services
    • Depreication & use allowances
    • Donations & contributions
    • Employee morale, health & welfare costs
    • Entertainment costs
    • Fines & penalties
    • Fundraising & investment costs
    • Gains & losses on depreciable assets
    • Goods or services for personal use
    • Lobbying
    • Selling & marketing
  • Business meals shall be reasonable and be $100 or less per person (including tax and tip).  When sound business reasons necessitate that business meals exceed $100 per person, the excess cost of the business meal must be approved by the Office of the Provost.
  • Positive efforts shall be made by recipients to utilize small businesses, minority-owned firms, and women’s business enterprises, whenever possible. Recipients of Federal awards shall take all of the following steps to further this goal.
    • Ensure that small businesses, minority-owned firms, and women’s business enterprises are used to the fullest extent practicable.
    • Make information on forthcoming opportunities available and arrange time frames for purchases and contracts to encourage and facilitate participation by small businesses, minority-owned firms, and women’s business enterprises.
    • Consider in the contract process whether firms competing for larger contracts intend to subcontract with small businesses, minority-owned firms, and women’s business enterprises.
    • Encourage contracting with consortiums of small businesses, minority-owned firms and women’s business enterprises when a contract is too large for one of these firms to handle individually.
    • Use the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Department of Commerce’s Minority Business Development Agency in the solicitation and utilization of small businesses, minority-owned firms and women’s business enterprises.
  • The type of procuring instruments used (e.g., fixed price contracts, cost reimbursable contracts, purchase orders, and incentive contracts) shall be determined by the recipient but shall be appropriate for the particular procurement and for promoting the best interest of the program or project involved. The “cost-plus-a-percentage-of-cost” or “percentage of construction cost” methods of contracting shall not be used.
  • Recipients shall, on request, make available for the Federal awarding agency, pre-award review and procurement documents, such as request for proposals or invitations for bids, independent cost estimates, etc., when any of the following conditions apply.
    • A recipient’s procurement procedures or operation fails to comply with the procurement standards in the Federal awarding agency’s implementation of this Circular.
    • The procurement is expected to exceed the small purchase threshold fixed at $25,000 currently and is to be awarded without competition or only one bid or offer is received in response to a solicitation.
    • The procurement, which is expected to exceed the small purchase threshold, specifies a “brand name” product.
    • The proposed award over the small purchase threshold is to be awarded to other than the apparent low bidder under a sealed bid procurement.
    • A proposed contract modification changes the scope of a contract or increases the contract amount by more than the amount of the small purchase threshold.
  • Cost and price analysis. Price analysis may be accomplished in various ways, including the comparison of price quotations submitted, market prices and similar indicia, together with discounts. Cost analysis is the review and evaluation of each element of cost to determine reasonableness, allocability and allowability.
  • Procurement records. Procurement records and files for purchases in excess of the small purchase threshold shall include the following at a minimum: (a) basis for contractor selection, (b) justification for lack of competition when competitive bids or offers are not obtained, and (c) basis for award cost or price.