Two major financial policies effective July 1, 2018

Two major financial policies are now in effect as of July 1, 2018. The policies and additional materials may be found at the Financial Policy Offices website.

Financial Management of Property, Plant and Equipment (PPE Policy) (updated from 7/1/14 version )

This update to the 2014 PPE policy focuses on clarifying processes and procedures around the capitalization of property, plant and equipment. Updates to the policy include increasing the minimum threshold for upgrades and betterments for capitalized equipment to $5,000, clarifying when to capitalize or expense a fabrication, and allowing fixed pieces of equipment over $100,000 that are not linked to capital projects be capitalized. New sample forms around disposition of equipment, tracking untaggable equipment, and tracking equipment off-site have also been designed to aid the Oracle assets inventory process.

See also A Summary of PPE Policy Changes for 7/1/18 (Excel file).

Procurement Policy (new policy)

Effective 7/1/18, a new Procurement Policy went into effect. This policy details requirements and best practices for all funding sources, and includes specific requirements that comply with Federal Uniform Guidance (UG) requirements.

UG is a set of regulations that consolidate several federal guidelines related to purchases made with federal or cost-share funds or expenses transferred onto federal funds.

The policy and related materials are available on the Financial Policy Offices website (https://policies.fad.harvard.edu/pages/policies).

Key elements of the procurement policy include:

  • Conflict of Interest Standards
  • Instructions for Special Purchases
  • Use of Harvard Preferred Vendors
  • Tax Exemption Information
  • Required Practices for Purchases with Federal Funds, Including
    • Thresholds and Processes Required Based on Each Procurement Method (High-Level Summary Below)
  • Best Practices for all Purchases, Including
    • Best Practices around Thresholds for Non-Federal Funds
    • Small and Small Disadvantaged Business
    • Avoiding Wasteful or Duplicate Purchases
       
Procurement Requirement Threshold Processes and Documentation Required for Federal, Cost-Share, or Expenses Moved to Federal Funds
Micro Purchase ≤ $10,000
  • No additional documentation requirements
  • Use of Preferred Vendors encouraged

Small Purchase*

Simplified Acquisition Threshold (SAT)

> $10,000-$250,000
  • Two or more quotes (if Harvard Preferred Vendor isn't used)
  • Completed electronic HCOM VJF
  • Suspension & debarment form (if ≥$25K)
Large Purchases >$250,000
  • Formal bid process (posting, review, selection)
  • Sealed (Construction) or Competitive Bids
  • Completed VJF
    • Include documentation on how/why vendor selected
    • Cost and Price Analysis

*Earlier versions and outreach had listed the Small Purchase ceiling at $150,000. The Office of Management and Budget released a memo on 6/20/18 which increased the threshold to $250,000.