Procurement of Goods and ServicesProcurement of Goods and Services jbarber32 Tue, 09/04/2012 - 16:14
Counterfeit Electronic Part Detection and AvoidanceCounterfeit Electronic Part Detection and Avoidance
A counterfeit electronic part is an unlawful or unauthorized reproduction, substitution, or alteration that has been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified electronic part from the original manufacturer. The standard SAE AS6171 further classifies counterfeit parts as components that have been recycled, remarked, overproduced, out-of-specification/defective, received with forged documentation, or cloned. The United States (U.S.) Congress has directed that the Department of Defense (DoD) take specific actions to “prevent, detect, remediate and investigate counterfeiting in the DoD supply chain.”
The intent of the policy is to satisfy U.S. Government requirements (DFARS 246.870 and DFARS 252.246-7007) to prevent the proliferation of counterfeit parts while allowing researchers to fulfill their contractual obligations with minimal additional impediment. The policy was developed considering the requirements of the appropriate DFARS clause(s), Defense Logistics Agency standards, industry standards published by SAE, and conference with industry and government representatives.
Refer to Section 9 for reference documents and links as related to this policy.
It is essential that GIT maintain an acceptable Counterfeit Electronic Part Detection and Avoidance Policy (CEPDAP) adhered to by all individuals involved in the acquisition of electronic parts for work on DoD sponsored awards to comply with DoD mandatory requirements, minimize risk to DoD operations, and maintain an effective and efficient purchasing system. This policy describes the set of controls designed to eliminate or mitigate the risk of utilizing counterfeit electronic components in GIT delivered hardware. DoD contracts that are subject to DFARS 252.246-7007 are required to adhere to this policy. In the event of a conflict with other GIT policies or procedures, this policy shall take precedence.
Acronym, Abbreviation, or Term
|Authorized Aftermarket Manufacturer (AAM)||An organization that fabricates a part under a contract with, or with the express written authority of, the original component manufacturer based on the original component manufacturer’s designs, formulas,
|Authorized Supplier||Supplier, distributor, or an aftermarket manufacturer with a contractual arrangement with, or the express written authority of, the original manufacturer or current design activity to buy, stock,
repackage, sell, or distribute the part.
|C of O||Certificate of origin|
|Contractor-approved supplier (CAS)||A supplier that does not have a contractual agreement with the original component manufacturer for a transaction, but has been
identified as trustworthy by a contractor or subcontractor.
|CASL||Contractor Approved Supplier List|
|CDAS||Counterfeit Detection and Avoidance System|
|Contract manufacturer (CM)||A company that produces goods under contract for another company under the label or brand name of that company.|
|Counterfeit electronic part||An unlawful or unauthorized reproduction, substitution, or alteration that has been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified electronic part from the original manufacturer, or a source with the express written authority of the original manufacturer or current design activity, including an authorized aftermarket manufacturer. Unlawful or unauthorized substitution includes used electronic parts represented as new, or the false identification of grade, serial number, lot number,
date code, or performance characteristics.
|DFARS||Defense Federal Acquisition Regulations Supplement|
|DoD||Department of Defense|
The Electronic Components Industry Association (ECIA) maintains a database of verified authorized suppliers. The ECIA database is an alternative source for verifying authorized suppliers and shall be archived with purchase documentation.
|EEE||Electrical, Electronic, and Electromechanical|
An integrated circuit, a discrete electronic component (including, but not limited to, a transistor, capacitor, resistor, or diode), or a circuit
ERAI, Inc. is a global information services organization that monitors, investigates, and reports issues affecting the global electronics supply chain.
Government-Industry Data Exchange Program is a cooperative activity between government and industry participants seeking to reduce or eliminate expenditures of resources by sharing technical information essential during research, design, development, production and operational phases of the life cycle of systems, facilities and equipment.
Georgia Institute of Technology
Georgia Tech Research Institute
A process to protect or ensure the continued function and resilience of capabilities and assets – including personnel, equipment, facilities, networks, information and information systems, infrastructure, and supply chains – critical to the performance of DoD MEFs (Mission Essential Functions) in any operating environment of condition.
Obsolete electronic part
An electronic part that is no longer available from the original manufacturer or an authorized aftermarket manufacturer.
Original Design Manufacturer
Original component manufacturer (OCM)
An organization that designs and/or engineers a part and is entitled to any intellectual property rights to that part.
|Original equipment manufacturer (OEM)||A company that manufactures products that it has designed from purchased components and sells those products under the company's brand name.|
|Original manufacturer||The original component manufacturer, the original equipment manufacturer, or the contract manufacturer.|
|OSP||Office of Sponsored Programs|
|PMO||Project Management Office|
|SAE||Society of Automotive Engineers|
|Subcontractor||Any supplier, distributor, vendor, or firm that furnishes supplies or services to or for GIT|
|Suspect counterfeit electronic part||An electronic part for which credible evidence (including, but not limited to, visual inspection or testing) provides reasonable doubt that the electronic part is authentic.|
|Traceability||The capability to track the chain of custody of a procured item(s) through its specific supply chain.|
|Unit||College, School, GTRI laboratory|
|5.1 Employee Training|
To support this process, the following training requirement shall be imposed upon indicated personnel:
This policy will be the basis for a Counterfeit Electronic Component Awareness Training program to be developed and administered by GTRI, in conjunction with the Office of Sponsored Programs (OSP).
Project Directors (PDs) and Principal Investigator (PIs) are required to determine who within the project team should complete the training.
Personnel responsible for the specification and/or procurement of purchased components for prototypes, as well as personnel who physically handle electronic components or assemblies containing electronic components, are recommended to complete Counterfeit Electronic Component Awareness Training.
The GIT training for this policy can be found here. To access the training module, GIT employees will need to login to the employee training portal and search the course catalog for “Counterfeit Electronic Part Detection and Avoidance Policy Overview”.
|5.2 Inspection and Testing|
It is the responsibility of all personnel who handle electronic components or assemblies containing electronic components at any point in the inspection, assembly, and test flow to be aware of and to report any attribute, feature, or performance parameter that may indicate that the part is not genuine.
GIT procurement sourcing controls are designed to minimize risk of receipt of counterfeit electronic parts. However, there is a possibility that such parts may make their way into department or laboratory storage spaces. To support this policy, GIT will adhere to the following:
Upon receiving an item, a visual inspection must be conducted. If an item is purchased from Category 1 or Category 2, a visual inspection and acceptance will need to be completed. If an item is purchased from Category 3, it will need to be sent to a testing facility as identified on the CASL.
The physical/environmental/electrical/inspection test sequences required for Category 3 electronic parts is dependent on a risk assessment to determine the recommended level of testing to mitigate risk associated with obtaining the parts from an unauthorized supplier. SAE-AS6171 provides a method for establishing risk and appropriate test sequences, and shall be utilized and documented for GT and GTRI for procured Category 3 electronic parts.
Refer to Section 5.5 for supplier category and CASL information.
Refer to Section 5.6 for quarantine procedures if a suspected counterfeit part is identified.
|5.3 PROCESSES TO ABOLISH COUNTERFEIT PARTS PROLIFERATION|
All GIT orders for electronic components from any supplier shall request that the total quantity of any individual part be from a single manufacturing lot or date code. In addition to minimizing variation in performance, it is less likely that a single manufacturing lot or date code across the total quantity represents parts from an unauthorized market source.
This policy shall be imposed on GIT subcontractors as described in Section 5.9.
|5.4 PROCESSES FOR MAINTAINING ELECTRONIC PART TRACEABILITY|
GIT PDs, PIs, and PMs are required to add traceability documentation provided by vendors into the document repository of the PD's choice (Box, Sharepoint, etc) upon receipt of components to maintain supply chain traceability. PDs, PIs, and PMs must be aware that the selection of non-approved suppliers are subject to review and audit by the appropriate U.S. Government representative.
When sourcing an electronic part from a supplier, the following requirements apply:
|5.5 USE OF SUPPLIERS|
GIT is not certified to test suspected counterfeit parts; therefore, GIT shall follow the following guidelines in order to avoid the receipt of counterfeit parts.
GIT will be in compliance with DFARS 252.246 by obtaining electronic parts from one of three categories listed below in sequential order:
1. Category 1: GIT PDs, PIs, and PMs will obtain electronic parts that are in production by the original component manufacturer (OCM) or an authorized aftermarket manufacturer (AAM). If parts are not in production, obtain from currently available stock in the following order:
a. OCM of the parts;
b. OCM-authorized suppliers of the parts; or
c. Suppliers that obtain such parts exclusively from the OCM of the parts or their authorized suppliers.
OCM authorized suppliers shall be verified using one of these methods:
a. Verification of OCM authorized supplier legitimacy prior to purchase shall be documented. OCM websites include the suppliers that are authorized to distribute their components. A screenshot from the OCM website designating authorized suppliers or an email from an OCM verifying an authorized supplier is acceptable verification.
b. The Electronic Components Industry Association (ECIA) maintains a database (https://www.eciaauthorized.com/en) of verified authorized suppliers. The ECIA database is an alternative source for verifying authorized suppliers and shall be archived with purchase documentation.
A supplier’s website should never be solely relied on as a source for OCM authorization to distribute.
2. Category 2: If electronic parts are not available as provided in Category 1, GIT will obtain electronic parts that are not in production by the OCM or an AAM from suppliers identified by the CASL. The CASL is derived from the DLA certified vendor list, which is included in the workflow attached to this policy. The following three conditions apply to this source of electronic parts:
a. GIT will comply with GT Procurement processes to identify and approve CASs who adhere to established counterfeit prevention industry standards as mentioned in Section 10;
b. CAS assumes responsibility for the authenticity of parts provided to GIT; and
c. CASL is subject to review and audit by the government CO.
3. Category 3: If GIT (i) obtains an electronic part from a source other than those identified in Categories 1 and 2 because of nonavailability or from a subcontractor other than the OCM that refuses to accept the flow down of DFARS clause 252.246-7008; or (ii) cannot confirm that an electronic part is new or previously unused and that it has not been comingled in supplier new production or stock with used, refurbished, reclaimed, or returned parts, then the contractor must adhere to the following:
a. Promptly notify the sponsor CO in writing;
b. Be responsible for inspection, testing, and authentication by selecting a test resource from the CASL; and
c. Log documentation of inspection, testing, and authentication to make available to the government upon request.
|5.6 REPORTING AND QUARANTINING OF COUNTERFEIT ELECTRONIC PARTS|
When one becomes aware of, or has reason to suspect that any electronic part, component, or assembly containing electronic parts purchased contains counterfeit electronic parts or suspect counterfeit electronic parts, reporting is required to the Government CO and to the GIDEP.
Per standard AS5553C, control suspect counterfeit EEE parts to preclude their use or reentry in to the supply chain by physically identifying and segregating the suspect counterfeit EEE parts from acceptable non-suspect EEE parts and placing in quarantine until dispositioned. Quarantine shall consist of a controlled access space.
PMO can provide guidance about any of these processes in this policy. Please direct any inquiries to PMO.
|5.7 METHODOLOGIES TO IDENTIFY SUSPECT COUNTERFEIT ELECTRONIC PARTS|
Electronic parts purchased from Category 1 or Category 2 suppliers do not require individual component testing. However, when purchasing parts from a Category 3 supplier, GIT will rely on the identification of suspect counterfeit electronic parts through the use of CASL Testers for inspection and counterfeit testing.
Refer to the policy workflow attachment for the CASL.
|5.8 DETECTION AND AVOIDANCE|
GIT is committed to the detection and avoidance of counterfeit electronic components in the government supply chain. GIT supports the procurement of electronic components through Categories 1 and 2, and to follow a thorough selection process when vetting Category 3 suppliers.
|5.9 POLICY FLOW DOWN|
All GIT orders for electronic components from any supplier shall request that the total quantity of any individual part be from a single manufacturing lot or date code. In addition to minimizing variation in performance, it is less likely that a single manufacturing lot or date code across the total quantity represents parts from an unauthorized market source.
Subcontractor Flow Down
A subcontractor is defined as any supplier, distributor, vendor, or firm that furnishes supplies or services to or for GIT.
Subcontractors participating in GIT projects at all levels in the supply chain that are responsible for buying and selling electronic parts or assemblies containing electronic parts, or that perform authentication testing are required to comply with the notification, inspection, testing, and authentication requirements as listed in this policy. GIT shall be responsible for ensuring that these requirements are flowed down to subcontractors.
The subcontractor is required to meet one of the two options listed below:
In all cases, GIT will work proactively with the subcontractor to ensure a smooth and expeditious resolution that is in the interests of both parties.
Purchase Order Flow Down
For COTS products and non-recurring engineering (NRE) initiated through a purchase order (PO), GIT will flow down this policy to ensure counterfeit avoidance compliance.
When sourcing an electronic part from a supplier, the following requirements apply:
|5.10 CONTINUING EDUCATION ON COUNTERFEIT PARTS|
GIT will require periodic training of counterfeit parts avoidance trends for applicable employees via online training and conferences.
|5.11 MONITORING POLICY UPDATES|
GIT has access to the GIDEP and other credible sources for information pertaining to updated counterfeit parts advisories.
For access to these reports, please direct any inquiries to PMSO.
|5.12 CONTROL OF OBSOLETE ELECTRONIC PARTS|
GIT shall avoid the use of obsolete parts on new designs. All parts lacking traceability shall be considered as obsolete parts.
Frequently Asked Questions
Question: What is an electronic part?
Answer: An integrated circuit, a discrete electronic component (including, but not limited to, a transistor, capacitor, resistor, or diode), or a circuit assembly. The term “electronic part” includes any embedded software or firmware.
Question: What is an electronic counterfeit part?
Answer: A counterfeit electronic part is an unlawful or unauthorized reproduction, substitution, or alteration that has been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified electronic part from the original manufacturer. The United States (U.S.) Congress has directed that the Department of Defense (DoD) take specific actions to “prevent, detect, investigate, and remediate counterfeiting in the DoD supply chain.”
Question: How does this policy pertain to GIT?
Answer: DoD contracts that are subject to DFARS 252.246-7007 are required to develop and execute a counterfeit parts policy in order to prevent counterfeit parts from entering the government supply chain. This policy describes the set of controls designed to eliminate or mitigate the risk of utilizing counterfeit electronic components in GIT’s delivered hardware.
Question: To whom does this policy apply?
Answer: The Counterfeit Electronic Part Detection and Avoidance Policy applies to all GIT Personnel who purchase or specify the purchase of electronic components for use in DoD delivered hardware on contracts that are subject to DFARS 252.246-7007.
This process applies to electronic components utilized by, or incorporated into, the fabrication, assembly, or test of prototype hardware that is to be provided for evaluation or service to U.S. Government sponsors. This process is also provided as a recommended practice for all programs. This includes electronic assemblies or subsystems that are designed and built to project requirements by third party original design manufacturers (ODMs), as well as hardware that is designed by GIT but then outsourced to a contract manufacturer (CM) for assembly.
Excluded from these requirements are electronic components procured for use in equipment intended for internal purposes (e.g. research, development, problem resolution, testing theories, trying new ideas, etc.), and which are not planned to be provided to sponsors. However, GIT still encourages the procurement of parts through approved venders as identified in this policy.
Also excluded are unmodified commercial off-the-shelf (COTS) assemblies or subsystems, procured from original equipment manufacturers (OEMs), unless otherwise specified in the project plan or mission assurance plan.
Question: Who is responsible for the implementation of this policy?
Answer: Implementation is the responsibility of any individual or organization, internal or external to GIT, which is involved in sourcing such parts in support of program hardware provided to U.S. Government sponsors.
Question: What types of counterfeits are there?
Answer: Counterfeit parts may consist of recycled, remarked, overproduced, out-of-specification/defective, cloned, received forged documentation, cloned, or tampered parts.
Question: Are parts other than electronic parts to be covered by this policy?
Answer: This policy currently addresses only counterfeit electronic parts. As future DFARS pronouncements expand the scope of the required Counterfeit Detection and Avoidance System (CDAS) to additional parts categories, the scope of this policy will expand accordingly.
Question: How does this policy affect parts purchased for internal projects or use (IRAD, Testing, RI needs, etc.)?
Answer: Although not subject to DFARS 252.246-7007, the purchase of any electronic parts for internal use can also introduce counterfeit parts into GIT supply and affect the safety and/or quality of assemblies and products. It is advisable to mitigate this risk by following the purchasing guidelines outlined within this policy.
Question: What is the process for reporting suspected counterfeit parts to GIDEP?
Answer: GIT PDs, PIs, and Program Managers (PMs) shall work with the supplier to verify counterfeit determination and shall issue a Government-Industry Data Exchange Program (GIDEP) Advisory (suspect counterfeit part, but confirmed genuine) or GIDEP Alert (confirmed as counterfeit). Such reports are to be issued within 30 days of the initial escalation. For access to GIDEP, please direct any inquiries to PMO.
Refer to Section 5.6 for quarantine procedures if a suspected counterfeit part is identified and notify PMO.
Question: Is the supplier’s certification, listed on their website that considered reliable?
Answer: No. GIT Personnel may, however, rely on the original manufacturer’s list of authorized suppliers to gain comfort that electronic parts purchased from that supplier are genuine. However, any certification must come from the Original Component Manufacturer (OCM), not the reseller.
Question: What is the importance of visual inspections?
Answer: Visual inspection on electronic parts and packaging is important to detect nonconforming and suspect counterfeit characteristics ahead of time, to prevent, investigate, and remediate counterfeiting into the government supply chain.
Visual Inspection is required on projects that purchase electronic components for use in DoD delivered hardware on contracts that are subject to DFARS 252.246-7007. PMO has PM Professionals who are certified component inspectors. Please direct any inquiries to PMO.
Question: What if traceability cannot be established?
Answer: Contact PMO if traceability of parts cannot be obtained.
Question: What should a Risk Matrix for Counterfeit Parts look like?
Answer: The sponsor may have specific requirements of what the Risk Matrix should contain. If no specifics are required, a template is attached to this policy.
Question: Who can help determine the level of risk and associated tests needed if purchasing Category 3 electronic parts?
Answer: Contact PMO for assistance with establishing a risk assessment and test sequence program as prescribed in SAE-AS6171.
Question: How often is the Counterfeit Electronic Part Detection and Avoidance Policy updated?
Answer: This policy is reviewed and updated on a yearly basis.
Question: Who should be contacted for questions or assistance?
Answer: Contact PMO or unit management with any questions or requests for assistance.
It is the responsibility of all personnel who handle electronic components or assemblies containing electronic components at any point in the inspection, assembly, and test flow to be aware of and to report any attribute, feature, or performance parameters that may indicate that the part is not genuine. The unit is responsible for establishing internal requirements for approval and delegation of authority to purchasing electronic parts.
Project Management Office
The Project Management Support Office (PMO-GTRI) is responsible for the implementation of the policy.
Georgia Tech organizational unit management
- Project Directors (PDs)
- Principal Investigators (PIs)
- Program Managers (PMs)
It is the responsibility of the purchase requestor to be sure that the policy is adhered to during the acquisition of electronic parts.
|Document Number||Document Title, Revision, and Date|
|DFARS 246.870||SubPart 246.8 – Contractor Liability for Loss of or Damage to Property of the Government, Revised October 21, 2016|
|DFARS 252.246-7007||Contractor Counterfeit Electronic Part Detection and Avoidance System, August 2016|
Sources of Electronic Parts
SubPart 231.2 - Contracts With Commercial Organizations
|Document Number||Document Title, Revision, and Date|
Acceptability of Electronic Components Distributed in the Open Market
Counterfeit Electronic Parts: Non-Proliferation for Manufacturers
|SAE AS5553B||Counterfeit Electrical, Electronic, and Electromechanical Parts; Avoidance, Detection, Mitigation, and Disposition|
|SAE AS6081||Fraudulent/Counterfeit Parts: Avoidance, Detection, Mitigation, and Disposition - Distributors|
Test Methods Standard; General Requirements, Suspect/Counterfeit Electrical, Electronic, and Electromechanical Parts
|Other Reference Items|
|CASL||Category 3 List of Testers|
|ECIA||ECIA maintains a database (https://www.eciaauthorized.com/en) of verified authorized suppliers. The ECIA database is an alternative source for verifying authorized suppliers and shall be archived with purchase documentation.|
|ERAI||ERAI, Inc. is a global information services organization that monitors, investigates, and reports issues affecting the global electronics supply chain.|
|GIDEP||GIDEP is a cooperative activity between government and industry participants seeking to reduce or eliminate expenditures of resources by sharing technical information essential during research, design, development, production and operational phases of the life cycle of systems, facilities and equipment.|
|PMO Help Request and Email||
Help Request Link
|7/22/2021||GTRI PMO||Editorial Updates|
|09/15/2017||GTRI PMO||Transitioned to a GTRI internal memorandum for record|
Employee Contractor PolicyEmployee Contractor Policy
To provide guidelines for contracting with individuals and firms. Additionally, this Policy clarifies the distinction between an employee and contractor.
A consultant or independent contractor is a firm or an individual offering professional or specialized services for a fixed rate or fee. A consultant or independent contractor should be used only when the services are not readily available from existing employees or where the services cannot be performed more economically or satisfactorily through the Institute employment process.
The Institute only controls the direction of the consultant or independent contractors' work with respect to work objectives and desired results and not the methodology for achieving the results. Any individual who performs services for the Institute is presumed to be an employee unless the relationship satisfies the IRS standards for Independent Contractor (see Classification of Independent Contractors versus Employees below).
Firms and corporations that are clearly in the business to offer and sell their services to the public are independent contractors.
A determination must be made to ensure that payments to individuals for services (instructors or consultants) clearly meet the Internal Revenue Service (IRS) definition of Independent Contractor and that the regulations of the IRS and Immigration and Naturalization Service/US Department of State with respect to non-US citizens/resident aliens have been followed.
This policy applies to all Georgia Tech units.
Classification of Independent Contractors Versus Employees
The department/unit makes the initial determination whether an individual is an employee or independent contractor because of the familiarity of the relationship. Prior to engaging any individual for services as an independent contractor an assessment based on IRS guidelines must be made and documented. The department must complete the “Employee Contractor Classification Checklist”.
The prospective worker must also complete the “Employee - Independent Contractor Classification Checklist” as well as provide a vendor Statement of Work.
If additional review is required, a review committee which will include the Tax Compliance Manager, Procurement and Business Services, and Legal Affairs staff will make a determination.
If approved by Purchasing or Human Resources, the completed checklist must be attached to a requisition in Georgia Tech E-Procurement System for processing. If the consultant is a teaming partner and will be paid from sponsored funds, the agreement must be executed through the Office of Sponsored Programs on a "Request for Sub-Agreement Form".
Groups Usually Paid As Employees:
•Academic Activity – Instruction services provided to enrolled students and for Georgia Tech programs
•Former Georgia Tech Employees – Persons employed by Georgia Tech in any position within the last 36 months
•Graduate Research Assistant, Graduate Teaching Assistant, or Graduate Assistant – Graduate students providing teaching, research, and staff duties
•Individual who performs substantially similar services as those provided by Georgia Tech employees – All individuals, including student workers
•Office management and accounting services – individuals who perform substantially similar services to Georgia Tech employees not hired through an employment agency
•Retired Individuals from University System of Georgia who are receiving benefits – Retired-but-Working classification
•Short-term direct support staff supervised by Georgia Tech faculty or staff – duties often performed by Tech Temps
•Student providing non-skilled services – student assistants
•Support services for programs and activities – includes summer activities/camps, grading papers and other services
•Temporary help – includes event set-up, drivers, errands and various other services
A Pay Classification Matrix has been developed for your reference and the link can be found here and in the Related Information section of this policy.
The method for reimbursements made directly to the service provider (consultant, etc.) must be specified in the consultant's contract for services. Travel reimbursements may be made based on state travel regulations. The administrative unit is responsible for determining if charges for reimbursable expenses are proper and reasonable and the amount agreed to cover those travel expenses should be entered as a separate line item on the requisition. Specific requirements for documenting and itemizing those travel expenses will be detailed in the service agreement, but original receipts are not required. All payments to the consultant or firm will be reported on IRS Form 1099-misc or 1042-S, as appropriate. Tax withholding, where required, will apply at time of payment. Direct billing of airfare or hotel is not permitted.
It is the responsibility of the department/unit to initially determine if an individual is an employee or independent contractor based on IRS guidelines.
It is the responsibility of the Georgia Tech Human Resources to review documentation related to the individual to determine if classification of individual is independent contractor or employee.
|12-2020||Purchasing and Procurement||Editorial updates|
|10-2014||Purchasing and Procurement||Updates to verbiage|
Exempt ProcurementsExempt Procurements
This policy outlines requirements for exempt goods and services that may or may not be reviewed by the Georgia Tech Purchasing Department.
The State Accounting Office (SAO) provides guidance to state entities on when a purchase order is expected in the procurement of goods and services. A purchase order is required for all purchases of goods and services more than $2,499 except as noted in this Policy. For more details, see the State Accounting Office’s Statewide Purchase Order Policy.
For purchases requiring a purchase order, the following are exempt from procurement bidding requirements outlined in Policy 5.2 Procurement of Goods and 5.3 Procurement of Services. These exempt purchases are reviewed by the Georgia Tech Purchasing Department for amounts greater than $2,499 when processed via Georgia Tech E-Procurement System. The Purchasing Department reserves the right to require competitive bidding or sole source justifications on exempt purchases.
- Exempt goods and services identified by DOAS by NIGP code and posted on their website.
- Exempt goods and services identified in the State Purchasing Act
This policy applies to all Georgia Tech employees.
Requesting Department/End User
It is the responsibility of the requesting department/end-user to follow any institute, BOR, and state-related policies and procedures regarding exempt procurements.
It is the responsibility of the procurement professional to determine if the exempt procurements reviewed by the purchasing department meet the requirements outlined in any institute, BOR, and state-related policies and procedures.
|11-2020||Procurement and Business Services||Update to policy|
|07-2013||Procurement and Business Services||Update to policy|
Honorarium PaymentsHonorarium Payments
An honorarium is a one-time payment for short-term services, as outlined in this procedure, where the Institute does not expect a particular deliverable and the recipient will not invoice the Institute for services rendered.. Nonresident Alien individuals may receive honorarium payments with a J-1, B-1, or B-2 visa. Most other Visas do not permit honoraria payment.
- Honorariums are to be paid to individuals, rather than companies or organizations. Services provided by companies or organizations must be contracted.
- Honorariums are not to be paid to Georgia Tech employees including student employees.
- State law limits those State of Georgia employees who are eligible to sell their services to other State agencies on a per diem/honorarium basis. Payment is allowed only if the individual is classified in one of the following categories:
- any person holding a doctoral or master's degree from an accredited college or university
- registered nurse or licensed practical nurse
See documentation requirements below for when payee is State of Georgia employee.
When to Use
- An honorarium must be paid for services provided and cannot be used as a form of payment for an award.
- The service provided is one where Georgia Tech does not expect a particular deliverable.
- Examples include:
- presentation of research results
- reading of papers
- participation or leading of colloquiums, workshops, and seminars
- presentation of lectures
- The services provided must be short-term in length. Short-term is defined as 9 business days or less. Services over a longer period of time must be contracted.
- Approval by an administrative unit indicates that payment is allowable from funding source. [If state funds, the service should be instruction, research or public service. If sponsored funds, service must be instruction, research, public service or is specifically authorized by grantor.]
- Approval by an administrative unit indicates that payment is within policy guidelines for honorariums.
- Each honorarium activity should typically not be greater than $5,000 unless a special exception has been granted by the Purchasing Department. Honorarium payments are processed as a direct expense and are not initiated through the requisition process.
- Amount of honorarium may include payment for services along with amount intended to cover travel expenses.
- Amount for services (honorarium) may be paid and expenses reimbursed with appropriate receipts and documentation. Payment of honorarium and expenses must be requested at same time.
In accordance with Internal Revenue Service regulations, payments to US tax residents, which total $600 or more in aggregate to payee, will be reported as income on a 1099-Miscellaneous Income form.
If recipient is Nonresident Alien, reporting on IRS Form 1042-S will be in accordance with guidelines outlined in separate procedures for payments to Nonresident Aliens.
- An official announcement, invitation letter, flyer, etc. that outlines the need of the service provided must accompany the request for payment of honorarium.
- In all cases, requests must be accompanied by a Georgia Tech Vendor Profile Form completed by the recipient of the honorarium.
- If payee is Nonresident Alien, see separate procedures for restrictions and requirements may apply.
- Receipts for travel expenses if claimed as a separate expense line.
- If payee is State of Georgia employee, the following must be provided:
- certification from requesting department of the need for services and why the best interest of the State will be served by obtaining such services from a person not presently employed by the State,
- certification by department, agency, etc. employing employee that the performance of such services will not detract or have a detrimental effect on the performance of employee's full-time employment .
Procedure Guidelines Forms
Recipients of a honorarium will need to be set up as a supplier. Requests for payment of honorariums should be submitted electronically as a supplier invoice request (SIR) via the Institute’s Financial System. The appropriate spend category for honorariums is to be used.
Expense Account Classification
The appropriate expense category is also to be used for any associated travel expenses. Expenses must be reported by day and travelers must comply with Institute travel policies. Travel expenses that are not supported by receipts, or otherwise do not comply with Institute travel policies will have all expenses classified as honoraria income.
Payments to International Vendors and Nonresident Alien Foreign National Consultants, Scholars, and Official VisitorsPayments to International Vendors and Nonresident Alien Foreign National Consultants, Scholars, and Official Visitors
The following procedures will provide guidelines for retaining the services of non-employee foreign nationals, including international vendors, consultants, scholars, and official visitors. Policies are made to ensure that contracts and payments are made in compliance with Internal Revenue Service and Department of Homeland Security laws and regulations.
Eligibility for Payments
The U.S. Citizenship and Immigration Services laws and regulations are very specific about what types of payments may be made to each visa type, who may make the payments, and what type(s) of employment verification documents are required for the foreign nationals to receive payments.
An abbreviated list of common visa types, restrictions, and documentation is provided below:
- B-1 or *VWB or WB (Visitor/Business) - May receive reimbursement for reasonable travel expenses and, under limited circumstances, payments for compensation and honoraria.**
- B-2 or VWT or WT (Visitor for Pleasure) - Under limited circumstances, may receive payments for compensation, honoraria, and reimbursement of reasonable travel expenses.**
- F-1 & J-1 Students may receive compensation as well as an award, prize, research participant stipend or scholarship.
- J-1 (Exchange Visitor - Short term Scholar, Professor, Researcher or Specialist) is eligible to receive compensation and reimbursement payments from the organization and for the period stated on the DS-2019. Visitor must have a Social Security or Tax ID Number for compensation payments.
- Canadians who enter the United States and are not issued a Form I-94 are considered to be in B status (compensation and reasonable travel expense reimbursement) with permission to remain in the US for up to six months.
*VWB/WB or Visa Waiver for Business is an agreement between the US and certain countries in which the visitor is not required to have a visa. Participants in the program must be present in the United States fewer than 90 days with a valid passport and a nontransferable, nonrefundable round trip ticket.
**The American Competitiveness Workforce Act of 1998 allows payment of honoraria and associated incidental expenses to B-1, B-2, WB, and WT visa holders for “usual academic activity," if paid by a United States institution of higher education, a nonprofit organization affiliated with an institution of higher education, or a nonprofit or a governmental research organization. Under the Act, an academic activity may not exceed nine days at a single institution. In addition, such visa holders cannot accept honoraria and/or incidental expenses from more than five such institutions or organizations in the previous six months.
Federal Tax Treatment
Georgia Tech will withhold taxes in compliance with IRS tax law for all applicable foreign national payments, including honoraria, compensation, consulting fees, fellowships, stipends, awards, participant payments, sub-agreements, services/maintenance, royalties, rents, as well as some reimbursements for travel. Detailed descriptions regarding tax issues for non-US tax residents can be found in IRS Publication 519: US Tax Guide for Aliens.
Tax treaty benefits may be available to the payee, if there is an income tax treaty between the home country and the US. The individual’s US tax residency status, the business purpose of the payment, and payment amount determine whether a particular tax treaty benefit applies. In addition. All claims for tax treaty benefits must include the individuals social security number or an ITIN (Individual Taxpayer Identification Number). See IRS Publication 901: U.S. Tax Treaties.
A foreign national is an individual who is not a citizen or a permanent resident (holder of a "green card") of the United States. (U.S. permanent residents are foreign nationals, but by definition are treated the same as U.S. citizens for tax purposes.) A foreign national is admitted to the United States for a temporary stay and for a specific purpose (identified by visa type).
Georgia Tech utilizes the GLACIER Nonresident Alien Tax Compliance System to collect immigration and tax related information from foreign nationals receiving funds from the Georgia Institute of Technology. All foreign nationals receiving funds from the Institute must have a GLACIER record. GLACIER determines tax residency status and tax treaty eligibility for the foreign national. The system creates all forms required prior to payment, as well as the IRS form 1042-S for annual tax reporting.
The Accounts Payable Website includes payment request checklists to assist the campus administrator with the collection of required documentation for each category of international payment (How to pay an honorarium, How to make a fellowship payment, etc).
Please submit a ServiceNow request for additional guidance regarding payment processing for international payees.
Procurement Cards (PCard)Procurement Cards (PCard)
The Georgia Tech Procurement Card (PCard) is a purchasing card that may be used by Institute employees for authorized business purchases within the delegated authority limit. Cardholders must follow State of Georgia (DOAS), Board of Regents (BOR), and Georgia Tech purchasing policies and strive to obtain the maximum ultimate value for each dollar of expenditure. The Pcard is a tool for purchases of non-equipment, business related items under the cardholder’s single transaction limit in the approved PCard Plan (for vendors who are not currently setup in Georgia Tech's E-Procurement System or for vendors with whom we expect to only make one purchase). Effective, April 1, 2017, the State of Georgia PCard Policy changed which requires all State Agencies participating in the Card Program to have an approved PCard Plan. This PCard Plan was signed off by the Institute's President and the Institute's Chief Financial Officer (Chief Business Officer) and approved by the Department of Administrative Services in conjunction with the Office of Planning and Budgeting at the State level. Cardholders must follow State of Georgia (DOAS), Board of Regents (BOR), and Georgia Tech purchasing policies and strive to obtain the maximum ultimate value for each dollar of expenditure. Additionally, Institute employees and officials assigned PCard responsibilities should familiarize themselves with the provisions of public law governing PCards to include Title 50, Chapter 5, Article 3 of the O.C.G.A. at:
The use of the card is beneficial to the individual purchaser, the purchaser's department, the Institute, and the suppliers. It simplifies the purchasing and payment process and expedites receipt of goods. The PCard provides significant cost savings to Georgia Tech while providing electronic control and accountability. Any vendor that accepts Visa will accept the PCard.
This policy applies to all employees.
General Information & Definitions
Approver - The non-subordinate employee designated by the unit to review and verify cardholder transactions.
Billing Address - The campus billing address of the individual cardholder. Address should include mail code. The Billing Address may be requested by vendors for order verification.
Procurement and Business Services – The Georgia Tech organization responsible for the overall administration of the PCard Program.
Billing Date (Bank Posted Date) – The date the vendor transmits your purchase information to the bank for posting to your PCard account (Not necessarily the date you made the purchase). Visa’s vendor contract requires account billing upon shipment of an order.
Billing Phone Number - The campus phone number of cardholder. May be requested by vendors for order verification.
Cardholder - Employee who has been issued a PCard.
Card Issuer - Bank of America, the bank issuing Georgia Tech’s PCard.
Cycle Cutoff - The date the monthly statement is issued, the 27th of each month
Department Head - For purposes of these instructions refers to the VP, Dean, Director, or Department Head with budget authority for unit. This authority cannot be delegated.
Director of Purchasing – Responsible for the acquisition of goods and services at Georgia Tech. Serves as the Institute’s primary liaison with the Georgia Department of Administrative Services (DOAS).
Employee Agreement Form - The written agreement between Georgia Tech and the cardholder.
Forms and Manuals – Forms and user manuals are available online at the Procurement and Business Services website at www.procurement.gatech.edu . Revisions to the forms and manuals may be frequent. All employees should check the website often for current versions.
Georgia Tech E-Procurement System - Web-based software that contains online record of Pcard transactions, which are verified and reconciled by cardholders. Transactions are then approved via automated approval workflows.
PCard Administration – Procurement and Business Services unit that manages the day-to-day operations of the Institute’s PCard Program.
PCard Program Manager - Procurement and Business Services representative responsible for PCard program. Serves as the Institute’s official liaison with State Cards Program Manager.
PCard Administrator – Procurement and Business Services representative that assists PCard Program Manager administer PCard program.
PCard Coordinators - Department representatives responsible for facilitating the Procurement Card Program within their departments.
PCard Helpdesk – PCard Administration point of contact to assist with questions/concerns, available via phone at 404-385-5578 or e-mail at firstname.lastname@example.org.
The purpose of this PCard Policy is to provide Institute guidelines for the issuance and use of the PCard along with instructions for reconciliation and review of transactions. The Policy will be reviewed for adequacy by the Institute’s PCard Program Manager annually.
Safeguarding of the Institute's Assets
- Rebates or refunds from vendors shall be the property of the Institute and shall be paid promptly into the Institute’s accounts.
- Criminal and consumer credit checks will be performed in accordance with BOR and DOAS policy. The Institute will ensure that the results of background checks are provided the privacy protections required by law.
- New cardholders, are required to have criminal and consumer credit checks prior to being issued a PCard. Additionally, credit checks must be done again at the time of card renewal.
- Cardholders will be required to personally reimburse the Institute for purchases made that are not appropriately documented. Approving officials may be required to reimburse the Institute if the approving official approved the purchase.
- Habitual loss of receipts/documentation may require personal reimbursement by the cardholder and/or approver and may also result in termination of the PCard.
- Items of value purchased for distribution to students are allowed only in support of the educational objectives of the Institute. Additionally, the cardholder must maintain sufficient documentation to identify the individual receiving an item. The requirement to track individual recipients does not apply to items of de minimis value.
Departments must ensure that PCards are promptly cancelled upon employee transfer or termination.
PCard purchases can only be shipped to GT addresses. Items shipped to non-GT locations must have written approval from the cardholder’s supervisor and the PCard Administrator.
PCards may be issued to “permanent, regular-status” employees only. No student employees, affiliates or Tech Temps may be issued cards. Only one card is allowed per employee.
Authorization - A PCard Request Form is completed by/for the employee and then signed by Department Head to indicate authorization, cardholder spending limits, and cost allocation information. Spending limits should be determined based on the cardholder’s job responsibilities, anticipated card usage levels, historical spending patterns, and budget limitations. The completed form with the required signatures is submitted to PCard Administration by the PCard Coordinator. After all background checks have been verified, the request will then be reviewed and approved by the CFO. Upon approval by the CFO, the PCard Administrator will order the card from the bank and maintain the form in a cardholder file.
- Distribution – PCard Administration will notify the cardholder and appropriate PCard Coordinator when the card has been received. Cards will be distributed to employees after completion of appropriate background checks, cardholder training and submission of the signed Employee Agreement Form.
- PCard Administration will review cardholder accounts annually to identify and close unused or low-usage cards for which there is no longer a business need.
Employee Agreement Form
Before being issued a PCard, a completed Employee Agreement Form, signed by the employee and Department Head must be submitted to Business Services. By signing the form, the employee acknowledges:
- Receipt of training and understanding of the regulations for use and protection of card.
- Understanding of responsibilities in reconciliation process and billing disputes.
- Understanding and acceptance of consequences for PCard violations.
Since Georgia Tech, not the individual employee, will pay for the purchases made with the card, additional controls have been added to the card accounts. These limits are imposed at the point of sale when the card is swiped.
- Institute Limits – The PCard may be used for purchases not to exceed the cardholder’s single transaction or cycle limit in the PCard Plan. The cardholder’s Department Head working with the PCard Coordinator may identify additional limits based on card usage and budget limitations. These limits should be noted on the approved Request Form and kept in the cardholder’s file.
- Increased Limit PCards may be used by department buyers and other specifically designated and pre-approved cardholders for purchases requiring increased limits on an as needed basis. Requests for transaction increased limits must be approved by the Department Head and submitted to the PCard Program Administrator for review and approval. The PCard Program Administrator will coordinate with the State Cards Program Manager when an exception to State PCard Policy is required. Increased Limit cards may not be used to circumvent the State’s no-bid limit.
- Cardholder Spending Limits – Adjustable limits per card are:
- Dollar amount limit per transaction
- Dollar amount limit per cycle (month)
- Changes to Limits - Requests for changes to card limits should be submitted on the “Limit Change Request” form by the Department Head or PCard Coordinator via email to PCard Administration. Change requests will be kept in the cardholder’s file. Additional information can be found at the link to PCard Requisition Instructions and Exceptions for the requisition process and limit increases. The form is available online in the Forms section of the Business Services website at: http://www.procurement.gatech.edu
- Merchant Activity Type Limits - Specific types of businesses identified by a Merchant Category Code (MCC) are restricted on the card. If you have difficulty using your card with any particular vendor, please contact your department PCard Coordinator or the PCard Help Desk.
- Policy Limits - In addition to the limits that are controlled at the point of sale by the card, Georgia Tech limits the use of the card through policy. The card may be used only for purchases that are made under delegated authority or items exempt from review and approval by the Purchasing Department.
Authorized Uses of PCards
All purchases made with a PCard must be for official Institute business. Cardholders and approving officials are designated as Institute purchasing agents and are subject to the provisions of O.C.G.A. § 45-10-1 et.seq. (State Employee Code of Ethics, Conflicts of Interest, etc.).
The PCard may be used for:
- Equipment: Single units under the cardholder’s single transaction limit Equipment over $3000 (single unit) is considered a capital asset and should be purchased via the Georgia Tech E-Procurement System.
- Supplies, Materials, and Services may be purchased for less than the cardholder’s single transaction limit. The Institute will monitor activity for purchases for the same supplies, materials, or services from the same vendor so as not to exceed $9,999.99 per year unless competitively procured as detailed in Georgia Tech, DOAS regulations and BOR policies and procedures. Supplies and materials purchased may also include items purchased for resale.
- Purchases from Statewide and Agency Contracts are permitted.
- Conference Registration Fees for Institute personnel on official Institute business with the requirement that employees not request reimbursement for meals paid with the conference registration fees.
- Departments must ensure that conference registration fees for employees paid pursuant to this section are recorded as required by Institute Travel Regulations. Departments should require employees to capture the aforementioned registration expenses on the employee’s travel expense statement. Care should be taken to ensure that the employee clearly identifies those items paid with the PCard versus those items requiring reimbursement.
- Student food, student travel, and food for instructional uses is permitted as outlined in the Institute Business and Finance Manual (BFM) Sections 22.214.171.124 and 6.16 subject to the documentation requirements outlined in this policy. Additionally, food purchased for sponsored research use as approved by an Institutional Review Board (IRB) is permitted.
- Employee food may be purchased with a PCard only when an employee is participating in a Group Meal or an on-campus academic program/on-campus sanctioned event as described in BFM Section 126.96.36.199. Employees participating in off-campus events or in a travel status must request reimbursement.
- Repairs and maintenance are authorized for Institute vehicles. All costs associated with vehicle repair and maintenance must be reported in accordance with DOAS fleet management regulations using the Maximo system.
Note: Exceptions may be granted by the PCard Manager.
Prohibited Use of PCards
The PCard may not be used for:
- Personal items. The use of the PCard for personal expenditures is strictly prohibited. Cardholders who violate this rule must reimburse these funds and, if the violation is determined to be intentional, may be subject to both losses of employment and criminal penalties.
- Employee Travel expenses (lodging, transportation, meals).
Entertainment expenses (must be done as a reimbursement through the Foundation or GTRC).
- Alcoholic beverages or tobacco products.
- Motor vehicle fuel (except for authorized rental vehicles for official student program group travel).
- Professional services as listed in BOR Business Procedures Manual (BPM) Section 3.1.2 including certified public accountancy, architecture, professional engineering, doctors & registered nurses, lawyers, and veterinary medicine.
- Gift cards, funding the GT BuzzCard, stored value cards, prepaid cards, calling cards, gift certificates, or other cash equivalent items.
- Food except as authorized under BFM Section 188.8.131.52.(PCard cannot be used for purchases of bottled water, beverage/coffee service, snacks, or entertainment)
- Cash advances, cash refunds, or “store credit.”
- Memberships and/or fees to wholesale shopping clubs or “warehouse type” retailers.(e.g. Sam’s, Costco, Amazon Prime)
- Agency (funds held on deposit) or affiliated organization expenditures except as permitted for Study Abroad Programs as detailed in BPM Section 21.4.
Purchases made from units of the Institute. No internal Institute charges are allowed on the PCard. This includes, but is not limited to, OIT printing services, Library, and Parking. Please note: The PCard may be used for official Institute business at outsourced businesses including the GT Bookstore, VWR, and Aramark.
- Split purchases. Dividing one purchase into two or more to circumvent the single transaction limits and procurement requirements previously enumerated is not allowed.(more than one transaction to the same vendor on the same day which exceeds the single transaction limit of the cardholder)
- Sales tax. Sales tax should not be paid for purchases made from vendors within the State of Georgia using institutional funds. Institutional funds used to further institutional business purposes are not subject to sales tax as outlined in O.C.G.A. § 48-8-3 (8). Sales tax may be paid when required for vendors out of state.
- Please reference the Georgia Tech Reference Guide for PCard allowable and unallowable purchases found on the PCard page of the Procurement and Business Services website.
Limitations on Vendors
High Risk Vendors:
- Georgia Tech does not encourage the use of high risk vendors such as PayPal. If no other form of payment is accepted by the vendor, then the PCard High Risk Vendor Purchase Authorization Form (high risk vendors are listed on the form) must be completed, signed, and approved prior to each purchase and appended with the receipt as part of the accountable documentation for the PCard Statement. Violations of policy will be evaluated as noted in the Violations of Policy section of this policy.
- Cardholder must not make PCard purchases from vendors where the cardholder has a financial interest.
- Cardholder must not accept any gift or gratuity from any source when it is offered, or appears to be offered, to influence your decision-making regarding PCard purchases.
Each card will be assigned a default project ID, as identified on the PCard Request Form, to which transactions will be automatically charged. Charges must be redistributed to the appropriate general ledger expense account, as well as the appropriate Project ID if necessary, through the Institute’s web based PCard approval system, Concur. PCard transactions are loaded to Concur daily by the bank and remain available for review and redistribution for 10 calendar days before being posted to the General Ledger (GL). Changes identified after the transactions are initially posted to the GL may be accomplished by completing a CPC (Campus PCard) journal entry in the General Ledger, effective June 28, 2017.
Department PCard Coordinators are required to complete the annual PCard Training and Certification online training tutorial. Cardholders are required to complete the “PCard Cardholder Training & Certification” online training tutorial prior to receiving a card.
Cardholders are required to re-certify annually. Failure to re-certify will result in card suspension until the re-certification is completed. Departments must ensure that Approvers complete the “PCard Cardholder Training & Certification” online training tutorial initially and annually thereafter.
Georgia Tech's E-Procurement System Training
Cardholders and Pcard Cost Center Managers must complete the Georgia Tech’s E-Procurement System Pcard Training module prior to taking on either role.
Departments are responsible for ensuring Cardholders and Approvers are trained in internal departmental PCard policies and procedures. Departments should ensure that non-procurement personnel are acquainted with small value purchase procedures.
The cardholder should use basic security measures, as outlined below, to prevent unauthorized use and limit the potential for fraud.
- Sign the card as soon as you receive it.
- Always keep PCards and account numbers in a secure place.
- Safeguard the PCard as you would your personal credit card.
- Be aware of your surroundings when using the card.
- Monitor card activity in Georgia Tech's E-Procurement System.
Reconcile and submit monthly statements in a timely manner.
Lost or Stolen Cards
- Lost, stolen, or fraudulently used PCards must be reported to the Bank of America at 1-888-449-2273 as soon as possible after discovering the loss, theft, or fraudulent use. The cardholder’s approving official and the PCard Coordinator must also be notified. Evidence of fraudulent use may be requested to include transaction detail. Lost or stolen cards require card cancellation. Failure to report the loss, theft, or fraudulent use of the PCard may result in increased financial loss to the institution.
- The PCard Coordinator has the responsibility for communicating the information to PCard Administration.
Surrendering the PCard
- The Pcard is the property of the State of Georgia. The cardholder is to surrender the PCard to the PCard Coordinator upon request, retirement, termination, or transfer to another department.
- The PCard Coordinator should destroy (cut up) the card and notify PCard Administration via email to cancel the PCard.
Unless covered by an approved exception, every purchase requires two prior approvals prior to purchase. These prior approvals must be documented via a requisition form designated by Procurement and Business Services. If the purchase is approved, the cardholder may make the purchase. The signed requisition form must be appended to the receipt image prior to the submission of the statement for approval.
For each transaction, accountable documentation (i.e. a sales draft or receipt) must be obtained as proof of purchase. This documentation will later be used to verify the purchases shown on the cardholder's transaction in Georgia Tech's E-Procurement System. The documentation must contain line item description and line item pricing for the purchase. The documentation should include:
- Vendor name
- Transaction amount
- Date of the purchase
- Itemized list of items purchased
- Other information as required by the department
If a sales draft or receipt does not provide a description, the cardholder should write the description on the document. For items such as subscriptions and registrations, where a receipt is not normally generated by the merchant, a copy of the ordering document may be used so long as it contains a description and price. Copies or facsimiles of the original receipt may be acceptable if the original is not available.
If the documentation for a transaction has been lost, it is the cardholder’s responsibility to obtain a duplicate from the vendor. If a duplicate cannot be obtained, the cardholder should complete the PCard Receipt Replacement Form for to serve as the receipt. The PCard Receipt Replacement Form should contain the itemized information for the transaction, as listed above, and describe the cardholder’s attempt to obtain a duplicate from the vendor. PCard Receipt Replacement Forms may only be used on an exception basis. Excessive use of the form (defined as more than three times in one fiscal year), may result in suspension of card privileges.
Receipts are attached to each transaction in Georgia Tech's E-Procurement System by uploading the receipt and attaching it to the transaction.
Maintaining PCard Documentation
Documentation will be retained in accordance with records retention and fund requirements. For transactions posted on or after October 28th, 2017, this documentation will be housed in Concur and/or in Georgia Tech’s Imaging system. For transactions prior to 28 October 2016, statements with documentation must be kept by the Department
Original receipts must be kept by the cardholder or department for 1 year per DOAS Policy (rolling 12 months).
The documentation must be made readily available for review/audit if requested.
Using the PCard - Making the Purchase
The PCard can be used to make purchases over the counter, by mail, by fax, by telephone, or by Internet at any vendor that accepts Visa. The following procedures should be followed for PCard purchases.
Obtain Best Value
When accepting a PCard, the cardholder becomes an authorized purchaser for the Institute with specific responsibilities for expending public funds. The cardholder should ensure the purchase is appropriate and in accordance with all Institute and State rules and regulations. Additionally, PCard purchases must comply with requirements of the Georgia Procurement Manual concerning Order of Precedence and Competitive Bidding. When purchasing goods or services, the order of precedence that should be followed in selecting the appropriate vendor is: (1) Statewide Mandatory Contracts, (2) GT Agency Contracts, (3) Georgia Correctional or Georgia Enterprises, and then (4) Statewide Convenience Contracts and the open market.
After verifying the item is not available on a Statewide or Agency contract, the cardholder must utilize lowest cost based on requirements, quality, and availability to obtain the maximum value of each dollar expended.
Vary the suppliers to give fair treatment to all suppliers and to assure that the price obtained is reasonable. Transactions you make may be on behalf of Federal sponsors. Purchasing on behalf of government clients requires special sensitivity on the part of the purchaser to obtaining fair and reasonable prices, spreading purchases among many suppliers including small, small-disadvantaged, and women-owned businesses, and adhering to strict ethical conduct.
When using the PCard, the cardholder should inform the vendor that the purchase is for official State of Georgia purposes, and therefore, may not be subject to Georgia state or local sales tax. If requested by the vendor, cardholders must present an “AP - Sales & Use Tax Certificate of Exemption / Georgia Form”. The form is available online in the Forms section of the Business Services website at: http://www.procurement.gatech.edu
If sales tax is erroneously charged by the vendor, cardholders should make every effort to obtain a credit directly from the vendor. Documentation of attempts to obtain credits should be maintained with the transaction receipt by appending to the receipt. Please note: Sales tax may not be disputed through the bank.
Making the Purchase - Over the Counter
- Verify that supplier accepts the Visa. (Note: If not and it is a supplier you will need for future purchases, notify PCard Administration.)
- Provide the PCard for payment.
- Inform the clerk that the purchase is for official State of Georgia purposes, and therefore, exempt from state and local sales tax. The PCard indicates sales tax exemption, but cardholder should verify that clerk does not charge sales tax.
- Verify the dollar amount is correct and no sales tax has been included, then sign the sales draft.
- Retain your copy of the sales draft and receipt. If the copy does not provide a description of item(s) being purchased, the cardholder should write the description on sales draft or receipt.
- Follow PCard transaction/documentation process established by the department.
Making Purchase - Mail, Fax, Telephone, or Internet Orders
- Provide supplier with requested card information.
- Inform supplier that the purchase is for official State of Georgia purposes, and therefore, exempt from state and local sales tax.
Give supplier detailed shipping instructions. It is recommended that you have the goods shipped directly to your campus address (this would normally be the cardholder’s Billing Address). Please note: Goods should be shipped to official Georgia Tech business addresses only. Occasionally, researchers will be in the field at a sponsor’s site and will need the goods shipped to that location or the location specified, (never a home address). Shipments to an address other than a campus Georgia Tech address must be approved by PCard administration via email from the PCard Coordinator, with the cardholder’s supervisor’s approval included. This documentation should be appended to the receipt as accountable documentation.
- Retain documentation for purchase. Acceptable documentation includes: a copy of order form, copy of catalog page showing cost, or email/faxed order confirmation showing price along with packing slip, print out of the online order form, print out of the online order confirmation, or a print out of the e-mail confirmation.
Returning Purchases Made With PCard
If you determine that the material is defective or incorrect, notify the supplier that the item needs to be returned and request an address to ship to, and a Return Authorization Number. Request that the supplier process a credit transaction through the PCard. Document that the goods have been returned for credit and communicate information through proper channels within your unit. Ensure that the credit appears in Georgia Tech's E-Procurement System. If not, process the charge as a Disputed Transaction.
It is a good practice to keep original boxes, containers, and special packaging until you are certain you are going to keep the goods. Some items must be returned in the original packaging.
It is the cardholder’s responsibility to resolve discrepancies and ensure credits are received. When a cardholder discovers an incorrect amount has been charged for goods or services received, or a questionable purchase or transaction appears for verification in Georgia Tech's E-Procurement System, the cardholder must immediately seek to resolve the problem with the vendor. Any communications should be documented and the documentation including dates, persons involved, and a brief description of the problem should be either appended to the receipt or appended to the PCard Dispute Form.
If the cardholder is unable to resolve the problem with the vendor, a PCard Dispute Form should be completed and faxed directly to Bank of America at the fax number on the form. The PCard Coordinator should be notified of the dispute and a copy of the dispute form should be appended to the monthly statement. The cardholder should check the following month’s statement to ensure that credit was received. Please note: Disputes must be submitted within 60 days of the statement date.
Reconciling PCard Transactions
Pcard Transactions post to Georgia Tech’s E-Procurement System for verification on a daily basis. As the transactions post to Georgia Tech’s E Procurement System, the cardholder should review the transactions and attach receipts to the transactions. If the cardholder believes a transaction listed on the statement is incorrect, the procedures outlined in the “Dispute Transactions” section should be followed.
All PCard transactions must be reconciled (verified) in Georgia Tech’s E Procurement System. All transactions must be submitted for approval by the cardholder. At a minimum a PCard Cost Center manager must also approve each transaction.
Timeliness and Escalations:
The PCard Office will provide direction on how/when transactions should be reviewed, submitted and approved in the online system. This direction will be provided to ensure that transactions are fully verified and posted to the ledger within sixty days of the transaction post-date.
Cardholder’s cards whose online transaction verifications have not been submitted and completely approved within the 45 day time-frame may be suspended. Repeated non-compliance will result in card cancellation. Cards will be suspended/canceled as follows:
- First Offense - PCard(s) suspended 7 days or until written notification (email is acceptable) is received that the reconciliation package is complete and the cardholder is in compliance, whichever is greater. PCard Coordinator notified of suspension.
- Second Offense - PCard(s) suspended 30 days or until written notification (email is acceptable) is received that the reconciliation package is complete and the cardholder is in compliance, whichever is greater. Cardholder must re-certify by completing the on-line “PCard Cardholder Training & Certification” tutorial. PCard Coordinator and Department Head notified of suspension.
- Third Offense - PCard(s) cancelled. Department Head may request cardholder be re-instated after 90 days provided written notification (email is acceptable) is received that all reconciliation packages are complete. Cardholder must re-certify by completing the on-line “PCard Cardholder Training & Certification” tutorial. PCard Coordinator, Department Head, and OHR notified of cancellation.
Please note: In extenuating circumstances (such as extended travel, on leave, etc), departments may request that specific cards be exempted from suspension for a brief period.
Monthly review and approval of PCard transactions is required at the department level. The Department Head/PCard Coordinator will determine who the approvers will be for their departments.
Departments are responsible for reviewing all transactions to:
- Ensure the appropriateness of purchases and funds being utilized.
- Verify the completeness of documentation (detailed receipts, disputed transactions, approved requisition forms).
- Identify any policy violations and take appropriate action.
Business Services will receive a consolidated monthly billing statement from Bank of America for all Institute cardholders. The statement will be reconciled and processed for payment, in accordance with a plan on file in Business Services.
Business Service and Internal Audit Reviews:
Transactions will be reviewed online in accordance with plans on file in Business Services and Internal Auditing. Cardholder files will be reviewed in accordance with a plan on file in Business Services. Internal Auditing periodically conducts on-site compliance reviews in each department. These visits will be designed to:
- Review departmental records and record keeping practices
- Monitor adherence to policy guidelines
- Identify opportunities for process enhancements
- Offer “best practice” procedures
Results of these reviews will be used to enhance Georgia Tech’s PCard processes and will be shared with the Department Heads.
- Ensure internal procedures are in accordance with established Institute policy. Your department procedures may be more restrictive than Georgia Tech Policy but not less restrictive. Monitor department program for compliance – identify and address policy violations.
- Establish coordination procedures between Cardholders, Approvers, and Coordinators to ensure timely transaction reconciliation and accountable documentation.
- Establish redistribution procedures to ensure expenses are charged to the appropriate fund
- Develop procedures to ensure the responsible budget holder is required to verify charges to sponsored accounts are appropriate.
- Ensure documentation is retained in accordance with Institute policy.(A paper copy of the receipts is required to be kept for 1 year per DOAS Policy)
- Re-evaluate transaction and monthly (cycle) spending limits periodically.
- Review the ongoing business need for cards issued within the department annually.
Department Head/Dean/Vice President Responsibilities:
- Ultimate responsibility for a department’s program resides with the Department Head.
- Department Head may delegate operational responsibility to a PCard Coordinator, but delegation does not relieve the Department Head of program responsibility. This delegation of responsibility does not include the approval of new card requests.
- Designate unit program officials: Coordinators, Approvers, Cardholders
There are two types of approvers for PCart Transactions
- Requisition approvers review and sign off on requisitions prior to the purchase being made. Two approvers are required for the PCard requisition. Both signatures must be obtained prior to the purchase being made unless the purchase is made under and using the terms prescribed in an exemption approved by DOAS. Instructions and Exceptions can be found on the Procurement and Business Services website.
Georgia Tech’s E Procurement System Reconciliation Approvers:
- Review and verify assigned cardholder PCard purchases.
- Validate and attest that the report and the purchase receipts have been reviewed and are in compliance with Georgia Tech’s Policy.
- Verify completeness of PCard documentation including business purpose and detailed receipts.
- Ensure the requisition forms have been reviewed and are in compliance with Georgia Tech’s Policy.
- Complete the review by approving the report.
Georgia Tech follows the doctrine that the use of and responsibility for PCard procurements rest with the cardholder (employee). The cardholder is accountable for all transactions on their card. To reinforce the doctrine of cardholder accountability with departmental oversight of the PCard:
- The card is to be under the control of the cardholder.
- Card-sharing is prohibited. Cardholders may not lend their card or card number to anyone.
- Use of the card as a “departmental” or “checkout” card is prohibited.
- All cardholders are required to have training in the use of a PCard. Training deals with both card use and with delegated procurement responsibilities.
- PCard training specifically reiterates the cardholder’s responsibility and consequences of card misuse.
- Georgia Tech has implemented a web based interface, Georgia Tech’s E Procurement System, that:
- Allows cardholders or delegates the ability to review PCard charges and reallocate project numbers and general ledger expense account numbers in near real time.
- Provides online management reporting capability on all PCard activity.
Violations of Policy
Violations of rules governing use of PCards can be classified as minor or major. Violations are evaluated on an individual basis and any action taken is dependent upon the nature and frequency of the violation.
Minor Violations include honest mistakes, such as inadvertently using the wrong card; allowable purchases from Institute funds, but those which are not allowed on the P Card. Minor violations should be addressed as follows:
- First Offense - The department is to address the violation with the cardholder and provide additional guidance as needed. Actions taken should be documented in writing with a copy sent to the PCard Program Manager.
- Second Offense - PCard(s) may be suspended for 30 days. Cardholder must re-certify by completing the on-line “PCard Cardholder Training & Certification” tutorial. Department is to ensure that the PCard Program Manager and Department Head are notified.
- Third Offense - PCard(s) may be cancelled. Department Head may request cardholder be re-instated after 90 days. Cardholder must re-certify by completing the on-line “PCard Cardholder Training & Certification” tutorial. Department is to ensure that the PCard Program Manager and Department Head are notified.
Major Violations are those violations that indicate a willful intent to disregard rules that results in cardholder misuse (i.e. would include knowingly making personal purchases). The circumstances of the violations will determine the appropriate action, which could include termination of employment and criminal penalties. When cardholder misuse is suspected, the department is to immediately notify the PCard Program Manager and the Director of Internal Auditing.
- The PCard is to be suspended pending further review and investigation by Internal Auditing.
Georgia Tech employees can confidentially and anonymously report suspected PCard misuse to the Georgia Tech's Ethics Hotline, a secure and confidential reporting system at:https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
|October 2021||Purchasing and Procurement||Editorial updates|
|August 2020||Purchasing and Procurement||Updates due to E-Procurement System Update|
|May 2017||Purchasing and Procurement||State policy updates|
|July 2016||Purchasing and Procurement||Update to policy changes|
|March 2015||Purchasing and Procurement||Added additional compliance measures|
|July 2013||Purchasing and Procurement||Update to policy|
Procurement of Goods and ServicesProcurement of Goods and Services
This policy provides guidelines regarding the Institute’s process for procuring goods and services.
Purchasing authority is granted to the College and University Procurement Officer (CUPO) at Georgia Institute of Technology by the State Department of Administrative Services (DOAS), State Purchasing Division (SPD) and the Board of Regents (BOR). In accordance with O.C.G.A Section 50-5-69, SPD may, at its discretion, delegate purchasing authority to state entities to permit those state entities to make purchases on their own behalf.
In all procurement instances, the Order of Precedence should be followed as described in the Georgia Procurement Manual Section 1.3 unless the goods or services are exempt (see Georgia Tech Policy 184.108.40.206 Exempt Procurements) or procurement requirements have been waived.
The Georgia Tech E-Procurement System and the GT PCard are the Institute’s approved buying methods for procurements from external suppliers. Use of the appropriate buying tool must be in compliance with Institute policies and procedures. Learn more here. All procurement related questions should be sent to the procurement mailbox via ServiceNow.
Access to the Georgia Tech E-Procurement System may be contingent upon training and/or role responsibility.
All purchase requests must be approved by a financial and spend approver (or equivalent). GT employees may have more than one role in the Georgia Tech E-Procurement System; however, each requisition must be submitted and approved by at least two separate individuals.
The official Institute process for the procurement of goods and services is categorized into the following types unless identified in Policy 220.127.116.11 Exempt Procurements:
- Purchases within the scope and limits of a Georgia Tech or State of Georgia contract
- Non-contract purchases less than $25,000 which are delegated to the departments/units
- Non-contract purchases $25,000 or greater which require formal bidding or publicly posted sole source justification (must be done by the Purchasing Department)
- Exempt purchases defined in Policy 18.104.22.168 Exempt Procurements may at the discretion of the Purchasing Department, require bidding/sole source justification
A quote from the vendor/supplier should be attached to the requisition for all non-catalog purchases. For low dollar purchases of items found on vendors/suppliers websites, the Purchasing Department may accept alternate documentation in lieu of a formal quote. Please contact the Purchasing Department in these cases for acceptable alternative documentation.
This policy applies to all Georgia Tech faculty and staff members.
Georgia Tech E-Procurement System
Georgia Tech’s E-Procurement System is utilized to establish all purchase requests. Within the e-procurement system, a purchase request is called a requisition. Requisitions must be utilized for all purchases that are not allowable under one of the other purchasing methods (i.e. PCard, check request, or petty cash).
It is the responsibility of the Sr. Director of Procurement and Business Services and the Director of Purchasing to verify that purchases made under their purview are compliant with Georgia Tech, Board of Regents, State and Federal procurement policies and procedures.
To report suspected instances of ethical violations, please visit Georgia Tech’s Ethics Hotline, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
|1/2021||Purchasing Department||Updated to align with 2 C.F.R. § 200|
|12/2020||Purchasing Department||Policy updated to comply with Workday and consolidate information|
Procurement of Group Meals for Employees, Students, and Official VisitorsProcurement of Group Meals for Employees, Students, and Official Visitors
Allowable Funding Sources for Purchase of Food and Meals
Institutional funds include all funds to which the Institute holds title, such as student fees, auxiliary revenues, state appropriated funds and departmental sales/service, revenue. The funding source should match the supported program and participants. For example, student activity funds might be used to purchase water for a volunteer event sponsored by a student group. Sponsored funds may be used where specifically permitted in the sponsored agreement. Institutional funds cannot be used to purchase alcohol. Funds collected by the sponsoring institution for intra-institutional events are normally collected in and expended from an agency account created for that purpose.
Employees with responsibility for administering institutional funds and employees requesting reimbursement from institutional funds should ensure that funds are spent only for legitimate business purposes and not for the personal benefit of the employee or other individuals. The misuse of institutional funds may result in both employment termination and various civil and criminal penalties.
Food purchases and reimbursements for group meals/food should be charged to the appropriate spend category for meals within the Institute’s Financial System to ensure compliance with 1099-misc reporting. These accounts will be subject to special audit scrutiny, to ensure that such expenditures are infrequent, rather than routine.
SC727710 - Group Meals - Employees
SC727730 - Group Meals - Students
SC727720 - Group Meals - Non-employees
I. Georgia Tech Employee Business and Training Meetings using Institutional Funding
Under certain infrequent circumstances, employees may be required to remain at the work site during mealtime. Such circumstances include emergency situations such as natural disasters or significant public safety events, but may also include intra-departmental meetings or training sessions, where the meeting or training session continues during the meal and the employees are not permitted to leave the premises of the meeting site. The following standards will be used when deciding whether a meal may be purchased under this policy:
Group meals should be held only to facilitate the effective and efficient operations of the departments involved. For example, it may be that scheduling an intra-departmental meeting or training session is the most effective and efficient use of employees’ time given teaching schedules, other meeting commitments, etc. In this instance, requiring employees to participate in a meeting over lunch may be the best means available to get the required participants in the same place for the period of time required.
Group meals should only be provided in those instances where the meeting lasts for at least four (4) hours. A meeting less than four hours could generally be scheduled prior to or after a normal meal without significantly impacting employees on different work schedules. The PCard may be used to purchase meals for employees in this scenario.
Group meals held at the start and/or finish of a meeting are not eligible for payment under this policy. Purchase of a group meal is authorized solely as a convenience to the employer and in those instances where employees may not leave for a normal meal due to the time constraints associated with the meeting or training session. Those events not starting until the normal meal time should be delayed until after the normal meal time, or employees may bring employee-purchased food (“brown-bag”) to the meeting.
Authorized group meal expenditures are limited to the purchase of meals only and do not include snacks. Purchase of group meals are to be approved by the Director, Department Head, or his/her designee, prior to the date of the event (for non-emergency situations). The Food / Group Meal Event Documentation Form will be used to document event details and ensure compliance with this policy. All of the documents that were a part of the approval process should be submitted with the payment request.
Meal limits outlined in Georgia Tech Travel Policy "Meals and Incidental Travel Expenses", must be followed. Meal limits apply to the actual food and drink purchased for the meal. Set-up and delivery costs associated with the group meal are allowable and shall not be included in the meal limit calculation.
II. Food and Group Meals for Students, Volunteers, Visitors, and Participants Using Institutional Funding
The purpose of this section is to clarify those instances when food may be purchased for consumption by students, potential students, volunteers and employees using institutional funds. Food includes meals, beverages, snacks, etc., but specifically excludes alcohol as an allowable food expense.
An individual may be subject to different rules depending on the capacity in which they are participating in an event. For example, volunteers might include employees or students if the individual is operating in a capacity separate from their employee or student role. An employee or volunteer attending a student event in the capacity of a student would be considered a student. A student worker participating in an event while being paid as an employee would be considered an employee.
Note: Employees working additional hours in their own area, using work time to provide volunteer service, or otherwise participating in activities expected of employees, are not volunteers for the purposes of this policy.
III. Business Entertainment Meals and Alcohol Purchases using Agency Fund, Foundation or GTRC funding
Institute related entertainment charges and meals purchased for business development include business related breakfast, lunch or dinner, catered meeting, fund-raising or alumni event, etc. Entertainment, individual professional achievement/milestone receptions, holiday and end-of-year receptions, retirement events, faculty recruitment entertainment and extraordinary development activities must be processed directly through the GT Foundation or GTRC.
Business related entertainment charges may only be processed using the funding sources listed below:
- Custodial funds
- Routine development activity using Foundation or GTRC funds
Employee business and training meetings are not restricted by the meal per diem limits (see the Promotional Funding for Meals and Entertainment section for additional guidelines) or the 4 hour minimum meeting length that is required for use of Institutional Funds. The Food/Group Meal Documentation Form is required for all payment requests processed through the Institute’s Accounts Payable Team.
- Events using custodial or GTF funds do not require this form.
- Events processed directly through the GT Foundation or GTRC do not require this form.
Alcohol is an allowable expense only if specifically permitted by the funding source or for conference programs that specify receptions in the conference agenda and are funded by participant registration fees, such as the GT Executive Masters program and DLPE conferences.
Link to GT Foundation policy
GTRC policy requires a copy of the invitation or agenda and the number of guests.
Promotional Funding for Meals and Entertainment
Meals and entertainment to conduct official Institute business with external person(s) or for Institute functions with a clear business purpose should be reasonable and appropriate to the occasion. The selection of meal sites and/or catering vendors should be consistent with the image of Georgia Tech and not excessive regardless of funding source. While situations vary for business meals, a guideline maximum for meals involving external parties is $90 per person (includes beverage, tax, and tip). A guideline maximum for a required business meal involving only Institute personnel is $75 per person (includes beverage, tax, and tip). As a reminder, food or beverage (non-alcoholic) consumed at an event, provided the value is reasonable under the circumstances should not exceed the maximum allowable under USG Policy 22.214.171.124 - Gratuities. For meal expenses that may exceed the aforementioned guidelines, please discuss the appropriateness of the anticipated cost with your supervisor prior to the event. If GTF funds will be used, request approval consistent with the Expenditure of GTF Funds process here: https://policylibrary.gatech.edu/business-finance/expenditure-gtf-funds. If GTRC funds will be used, request approval by submitting the GTRC/GTARC Expenditure Request Form found at https://gtrc.gatech.edu/other-forms and include and explanation of the reasons for exceeding the per person threshold.The GT Alcohol Policy should be followed when alcohol is provided.
IV. Food and Group Meals Using Sponsored Grant/Contract Funding
Sponsored funding will be treated the same as Institutional funding for the purpose of food and group meal purchases.
As the Institute must comply with federal cost accounting standards, which require consistency in the treatment of costs, the Institute typically cannot use sponsored funds for business related entertainment since Institute state accounts do not specifically allow the purchase of business related entertainment. Therefore, discretion must be exercised when charging such expenses to sponsored restricted accounts. As such, the cost of purchased meals or food within 50 miles of the Georgia Tech headquarters will normally not be allowed as a direct charge to a sponsored restricted project because the Georgia Tech employee or trainee is not "traveling" and the cost is normally considered a personal expense. See below for special circumstances.
In special situations such as all day seminars or meetings when a food, beverage, or meal cost meets the three criteria of allowable, allocable and reasonable to the specified sponsored project, the PI may provide written justification of the business purpose of the expenditures and how they relate to the specific sponsored project including purpose of the meeting, list of attendees, a formal written agenda, and the beginning and end times of the meeting. To be allowable:
- Meal or food expenses must be included in the budget and approved by the sponsor.
- An agenda must be provided with the request
- Must specify each participant on the Food/Group Meal Documentation form
- Must be attended by non-Georgia Tech personnel. Meetings comprised of all Georgia Tech personnel are more often designated as an employee business meeting (See section I of policy).
- Meal per diem limits are imposed, unless sponsor provides an exception in writing.
Examples of allowable food charges:
Lunch and refreshments provided for periodic all-day meeting of collaborators on a program project (with formal agenda and participants from different locations).
A post-doc being recruited to fill an open position on a research grant. Meal may be charged to the grant since they are on official travel status.
Sponsored projects which specifically allow for business related entertainment
Examples of unallowable food charges:
Meals for lab personnel meeting weekly to discuss progress on the grant
PI has lunch/dinner with a colleague and discusses research
While these expenses may not be allowable on sponsored restricted accounts, they may be reimbursed from discretionary type restricted accounts or directly from the Georgia Tech Foundation.
V. Meals and Receptions Provided in Conjunction with Professional Education Conferences and Institute-sponsored Conferences and Camps
Meals and receptions provided for participants of conferences, workshops, and campus events that are funded by registration fees can be paid through the Institute using participant revenue funds if the meals are specifically noted on the conference agenda and/or registration material. Meal per diem limits are not imposed. The source of funds must be primarily external to the Institute. Campus training designed primarily for Georgia Tech employees must comply with the employee business and training meeting policy, section I.
VI. Meals for Employees, Students, and Guests on Official Travel
Employees who are on official overnight business travel, are eligible for meal reimbursement, according to Institute travel regulations. See Travel policy 6.4 Meal Allowances for detailed policy and procedures.
VII. Purchase of Bottled water, Coffee/beverage Service, and Office Snacks
Water and other beverages purchased as part of a group meal are allowable, but the cost of the beverage is rolled into the meal per diem limit. Beverage service and office snacks are not classified as group meals. Institute funds cannot be used the purchase of water and beverage service or snacks purchased for general departmental use. An allowable exception is water/hydration products that are used in compliance with OSHA or for safety related to environmental or workplace conditions. If Foundation funds are used, payment can be processed through Accounts Payable and the Food/Group Meal Documentation Form is not required.
Documentation Requirements and Compliance with Per Diem Limits at Group Events
The Food / Group Meal Event Documentation Form is used to provide documentation for all group meal purchases funded with institutional, sponsored, and Foundation funds processed through Accounts Payable or via the PCard. This form serves to document details of the event, participants, and the approval signature of the department head that is required for employee business meetings using Institutional funds. The original receipt or invoice must accompany all payment requests and/or PCard documentation.
While the meal per diem limits also apply to group events where food is purchased on a group basis of more than 15 participants (pizza parties, buffets, etc), departments are not required to document the actual numbers or names of participants; However, an estimate of the number of participants should be noted to certify that the appropriate per diem limits were followed.
In the event that an employee expends funds in excess of the authorized State of Georgia per diem (see "Meals and Incidental Travel Expenses"), then the amount spent in excess is considered a personal expense and is not reimbursable to the employee or payable to the catering vendor.
Meal per diem limits apply only to food purchased with institutional funds. Food purchased by outside organizations does not fall under the scope of this policy. However, employees must comply with the provisions of BOR Policy 126.96.36.199: Gratuities as it pertains to receiving gifts.
- Reimbursement for employees are to be claimed on an expense report and submitted through the Institute’s Financial System using the appropriate spend category for Group Meals
- Invoices should reference a valid GA Tech PO number and are to be submitted directly to email@example.com
- P-Card (only for group meal expenses that comply with meal per diem limits and employee meeting length restrictions. No bottled water, coffee/beverage service or snacks). Review PCard policy 188.8.131.52 for specific requirements.
Regardless of payment method, documentation of the purchase must be submitted as outlined above in support of the payment. Itemized, original receipts are required.
Payment for entertainment and extraordinary development activities, including the purchase of alcohol will be via the Foundation or GTRC Check Request process processed directly through the Foundation or GTRC. Original, itemized receipts are required in addition to the other documentation (invitation, agenda, etc) to support the request.
Payments made directly through Georgia Tech Accounts Payable or via the Pcard are exempt from sales tax. Payments made through the GT Foundation and GTRC are subject to sales tax.
Authorized Caterers for Events on Georgia Tech Campus
University System of Georgia policies grant exclusive rights to provide food services on campuses to Auxiliary Services. See the Catering Providers Policy for details regarding authorized caterers and policy details.
The Food/Group Meal Procurement form, and links to related policies are available via the Business Services Web Site: http://www.procurement.gatech.edu/payables/forms.
|4-2023||Accounts Payable||Editorial Updates to add information about USG Policy 184.108.40.206|
|09-2021||Accounts Payable||Editorial Updates|
|11-2020||Accounts Payable||Updated terminology and process to align with Workday implementation|
|09-2013||Accounts Payable||Update to policy|
|08-2013||Policy Library||Updated link to Procurement Forms|
Procurement of ServicesProcurement of Services
Payments for services to non-employee individuals and firms will fall into one of the following categories: honoraria, non-faculty instructors or lecturers, consultants, repairs and maintenance, temporary employment agencies, OSP subcontracts, stipends/awards and freelance service providers.
All payments (including expense only reimbursements) to individuals who are not US citizens or residents (green card holders) must comply with the Internal Revenue Service and Homeland Security regulations and requirements outlined in payments nonresident aliens non employees.
Employees may not receive payment for services through Accounts Payable. Consult OHR policies for supplemental pay options and Tech Temp employment options. Employees who have retired from the University System of Georgia may continue to work for Georgia Tech through the OHR Retired but Working program and compensation is through Payroll.
Reimbursable Expenses for Official Guests and VisitorsReimbursable Expenses for Official Guests and Visitors
Expense-Only reimbursements are for the travel of non-employees who do not have a contract for services, such as guest lecturers, student candidates, or interviewees for employment. In general, official guests and visitors must comply with the same travel regulations as employees.
See "Non-Employee Travel"
Reimbursements for Purchases Made Using Personal FundsReimbursements for Purchases Made Using Personal Funds
This policy outlines the expectation that individuals who have a procurement need will utilize the Institute’s procurement tools and processes to verify compliance with state, federal and Institute purchasing policies, and minimize institutional risk.
The Institute will reimburse employees for out-of-pocket expenses incurred during the execution of Institute business. Substantiation of reimbursable expenses must detail who incurred the expense, what was purchased, where the transaction occurred, the date the transaction occurred, and the business purpose of the expense.
Convenience and/or a lack of proper planning are not legitimate reasons to circumvent standard institute procurement processes. Use of personal funds, up to $500 per day or event, is allowed only when logistical or extenuating circumstances occur that preclude use of the Georgia Tech E-Procurement System procurement process or PCard. All reimbursements should be submitted within 45 calendar days of incurring the expense (unless approved by the Director of Accounts Payable or designee) and must be allowable by the funding source being charged. Allowable exceptions to this policy are noted below. Any other exception must be approved by the Director of Purchasing in advance. Any requests for reimbursements that do not meet the criteria specified in this policy may not be reimbursed.
Reimbursement for Purchase of Supplies, Equipment
Use of personal funds for the purchase of goods incurs additional cost due to sales tax and non-contract pricing, in addition to the loss of procurement data metrics necessary for strategic sourcing activities. Reimbursements for goods and supplies should only be made for small dollar items less than $500 where it is not practical or possible to make the purchase using standard institute procurement processes. Purchases over $500 that have not been approved by the Director of Purchasing may be classified as personal purchases and may not be reimbursed.
Reimbursement for Payments Related to Personal Services
Payments for personal services (consultants, temps, awards and prizes, rentals, royalties, and honoraria) must be processed through the Institute via the Procurement and Business Services’ procurement process, regardless of dollar amount, to ensure compliance with IRS and other federal regulations.
- Travel expenses for individuals
- Conference and meeting registration fees
- Cell phone/internet expenses (mobile and home use) Note: This does not include mobile device purchases
- Agency fund (as defined in the chart of accounts) purchases
- Study abroad expenses incurred during overseas activity
- Small dollar research participant payments (< $75/person) where check payment is not practical or possible
- Allowable restaurant meal purchase associated with an official GT conference/event/meeting
- Staff Tuition Reimbursement Assistance Program (STRAP) tuition reimbursements
- Campus Recreation Center (CRC)/Outdoor Recreation Georgia Tech (ORGT) reimbursements for trip leaders (Alaska, National Parks, etc)
- Allowable food/beverage supplies purchased at retail store
- Business center supplies/printing/shipping incurred while on travel status
This policy applies to all Georgia Tech faculty and staff members.
Reimbursement to Employees
Employees may be reimbursed via Expenses in the Georgia Tech E-Procurement System for supplies and allowable expenses up to $500. Reimbursement requests for the allowable exceptions, referenced previously, are allowable for amounts over $500, if approved by the unit financial approver. Reimbursements associated with program and participant research advances are processed via Expenses.
Reimbursements for employees that pay for meal expenses for official guests/visitors, or seek reimbursement for food/group meals, may also be reimbursed via Expenses in the Georgia Tech E-Procurement System. In that case, documentation requirements include the Food Group Meal Documentation Form, list of attendees (if fewer than 15), an agenda and an itemized receipt. Employees should not pay for travel-related expenses on behalf of other GT employees, due to state reporting requirements. In all cases, the receipt is to be the vendor's normal and customary receipt. The receipt must reflect the vendor's name, date of purchase, quantity, description, price of items purchased and the total amount paid.
Reimbursement to Non-Employees
Supplier Invoice Request (SIR)
Non-employees (including Students) will be reimbursed through Accounts Payable via the Supplier Invoice Request in the Georgia Tech E-Procurement System for approved reimbursements up to $500. Allowable exceptions outlined above apply to non-employees.
Petty Cash Replenishment/Reimbursement Request Form
Reimbursements for students, up to $250, may also be made through the Bursar’s Office petty cash process by using the Petty Cash Replenishment/Reimbursement Request Form.
|09/2022||Purchasing Department||Editorial updates.|
Updated to align with Workday implementation.
|09/2017||Purchasing Department||New Policy|
Short-term Instructors or Lecturers (Non-Faculty)Short-term Instructors or Lecturers (Non-Faculty)
Individuals providing a service to the Institute as Continuing Education speakers, OPTIONS instructors, CRC instructors, and other short-term instructors may be handled as independent contractors OR employees depending upon the number of payments involved and the "Classification of Independent Contractors Versus Employees" determination. For speakers and instructors employed through independent business firms, refer to the Consultants—(Individuals and Firms) section of the "Procurement of Service" procedures.
If the review of the questions under "Classification of Independent Contractors Versus Employees" (see procedure Purchase of Services -- Consultants –(Individuals and Firms)) indicates that the individual should not be classified as an employee, the payments may be processed through Accounts Payable on a Check Request Form. The individual will receive a Form 1099 at year end. If the instructor is a not a U.S. citizen or resident, refer to the "Payments to Nonresident Aliens (Non-employees)" procedure.
If the review of the questions under "Classification of Independent Contractors Versus Employees" (see consultants individuals and firms) indicates that the individual should be classified as an employee. Refer to Office of Human Resources Procedures for employment through the Tech Temp Program.
Subcontract ProcessingSubcontract Processing
Process to Request a Sub recipient Online-
Principle Investigator or Unit Financial Officers (Departmental Administrators)
- Visit OSP Contract System - https://webwise.gtri.gatech.edu/osp/sub/sitemap. Use your GT Kerberos Password or GTRI credentials to access the system.
- Under the OSP Contract Information System tab you will find a section for Sub- agreement Management. Click on “make a request for new sub-agreement.”
- To complete the "Request for a Sub-agreement" process you will want to have the following information ready:
-- Detailed budget
-- Statement of work (including any deliverables/reports)
-- Short narrative as to why you selected the subcontractor
-- Cost price analysis
- Query on the fund number you wish to issue the subcontract/consulting agreement under.
- After completing the required fields, click on “Submit to OSP.”
- Print a copy of the request; complete accounting section of the form and route for signatures.
- Route to PI for signature
- Route to xGRANTS@x.gatech.edu for department signature.
Sub recipient Monitoring- Principle Investigator or Unit Financial Officers (Departmental Administrators)
Unit Financial Officers (UFO’s) should assist PI’s in carrying out their sub recipient monitoring responsibilities. This includes:
- Reviewing invoices from sub recipients to ensure invoices are within the parameters of the sub-award budget, and questioning expenditures if necessary.
- Ensure that invoices are approved by the PI or his/her designee and submitted to Accounts Payable in a timely basis.
- Maintain copies of all invoices that provide evidence of the regular review of invoices by the PI. “Evidence” can be in the form of authorized signature by the PI or his/her designee, PI’s initials, e-mail communications, or notes of meeting between the PI with the department administrator.
- Maintaining documentation of monitoring efforts (copies of e-mail, phone log, etc.).
Process to encumbering Sub recipient in Buzz mart- Unit Financial Officers (Departmental Administrators)
Create “CONFIRMING ORDER/SUBCONTRACT” requisition cart:
- Select Vendor and choose appropriate address.
- Enter Descriptions details: Fund Number/Agreement number; PI name; Budget Dates
- Expense Codes: 753160- 1st $25K - 753180- over $25K
- NIGP Code: 95675- Scientific Research Services
- Release cart after ICOL notice has been received that sub agreement is complete. Procurement services cannot release encumbrance until agreement is active.
- Enter confirming order request annually for each funding year.
Subcontract Invoice Payments:
- Review invoices from sub recipients to ensure invoices are within the parameters of the sub-award budget, and questioning expenditures if necessary.
- Code invoices with purchase order number and expense code and send to GaTech PI for compliance verification.
- Sub recipient invoices must be sent to firstname.lastname@example.org for upload into Web Now queue for approval.
- Complete the Invoice Payment Approval Form (Worksheet) within the image in Web Now and route the invoice forward to the ‘Sub award Pay’ queue for processing. Subcontract payments are processed directly in PeopleSoft, rather than BuzzMart, so voucher detail will not be available in BuzzMart. Your electronic signature approval on the Web Now approval form certifies that the goods were received and/or services performed, so no additional ‘Receipt’ is required in BuzzMart and vouchers should not create a match exception.
- File all invoices with contract packet.
Subcontract Closeout Process:
- Audit invoices payment to verify that cumulative expenses submitted by subcontract matches total invoice payments.
- Ensure that final invoice is paid/submitted to OSP so that closeout procedures are initiated.
- Verify open encumbrance report and close out any remaining encumbrance if necessary.
Mark subcontract package “complete” and retain packet per file retention guidelines.
Unallowed Procurements or Sensitive ProcurementsUnallowed Procurements or Sensitive Procurements
A purchase that is contrary to the rules and regulations established by State Purchasing Division or Board of Regents shall be void and of no effect. Any official of a state entity or institution who willfully purchases or causes to be purchased any materials, supplies or equipment contrary to the rules and regulations will be personally liable for the cost thereof. If paid for from state funds, the amount may be recovered in the name of the state. (O.C.G.A. Section 50-5-79)
Procurements for Personal Use Using State Funds
It is unlawful to make procurements for the personal use of an employee. While it is difficult to define specifically all such goods and services, the following list includes examples of items which have been denied (by State Purchasing, other state agencies and Georgia Tech) on the grounds that the apparent end-use is primarily personal in nature:
- Holiday decorations and cards
- Cut flowers/plants
- Entertainment and recreational activities
- Alcoholic beverages
- Bottled water, coffee and beverage service, snacks
- Watches, groundbreaking shovels and other items to be granted as a donation or gratuity in favor of a person, corporation or association
- Dues to a Chamber of Commerce
- Clothing, such as tuxedos, used for commencement services or other personal use
- Personal moving expenses, other than authorized relocation expenses
- Airline club memberships
- Gifts and gift cards
Procurements by Employees
The Board of Regents (BOR) Policy Manual, Statement 7.7.2 states the following:
- Employee Purchasing: Absent a specific and approved exemption in state law or as approved by the Chancellor, USG employees shall not purchase goods or services for personal use through channels used in the purchase of goods and services for USG operations.
- Printing for Charitable Campaign
- In September 1992, the Chancellor’s Office of the Board of Regents made a ruling to allow the printing of the Charitable Campaign material from state funds.
- Animals for Research
- Animals procurements for research and teaching activities must have prior approval by the Georgia Tech Institutional Animal Care and Use Committee (IACUC)
- Radioactive Materials
- All procurements of radioactive materials/isotopes and any X-Ray generating devices are governed by the GT Radiation Safety Committee (GTRSC) to maintain compliance with the Georgia Department of Community Health or the license granted by the Georgia Department of Natural Resources. All procurements of radioactive material/isotopes and any X-Ray generating devices must be approved by the GT Office of Radiological Safety. The Office of Radiological Safety procedures and forms can be found at www.ehs.gatech.edu/radiation.
This policy applies to all Georgia Tech faculty and staff members.
If a purchase request/requisition has been submitted in the Georgia Tech E-Procurement System and the buyer ascertains that the purchase has already occurred or that work has commenced, the requisition may be subject to rejection and the purchaser required to follow unauthorized purchase procedures.