Information for Departments
Departmental Purchasing Overview
As an institution operating under the Higher Education Restructuring Act of Virginia (Restructured Higher Education Financial and Administrative Operations Act), the University has been granted additional autonomy in procurement while maintaining accountability to state laws and public trust. Our procurement procedures empower departments to efficiently acquire goods and services necessary for ongoing operations while complying with the institution’s Management Agreement with the Commonwealth. As such departments have been delegated the Authority to make their own purchasing decisions under $10,000.
Departments should first consider vendors under existing university, state, or cooperative contracts. When competition is applicable, departments are encouraged to seek quotes from certified small, woman-owned, and minority-owned (SWaM) businesses in alignment with Commonwealth and institutional goals. Regardless of the method, purchases must represent fair and reasonable pricing and deliver the best value to the University.
Purchasing Thresholds and Process Guidance
Purchases up to $10,000
- Price competition is not required but is encouraged.
- Consider using a certified SWaM vendor when available.
- Determine a firm, fixed price inclusive of all charges (handling, shipping, taxes, etc.).
- Enter the order as a HokieMart requisition.
- Requisitions valued at $10,000 or less will automatically convert to a purchase order once all appropriate departmental and commodity specific approvals have been obtained in HokieMart.The purchase order can be sent directly to the supplier.
Purchases above $10,000
- Require review and action by the Procurement Department.
- May be routed through additional HokieMart approval steps based on funding source or purchase type.
- Will be converted into purchase orders by Procurement after applicable competition or sole-source justification requirements are met, in accordance with the institution’s delegated authority.
Department-Level Transactions The following transactions may be processed directly by departments under delegated authority:
- Purchase Orders up to $10,000
- Maintenance Agreements up to $10,000
- P-Card Transactions up to $2,000
- Should be used only when a HokieMart order is not feasible.
- Must comply with P-card policy and restrictions.
- Purchases at Any Value Against an Established Contract
- Must follow the terms and conditions of the contract.
Exceptions to Departmental Delegation Certain purchases are exempt from competitive procurement requirements but are still subject to university signature policy and internal controls. For a full list of these exceptions, refer to the Procurement Department's Exemptions Page.
Compliance Reminder All departmental transactions are subject to audit and must comply with the University’s procurement policies. Adherence to these requirements ensures responsible stewardship of public funds and supports the University’s continued autonomy.
The Ethics section of the Virginia Public Procurement Act (VPPA) outlines the conduct of public employees in procurement transactions.
Section 2.2-4369 of the Code of Virginia states:
"...no public employee having official responsibility for a procurement transaction shall participate in that transaction on behalf of the public body when the employee knows that:
- The employee is contemporaneously employed by a bidder, offeror or contractor involved in the procurement transaction; or
- The employee, the employee's partner, or any member of the employee's immediate family holds a position with a bidder, offeror or contractor such as an officer, director, trustee, partner or the like, or is employed in a capacity involving personal and substantial participation in the procurement transaction, or owns or controls an interest of more than five percent; or
- The employee, the employee's partner, or any member of the employee's immediate family has a pecuniary interest arising from the procurement transaction; or
- The employee, the employee's partner, or any member of the employee's immediate family is negotiating, or has an arrangement concerning, prospective employment with a bidder, offeror or contractor."
In addition, public employees shall not solicit or accept gifts from bidders, offerors, contractors, or subcontractors. Give-aways at trade fairs which are available to all participants and are generally acceptable.
A conflict of interest may be actual or potential. It most often occurs when an employee has a financial interest in a private firm which is doing business or is attempting to do business with the university. A conflict of interest can also result in a situation where the employee's immediate family member has the financial interest.
The following policies provide detailed guidance regarding what is considered a qualifying financial interest and the disclosure procedure.
- University Policy 13010 - Individual Conflicts of Interest and Commitment
- Conflict of Interest and Commitment
The most common situation where a conflict of interest occurs is with related-party suppliers. This is a situation where a Virginia Tech employee has an immediate family member who has a financial interest in a private business and sells to the university. It is not a conflict if the business sells to other state agencies. The violation occurs if they sell to their immediate family members employing agency.
Example: Mary works in the Facilities Department at Virginia Tech. Her husband John owns a carpentry business. Under the provisions of the Conflict of Interest Act, John cannot sell his services to Virginia Tech. John can sell his services to Radford University or other state entities, just not to where Mary works. If John sells to Virginia Tech, the university will be unable to pay the invoice and Mary will be in violation of the Conflict of Interest Act.
As with most laws, there are some exceptions to the basic rules outlined above. If you have a potential conflict, our advice is to visit the Legal Office and get an informed opinion.
Each of us wants to do the right thing and to avoid causing any embarrassment to ourselves, our department or Virginia Tech. For this reason, it is important to know the basic standards of conduct guidelines.
As public employees, we are all bound by standards of conduct which prohibit the acceptance of gifts, gratuities, favors or rewards from vendors, contractors and persons seeking to do business with the university.
Perceptions. What this subject boils down to is this question: could this situation create the perception that the contractor is unfairly influencing a public employee? For this reason, employees involved in purchasing decision making or contract administration are encouraged to adopt a very strict set of personal standards regarding the acceptance of anything from a vendor. Avoiding the acceptance of gratuities enables us to maintain our freedom from influence and to exercise truly independent judgment.
Here are some comparison factors that might help you evaluate situations:
- Is the event being held on-campus or in a private location? (On-campus is more open and more logically associated with work)
- Is it work-related, such as training, or is it purely social? (work-related training and learning is understandably of more benefit to Virginia Tech than a social event).
- Is it open to attendees from other organizations or the public, or is it focused only on Virginia Tech? (There is more safety in numbers. It is generally more permissible to participate in open events than in ones that are closed or give the perception of being directed at a very precise group).
- Do you perceive it to be modest in cost, or expensive and elaborate? (The more modest the event, the better).
- Are you involved in some way with the decision to buy the goods and services offered by this contractor or the administration of this vendors contract? (If you are a decision maker, there is a much greater likelihood of creating the impression of improper influence).
Remember, when in doubt or uncomfortable, the best course of action is to politely decline. Other factors to consider are prior employment or having a close personal relationship with the supplier. Either of these situations could create the perception of influence. Legal Counsel can assist in evaluating these matters on a case by case basis.
Standards of Conduct
All gifts to the university are received through the Virginia Tech Foundation. University Policy Number 12115, Reporting Gifts-in-Kind to the University, notes that only officials of the Virginia Tech Foundation are authorized to sign contracts, licensing agreements, purchasing documents, or other contractual documents that pertain to gifts. After Receipt of the gift, the Virginia Tech Foundation will normally transfer the title of the equipment to the university and the equipment will be entered on university property records. Gifts-in-kind are defined as equipment, tools, software, paintings, furniture, and other items that could be determined to a value.