Per Uniform Guidance, purchases of $10,000 or more that use federal funds require certain federal compliance checks at the time of purchase. University of Arizona Purchasing Policy 7.1 documents these requirements.
As written in Purchasing Policy 7.1, “acquisitions over the $10,000 micro-purchase threshold that are purchased on non-sponsored accounts may not be transferred to federal sponsored projects at a later date due to the additional Federal purchasing requirements required at the time of purchase. The transfer would only be allowable if the Federal purchasing requirements were followed at the time of acquisition.”
Therefore, Purchasing must be notified at the time of the Requisition document if a purchase of over $10,000 is being made from a non-federal account - including non-sponsored accounts and non-federal sponsored accounts - and any portion will later be transferred to a federal account. This will ensure Purchasing is able to complete all necessary compliance checks at the time of purchase.
An alternative to ensure the purchase exceeding $10,000 is compliant with federal requirements is to establish the federal account with a backstop when appropriate and make the purchase from the backstopped account. If the compliance checks are not completed at the time of purchase, Sponsored Projects Services cannot approve the expense transfer to the federal account.
Note: The term federal account includes both federal and sub-federal funding.
Please contact Purchasing at purchasing@fso.arizona.edu or Sponsored Projects Services at SPCS-financialcompliance@arizona.edu with any questions.
