Navigating Service Procurements at UCSF: Critical Compliance Checks
Service procurement breakdown brought to you by Tina Stugart, Supply Chain Management (SCM) Procurement Supervisor and Laura Morsony, SCM Response Team Analyst.
Your Supply Chain Management (SCM) Strategic Procurement team wants you to navigate purchasing services efficiently and adeptly. Our team processes thousands of service requisitions a year. We know that efficiently navigating the policies and gathering the correct documents and approvals can be daunting, and we’re here to help. Throughout this series, we’ve addressed some of the most common points of confusion and contention in the purchasing process. Careful attention to detail will prevent delays and rework, and ensure that you get the service you’ve envisioned.
Here is a quick recap of critical compliance checks to consider prior to completing a SOW with your intended services supplier.
Covered Services
It is vital that your contracted supplier does not duplicate the skills and services offered by UCSF employees. (For more information, we have posted a complete guide to Covered Services on our website.) Departments must consult with HR or internal partners to determine if these services can be contracted or if internal hiring is necessary.
Securing exceptional approval to hire will require detailed documentation and a strong business case. If you are given the go-ahead to hire, complete the Pre-Hire Worksheet for Independent Contractors to help determine the employee or independent contractor status. Refer to Navigating Service Procurements at UCSF: Employment Policy Compliance for more information on how we distinguish contractors from employees.
IT Security
There is a lot of risk in information technology projects and software purchases. Some threats may not be obvious on the surface, such as contractor use of cloud storage and AI elements; others, like mishandling of data and system outages, are more obvious. Departments must review every detail of the covered service’s IT security implications before engaging in a project. If the project involves access to any UCSF systems or data, consult our website for more details on IT Security requirements.
Signing Authority
To minimize risk, the University has limited signing authority for most employees. The SCM website provides guidance on the limits of signing authority. If you have questions or concerns about documents or supplier terms, contact your department-assigned buyer.
Competitive Bidding
Purchasers are always encouraged to solicit bids when planning a purchase—regardless of the price point. (Keep in mind that any purchase over $100,000 crosses a mandatory review threshold.) Pairing quality work with fair pricing is a win for our entire enterprise.
Taking time to identify and review the competitive set will help you avoid costly mistakes. To learn more about competitive bidding visit our web page which details the process.
Source Selection & Price Reasonableness Justification (SSPRJ)
Pay careful attention to your source of funding (e.g., federal, state, private) and any stipulations that may impact your supplier choices. Federal and state law requires the SSPRJ be completed for:
- federally funded grant/cooperative agreement purchases greater than or equal to $50,000 (including tax and shipping),
- federally funded contract purchases greater than or equal to $10,000 (including tax and shipping), and,
- non‐federally funded purchases greater than or equal to $100,000 (excluding tax but including shipping).
Because this is a critical consideration, a template for SSPRJ is built into most of our BearBuy forms. (There is a stand-alone form available on the SCM website if necessary, though BearBuy is the preferred method.) More details about SSPRJ can be found on the SCM website, and there is targeted training on navigating source selection and price reasonableness posted in the University of California Learning Center.
Conflict of Interest Form
When making purchases, departments should avoid doing business with suppliers if there is a conflict of interest. If you are considering doing business with a supplier where there is a possible conflict of interest, the supplier needs to complete the Conflict of Interest Form. SCM will determine if the purchase can be made with the supplier.
Once you’ve considered these critical compliance checks, it is time to move forward with your service supplier. As soon as you’ve selected a supplier, they will need to register with UCSF and set up an invoicing and payment protocol. Once the supplier has agreed to our terms and conditions and arranged their payment process, SCM will provide guidance and support for your supplier throughout their engagement. Suppliers have customized support ticket queues and should use our supplier support link to submit an inquiry. If you or your supplier needs to revisit your agreement, consult your department-assigned buyer.
This multi-part guide will get you on the right path to securing an agreement with a service supplier. The SCM website has more details on service procurements and all aspects of creating agreements. We are here to make sure you undertake purchasing projects with clear documents expectations, firm supplier commitments, and minimal risk for all parties. We’re proud to support you in the work you do.
Questions about this article? Contact SCM Response Team