September 17, 2018
Drexel University and the Academy of Natural Sciences are required in their roles as federal government contractors to abide by the Executive Orders 12549 and 12689, 2 CFR part 180. This regulation restricts awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance activities.
To prevent unknowingly doing business with a vendor that may be suspended or debarred, Procurement Card (P-Card) transactions are not allowed to automatically default to a grant fund. If the P-Card cardholder wishes to reconcile transactions to a grant, it will be their responsibility to attach a PDF from the SAM database search stating the supplier in question is not suspended or debarred. It will be the responsibility of the P-Card cardholder's expense approver to verify this documentation before approval. If a supplier that has been reconciled to a grant fund is found to be suspended or debarred, it will be the responsibility of the department administering the grant to submit a journal entry to move the expense from the grant fund to an operating fund.
If a purchase is made on a P-Card and charged to a non-grant fund (i.e. unrestricted, designated, restricted) and subsequently needs to be transferred to a grant fund, the submitter must submit as backup to the journal entry in the Journal Entry Workflow, a copy of the PDF from the SAM database search stating the supplier in question is not suspended or debarred and the invoice supporting the purchase. Any journal entries submitted without this backup will be returned by Research Accounting Services.
Should you have any questions concerning this updated procedure as it relates to grants, please contact firstname.lastname@example.org. For questions on the P-Card, please contact email@example.com.