Interim Purchasing Policy

Less Than $5,000 and not on the Restricted Category List

For purchases less than $5,000 and not on the restricted category list, authorized purchasers may identify and select suppliers subject to provisions of this policy. If the vendor is on the College’s preferred or contracted vendor list, it is required the requestor purchase from this source and no documentation of purchase selection is required. 

The procurement card (or P-Card) should be used to pay for purchases when such payments:

a) are recurring payments less than $75,

b) one-time purchases, or

c) travel (which is subject to the College’s travel policy).

Cardholders are prohibited from "splitting" purchases that exceed $4,999 into multiple procurement card charges, and are required to adhere to the College’s procurement card policy.

All other purchases should be paid through accounts payable.

Purchase orders are available, but not required. If there is a written contract or agreement, it is required to be submitted to the contracts@holycross.edu for review and signature by an authorized signer.

Between $5,000 and $24,999 and not on the Restricted Category List

A competitive bidding process is recommended, but not required, for purchases over $5,000 but not exceeding $24,999 that are not on the restricted category list. If the vendor is on the College’s preferred or contracted vendor list, it is required the requestor purchase from this source and no documentation of purchase selection is required. 

All payments must be made through accounts payable.

Purchase orders are available and required if there is no written contract or agreement. If there is a written contract or agreement, it is required to be submitted to the contracts@holycross.edu for review and signature by an authorized signer.

Purchases Between $25,000 and $249,999 and not on the Restricted Category List

A competitive bidding process including a minimum of three quotations is required for purchases over $25,000 and below $249,999. This process may be managed by an authorized purchaser. 

Rebidding Requirements

As contracts reach the end of their term, the vendor relationship should be reviewed. If a vendor was selected based on a competitive bidding process within the past 5 years, the department may make a determination to not rebid if the following criteria are met: a) work performance is satisfactory, b) price adjustments are reasonable and consistent with industry standards, c) the nature of the contracted work is similar in nature in terms of scope and cost, and d) the increased term will not exceed three years.

If work is not rebid, written justification for this decision should be attached to the new contract, agreement, or purchase order when submitted to contracts@holycross.edu for review.  

If a good or service is subject to a competitive bidding process and has not been part of a process within the past 5 years, a competitive bidding process is required unless expressly approved by the Purchasing Department in writing. A written justification, including the Purchasing Department’s approval, is required.

All payments must be made through accounts payable.

A contract or purchase order is required for all purchases. All contracts must be submitted to contracts@holycross.edu for review and signed by an authorized signer. When contracts are submitted, documentation of the three quotations reviewed as part of the competitive bidding process must be attached. If there are limited sources of supply or the low bid is found unacceptable because of some factual circumstance, the authorized purchaser should write a clear, concise and factual justification for not accepting the lowest bid by using the Sole Source/Higher Price Justification Form. If the requestor is unable to identify three suppliers, the Purchasing Department should be contacted to assist in identifying additional suppliers.

Purchases Over $250,000 and not on the Restricted Category List

All purchases over $250,000 require the requestor to contact the Purchasing Department to conduct a formal bid process. The Purchasing Department will work collaboratively with the requestor to facilitate this process for the requestor's review and evaluation.

A contract and purchase order are required for all purchases. All contracts must be submitted to contracts@holycross.edu so that they can be reviewed and signed by an authorized signer. 

All payments must be made through accounts payable.

Policy Exception for Emergency Acquisitions

The President or Treasurer (or Assistant Treasurer(s), if delegated) may approve spending outside of this policy if, in their professional judgment, it is an emergency situation in which there is no time to seek approval and there are College resources to support the action.

Holy Cross contracts for certain commodities and services on a college-wide basis with particular suppliers for the best quality, service and price.  Departments are expected to make use of the contracted suppliers whenever possible. Please refer to the on-line Preferred Vendors List below for the applicable contact information.  Once accounts are set up, Departments should contact the preferred vendors directly for these purchases. Click here for a list of local preferred hotels.

Restricted Category List (No Dollar Limits Apply)

Some categories of goods or services involve unique risks or compliance requirements and always require centralized review, including potential involvement of multiple offices. These categories are considered “restricted categories” and a contract or purchase order is always required regardless of the dollar amount.  The following categories are considered restricted categories:

• Software
• Hardware  
• Agreements requiring a certificate of insurance
• Transportation agreements
• Speaker fees and honorarium
• Employment Agreements
• Settlement and Release of asserted claims
• Professional Services, Consulting and service agreements with an individual (as opposed to an entity) or an entity wholly owned by the individual providing the service unless using a standard PSA after meeting independent contractor screening list
• New student agreements (other than standard form)
• Financing contracts - loan agreements, notes, credit or line of credit agreements, and other agreements to borrow money
• Real estate - leases, rental agreements, lease-purchase arrangements, agreements for land, buildings or other structures, space in buildings, housing, apartments, parking (other than standard form)
• Contracts for the construction, renovation or repair of any building, facility, grounds, or physical plant equipment
• Gift/donation agreements (other than standard forms)
• Investment agreements (including investment management agreements, custodial agreements, investment advisor agreements and investment vehicles)
• Federal contracts and subcontracts
• Contracts with international entities or individuals (other than standard form Study Abroad agreement)
• Contracts with exclusivity provisions
• Intellectual property agreements and licenses (other than standard forms)
• HIPAA, GDPR, other international PII obligation
• Acquisition of legal services
• Out of ordinary course or purchases with unique risk factors (e.g., helicopter acquisition)
• Contracts directly implicating health and safety or new regulatory obligations

For the Commodities listed below, please contact the responsible Department directly prior to purchasing items from an outside vendor. They will either assist in ordering the item or provide you with the approval to use Holy Cross preferred vendors.

Sole Source and Higher Price Purchases

In cases where the purchase is limited to a single or sole manufacturer or supplier, the College may waive competitive bidding requirements if there is an approved Sole Source/Higher Price Justification form on file. 

A Sole Source Justification Form documenting the situation that makes it impractical to obtain competitive bids is required for each purchase subject to competitive bidding requirements for which sole source is being sought. The Sole Source Justification Form must be completed by the requisitioning department. Final authority in determining whether an item or service may be purchased from a sole source rests with the Purchasing Department.

The Sole Source/Higher Price Justification form should be submitted, with the accompanying bids/quotes, when the lowest priced bid/quote was not used. Please include a clear explanation describing the contributing  factors and reasoning for not selecting the lowest priced bid/quote. Final authority in determining whether an item or service may be purchased from a higher priced source rests with the Purchasing Department.

Examples of sole source justification include: