Procedures for Reporting Purchasing Accomplishments under Federal Contracts

Procurement Manual
Section V

As a federal contractor, the University is required to submit periodic reports to the federal government of its accomplishments in purchasing and subcontracting with small businesses. Reporting is required for all federal contracts over $500,000 and for EPA awards, contracts, grants, and cooperative agreements of any dollar value. At the time of award, the school or department develops a subcontracting plan. A required element of the plan is to establish goals on the amount of purchases to be expended with small, minority, women-owned, veteran-owned, and HUBZoned businesses, as appropriate. Reporting progress toward achieving the goals is accomplished by using the Standard Form (SF) 294 (Federal Contracts) and EPA Form 5700-52A.

The award's Principal Investigator (PI) is responsible for completing the EPA form annually and the SF 294 form semi-annually. Form SF 294 is available at http://www.gsa.gov/Portal/gsa/ep/formslibrary.do?viewType=DETAIL&formId=2D5E310C4C549B2E85256A72004B1364 and the EPA form at http://www.epa.gov/osdbu/pdfs/5700_52a.pdf.

FORM 294-Filing Instructions

When complete, the form should be reviewed and approved by department signatories and submitted directly to the sponsoring agency. A copy should be kept with departmental files. This form is filed twice yearly, in April and October, and at closeout.

For existing contracts that require 294 reporting, an Action Memo will be generated by the Office for Sponsored Programs.  New contracts will be evaluated at the time of award and 294 reporting requirements will be noted in the initial Action Memo.  Timely submittal and record-keeping is the responsibility of the Principal Investigator and the department. 

EPA form 5700-52A-Filing Instructions

When complete, the form should be reviewed and approved by department signatories and submitted directly to the sponsoring agency. A copy should be kept with departmental files. When required for universities, form 5700-52A should be submitted annually for the period ending September 30th.

For existing contracts that require EPA reporting, an Action Memo will be generated by the Office for Sponsored Programs.  New contracts will be evaluated at the time of award and EPA reporting requirements will be noted in the initial Action Memo.  Timely submittal and record-keeping is the responsibility of the Principal Investigator and the department. 

The Procurement Management team is available to assist the Principal Investigator with the identification of vendors that meet specific minority, women owned, small business or other requirements. Contact PMD at 5-5401.

For a listing of minority, women-owned, and small business enterprises, visit the PMD website at http://vpfweb.harvard.edu/ofs/procurement/add_add.shtml#minority.