Contract Specialists manage contracting and compliance for Personal Service Agreements and for contracts that are sourced through the University’s Purchasing Department and CPFP. Contract Specialists are nonetheless glad to advise University Departments about “Non-Procurement Contracts,” which are contracts Departments source independently. However, it is the originating Department’s responsibility to ensure that its Non-Procurement Contract complies with applicable laws and policies.  Before issuing a Purchase Order for a Non-Procurement Contract, the Purchasing Department will require the originating Department to confirm that the originating Department has, and will continue, to meet its compliance responsibilities.

An overview of common compliance requirements is below.  Because contracting compliance requirements can be complicated and more extensive than outlined, it is generally advised that Departments submit requisitions for their purchases through the University’s Purchasing Department or CPCA instead of proceeding with a Non-Procurement Contract.

• Sourcing. Contracts must be sourced in a manner consistent with Section 10a-151b of the Connecticut General Statutes. For questions about sourcing, contact CPFP (for facilities and construction contracts) or the Purchasing Department (for other contracts).
• BOT Contract Submission and Reporting. University contracts must be submitted to the Board of Trustees (BOT) in accordance with the BOT’s contract authorization. In general, contracts (and amendments thereto) with a value of $1,000,000 or greater may be executed only with the BOT’s prior approval and contracts (and amendments thereto) with a value of $500,000 or greater must be submitted to the BOT for informational purposes following execution.  Please note the deadlines for BOT submissions.
• Required Provisions. State law and/or UConn policies require that certain provisions be included in UConn contracts. The most typical are the Standard Terms and Conditions. Other provisions may be implicated under certain circumstances, such as provisions regarding FERPA, HIPAA, or federal grant requirements.
• Certifications. State law requires that UConn collect Ethics Forms and a Non-Discrimination Certification with each contract. Please note that the Form 1 Ethics Form and the Non-Discrimination Certification must each be updated every 12 months. More information of State certifications is available on the contracting page of the Office of General Counsel.
• Employment Status. Vendors must be independent contractors. Contracts must not create an employee-employer relationship between UConn and the Vendors. Contracts can create employee-employer relationships inadvertently.  Such employee-employer relationships could have serious State and federal tax implications that could have significant financial repercussions for UConn. The Guidelines for Assessing IC Relationships should be consulted to help determine whether a Contract may create an employee-employer relationship.  The State Comptroller Memo 94-9 may also be consulted for guidance. The Office of Faculty and Staff Labor Relations should be consulted with any questions and for any difficult determinations.
• Signatories. Only authorized individuals may sign agreements on behalf of UConn. Refer to the UConn Attorney General’s page for the latest signature authority document.
• AG Approval. The Attorney General of the State of Connecticut requires that it approve all State contracts with a value of $25,000 or greater. The Attorney General also requires evidence of a vendor’s signature authority. More information is available on UConn Attorney General’s page.
• Conflicts/Ethics. The State Code of Ethics for Public Officials, UConn policies and procedures, and the UConn Code of Conduct forbid certain transactions that benefit a State employee in other than their official capacity. For questions about conflicts and ethics, contact the Office of Audit, Compliance and Ethics.

The Office of General Counsel is also available to assist Departments with some types of Non-Procurement Contracts.