To: Selected Administrators, Deans, Directors, Chairpersons, Administrative Assistants

Subject: Contractor Procurement Integrity

Effective July 16, 1989, Section 27 of the Office of Federal Procurement Policy Act (U.S.C. Title 41, Section 423) requires Columbia to submit a certification regarding procurement integrity for all competing contracts and modifications thereto which exceed $100,000 issued by a Federal agency. This certification must be made by all "officers, employees, representatives, agents, or consultants" of Columbia who are engaged in the preparation and/or negotiation of the proposal bid for contracts defined above.

The Office of Projects and Grants will have to certify for each applicable contract proposal for all people at Columbia directly or indirectly involved in the proposal. Usually these will consist of people in my office and those in the department or school office. However, for certain contract proposals there may be other Columbia people involved, such as those in the President's Office, the Provost's Office, and the Office of the Vice President for Government Relations and Community Affairs. In order for OPG to provide this certification for all parties involved in a particular contract proposal, the attached "Certification of Procurement Integrity" will have to be signed by all individuals concerned.

Those departmental representatives who have a direct involvement in a contract proposal will always be asked by OPG to complete and sign this certification. I ask that all other Columbia administrators who are sent this memorandum also be alert to the requirement to complete it and forward it to OPG, if assistance is provided for that which becomes a submitted competing contract proposal in excess of $100,000 which is sent to a Federal agency.

Please call the undersigned if you have any questions.

	James P. Lewis
	Director

Section 3.104-3 provides the following statutory prohibitions:

"During the conduct of any Federal agency procurement of property or services, no competing contractor or any officer, employee, representative, agent, or consultant of any competing contractor shall knowingly -

1. Make,directly or indirectly,any offer or promise of future employment or business opportunity to, or engage, directly or indirectly, in any discussion of future employment or business opportunity with, any procurement official of such agency;

2. Offer, give, or promise to of fer or give, directly or indirectly, any money, gratuity, or other thing of value to any procurement official of such agency; or

3. Solicit, or obtain, directly or indirectly, from any officer or employee of such agency, prior to the award of a contract any proprietary or source selection information regarding such procurement."

A. Listings of offerors and prices; (B) listings of bidders prior to bid opening; (C) source selection plans; (D) technical evaluation plans; (E) technical evaluations of competing proposals; (F) competitive range determinations; (G) rankings (not applicable to sealed bidding); (H) source selection board reports and evaluations; (I) source selection advisory board recommendations.

The law which mandates this is the Office of Federal Procurement Policy Act (41 U.S.C. 423), Section 27. This act requires that each "officer, employee, representative, agent, or consultant" involved with official contract negotiations with Federal p rocurement officials must certify in writing that, to the best of his or her knowledge and belief, he or she has no information concerning a violation or possible violation of section 3.104-3 of the FAR (see above); that any and all such information has been disclosed; and that he or she is familiar with section 3.104-3 of the FAR and will report immediately any information concerning a violation or possible violation of 3.104-3.

I hereby certify to the best of my knowledge and belief to the foregoing concerning the proposal:
__________________________________________________________________________.

Disclosure of information concerning a possible violation of section 3.104-3 (enter "none" if applicable): _________________________________________________________________

_____________________________________________________________________________

_____________________________________________________________________________

_____________________________________________________________________________ (attach additional pages if necessary).

Certification signature(s). All persons involved in the preparation or negotiation of the contract proposal must certify by signing below. This includes Principal Investigators; Department Chairpersons and Administrative Assistants; Budget Analysts and Clerks/Typists; and any agents or consultants retained to secure this contract.

OPG: 9/89

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