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Anti-Kickback Policy

The federal Anti-Kickback Act of 1986 prohibits those involved in government contracting from offering, accepting or attempting to accept inducements for favorable treatment in awarding contracts for materials, equipment or services of any kind. The act imposes criminal penalties on any person who knowingly and willfully engages in the prohibited conduct. 

A kickback is compensation of any kind directly or indirectly accepted by a faculty or staff member from a vendor, contractor or subcontractor who is competing for or doing business with the University for the purpose of influencing the award of a contract. Kickbacks can include:

  • Money
  • Fees
  • Commissions
  • Credits
  • Gifts or gratuities


Federal acquisition regulations require that the University follow reasonable procedures to prevent and detect violations of the Anti-Kickback Act. These procedures include:

  • Purchasing Conduct and Ethics, incorporating the National Association of Educational Procurement's (NAEP) Code of Ethics.
  • University of California Policy and Guidelines Regarding Acceptance of Gifts and Gratuities by Employees, (which applies Circular A110, Office of Management and Budget administrative requirements).
  • Internal and external reviews from the federal Office of Naval Research and the Circular A110 auditor to provide checks and balances.
  • Levels of authority for approving transactions established by University purchasing departments to detect any discrepancies or failure to follow required policies and procedures.



The act provides for the recovery of civil penalties by the United States from any person who knowingly engages in such prohibited conduct and from any person whose employee, subcontractor or subcontractor employee provides, accepts or charges a kickback.

To report kickback violations, immediately contact the Director of Campus Purchasing. All reports will be examined and, if warranted, investigated.

Content Courtesy of Blink, UCSD