Page 18 - AASBO EDGE 2020 WINTER

PROCUREMENT

BY BILL MUNCH, CPPO, CPPB

Federal Purchasing Tidbits That Will

Keep You Out of Trouble
Bill Munch

We all have a lot to be grateful for. We live in the best state in our regular formal procurement documents and cooperative
the country and the future looks bright. I hope to continue to keep contracts.
you updated on school district procurement happenings for many
years to come. Here are few tidbits to remember about federal purchasing:

Before I go off on federal purchasing, I wanted to let you know 1. Procurements over $100,000 must have all federal
that we are still waiting State Board of Education approval on certifi cations in the bid or RFP. If you utilize your own
revisions to our own Arizona School District Procurement district contract, it must have these certifi cations regardless
Rules. As I had promised in my last article, I will write about the of the dollar amount of the purchase. The new best practice
procurement revisions as soon as the State Board approves. So be recommendation is put federal language in ALL your multi-
looking for that article in the very near future (I hope!). term formal procurements so that you can use them for
federal purchases if federal dollars are being spent.
So at the end of October, on my way to the Annual ASBO
International Conference in National Harbor, Maryland, I had 2. If you utilize a cooperative contract in ANY amount, the
a stopover in Albuquerque, New Mexico, where I served as cooperative contract must have all federal certifi cations
keynote speaker and presented on cooperative purchasing best in the bid or RFP. 1GPA, Mohave and Choice Partners
practices for 200 public purchasing professionals. The day before are among the cooperatives that have done a great job of
my presentation, I got a harried phone call from the President of including federal language in their procurements. However,
the Chapter asking if I could “pinch-hit” for a session speaker on always “Trust, but Verify!”
federal purchasing. The speaker, who had gone ill, had his Power
Point completed and I was asked to present it as best I could. The 3. All federal purchases have certain federal certifi cations that
presentation was well received and so many federal purchasing need to be acknowledged by your vendor. No purchase is
issues were discussed by the 75 folks who attended the session. exempt from these limited certifi cations.
I tell you all this because my impromptu presentation reminded
me it was time to write another article about federal purchasing! 4. For Micro-Purchases (under $10,000) you are required to
rotate vendors and “spread the wealth” throughout the fi scal
Federal purchasing for your school nutrition programs is under year unless you get three quotes each time.
heavy scrutiny by the Health and Nutritional Services at the
Department of Education. Your district will be audited every 5. The feds can withhold or “take back” federal dollars for
three years to ensure compliance with federal procurement non-compliance. There are even documented cases where
guidelines. Federal laws and regulations specify the methods the feds have taken money away from areas declared to be
that school districts must follow to properly procure goods and a “national disaster” by the President. If you violate federal
services (7 CFR 200 and 210) and the Department of Education procurement, it could cost your district dollars!
is required to ensure that school districts comply with the
applicable regulations through audits, administrative reviews, These little tidbits just scratch the surface. If a federal procurement
technical assistance, training, guidance materials, and by other question comes up, email me. If I don’t know the answer, I
means. (7 CFR 210.19(a)(3)). Here is the link to the regulations: promise not to make one up. I will fi nd someone who knows the
https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/ answer and do my best to keep you on the compliance path. If you
Title02/2cfr200_main_02.tpl need procurement assistance or training in your district, contact
me. That’s why I am the Procurement Compliance and Training
While the Department of Education audits your food service Offi cer for Valley Schools. It is my hope this article gave you
purchases, federal requirements apply to ALL purchases using some things to keep in mind as you make federal purchases for
federal dollars. Even though the federal quote requirement your district. Go Procurement Go!
thresholds are the same for purchases from $10,000 to $100,000,
there are additional federal clauses that should be added to
federal purchases. For purchases under $10,000 (the feds call Bill Munch, CPPO, CPPB is the Procurement Compliance
these Micro-Purchases), federal provisions require you to and Training Offi cer for Valley Schools Management Group,
rotate vendors unless you obtain three quotes. It is important to recipient of the 2018 AASBO Bill Lovett Award, and the 2016
recognize that formal federal purchases over $100,000 require NIGP National Purchasing Manager of the Year. He may be
additional federal procurement clauses not always found in reached at: bmunch@vsit.org.

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18 THE EDGE WINTER 2020