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Follow EDGAR Under a separate federal program, procurement methods for
Continued from page 27 more than $100,000 include sealed bids, competitive proposals,
competitive proposal qualifications based for architects and
engineers only, and sole source non-competitive proposals.
The current limit on purchases that qualify is $10,000. “You can do sole source under federal rules,” Williams said.
Williams explained: “A micro-purchase is essentially a one- “There is some verbiage that allows you to do that – or not.”
and- done purchase. For example, if you were going to make a Regarding contract cost and price, Banuelos emphasized
software purchase with federal dollars, a micro-purchase might that the school district must perform a cost or price analysis
be the way to go. However, if you buy cafeteria plates multiple in connection with every procurement action in excess of the
times, maybe quarterly, you might not want to do a micro simplified acquisition threshold. “Do this before you ask for
purchase, unless you planned on buying from four different bids,” she said. “You have to have some kind of analysis.”
entities. If you only have two vendors, you would have to go Williams said that in the past he has checked vendors’ five-
back and forth, from one to the other. With a micro-purchase, year history and several had no price increases. “I can evaluate
you have to spread the wealth among the multiple vendors that whether a major increase is due to some event,” he said. “Most
you have.” of my contracts blew up during the last twelve months due to
A school district has to show that it made a good-faith effort tariffs on metals – copper and aluminum. I had vendors who
to spread the federal money around, Williams said. could not hold prices.”
Taking it a step further, if there is only one vendor nearby, Williams said he limited the increases he paid to the higher
but there are several others hours away, you could step up costs vendors experienced because of tariffs.
from a micro-purchase to a simplified acquisition threshold, Contract provisions for non-federal entity contracts under
Williams said. federal awards include such issues as equal employment
That regulation states: “Simplified acquisition threshold opportunity, David-Bacon Act, Contract Work Hours and Safety
means the dollars amount below which a non-federal entity Standards Act, Clean Air Act, and debarment and suspension.
may purchase property or services using small purchase General procurement standards provide that a “non-
methods … in order to expedite the purchase of items federal entity must use its own documented procurement
costing less than the simplified acquisition threshold.” procedures which reflect applicable state, local and tribal laws
The current limit, adjusted periodically for inflation, is and regulations, provided that the procurements conform to
$150,000. applicable federal law and the standards identified in this par.”
Referring back to a micro-purchase, Williams said, “I On the question of whether school districts can use IGAs,
recommend that you find multiple vendors, get quotes, and Williams said, “Yes. They are encouraging IGAs. Just follow
you’re covered.” EDGAR.”
He also recommended; “Stay compliant with both the
federal and state side. If it’s not a one-and-done purchase, get Bobby Williams can be reached at: blwilliamsii@mpsaz.org
quotes and move on without stress. You don’t want to get in
trouble with the auditors.” Lourdes Banuelos can be reached at: lourdes.banuelos@tuhsd.org

28 THE EDGE | SPRING 2019