Page 28 - The Edge - Fall 2018

District Procurement Compliance over $100,000 require additional federal procurement clauses
Continued from page 26 not always found in our regular formal procurement documents
and cooperative contracts.
The School Facilities Board (SFB) is charged with adopting
Documenting three quotes from a cooperative or multiple rules establishing minimum school facility guidelines, assessing
cooperatives in the form of a written determination and school buildings against these guidelines, and providing monies
justifying the selection based upon the quotes obtained would to bring the buildings up to the guidelines. In providing monies,
certainly comply with the requirement. However, there is no SFB has established procurement guidelines that can be more
specific requirement to obtain quotes from cooperatives and restrictive than the School District Procurement Rules.
should only be considered as a best practice recommendation. Districts should work with their liaisons and review the
The most important thing is to provide a written justification on procurement decision matrix on the SFB website to ensure
just how your district chose the particular cooperative vendor compliance with procurement requirements imposed by the
contract. The State Board of Education is working on a specific SFB. Failure to comply with SFB procurement requirements can
rule that should give us further guidance. result in funding being denied. The SFB is continually working
I serve on a Cooperative Purchasing Committee with the toward developing procurement procedures that will ensure
Arizona Capitol Chapter of National Institute of Governmental the best possible expenditure of funds. So it is important to
Purchasing (NIGP) and we keep in touch with your liaison
have been working on best on all procurement issues and
practices and justifications for While most people in Arizona questions and review the website
cooperative purchases for years for updates regularly.
– our work is very reflective of recognize the budget bill that gave We all know that school
the new rationale determination district procurement operates
requirements. You can find our teachers a much needed raise, in a fish bowl. School district
some great recommendations procurement is audited to
for justifying cooperative that bill also clarified and added an even higher level than
purchases and information on state agencies, cities, counties
specific cooperatives that may procurement requirements to and higher education in Arizona.
be available to schools districts When “non-compliance” is
at: https://www.aznigp.org/ school districts. The bill reiterated discovered, the media will not
insidepages/contracts. I am hesitate to report on it. As I travel
also happy to work with any conflict-of-interest requirements around the state and work with
districts to help them navigate school districts on procurement
best practices to comply with this and the personal and criminal matters, I always stress that,
new cooperative procurement “Procurement Compliance is Job
requirement. liabilities for violations of the 1.” OK, I kind of took that from
Federal purchasing for your Ford and I drive a Chevy. But,
school nutrition programs is procurement rules. it has never been truer than it is
under scrutiny by the Health today that compliance is the most
and Nutritional Services at the important job for an Arizona
Department of Education. Your school procurement official. It is
district will be audited every three years to ensure compliance getting a bit more complicated, but keep networking with other
with federal procurement guidelines. Federal laws and districts and look to AASBO for help.
regulations specify the methods school districts must follow to If a procurement question comes up, email me. If I don’t know
properly procure goods and services (7 CFR 200 and 210) and the answer, I promise not to make one up. I will find someone
the Department of Education is required to ensure that school who knows the answer and do my best to keep you on the
districts comply with the applicable regulations through audits, compliance path. If you need procurement assistance or training
administrative reviews, technical assistance, training, guidance in your district, contact me. That’s why I am the Procurement
materials, and by other means. (7 CFR 210.19(a)(3). Compliance and Training Officer for Valley Schools. It is my hope
While the Department of Education audits your food service this article gave you some things to keep in mind as you make
purchases, federal requirements apply to ALL purchases using purchases for your district. Go Procurement Go!
federal dollars. Even though the federal quote requirement
thresholds are the same for purchases from $10,000 to $100,000, Bill Munch, CPPO, CPPB is the Procurement Compliance and
there are additional federal clauses that should be added Training Officer for Valley Schools Management Group, recipient
to federal purchases. For purchases under $10,000, federal of the 2018 AASBO Bill Lovett Award, and the 2016 NIGP National
provisions require you to rotate vendors unless you obtain three Purchasing Manager of the Year. He may be reached at: bmunch@
quotes. It is important to recognize that formal federal purchases vsit.org.

28 THE EDGE | FALL 2018