Page 32 - The EDGE Spring 2020

VENDOR/BUYER CONFERENCE

BY DON HARRIS
Auditors Can Spot Deficiencies – They Tell How to

Reduce Them

Two state auditors who carefully review school district “You can’t delegate all that authority to that consultant,” Gustafson
procurement policies, practices and procedures looking for said. “I have seen mistakes that may require a rebid, or they might
deficiencies told AASBO members how to reduce those missteps. have a bid protest filed against them.”
Megan Smith and Paula Gustafson of the Arizona Office of the
Auditor General provided tips and guidance for AASBO members To reduce deficiencies, before issuing a solicitation AASBO
at the 2020 Vendor/Buyer Conference on January 28. members were told to verify timelines and make sure all pages are
included and numbered correctly.
“It’s not possible to avoid every deficiency,” Smith said, but there
are ways to reduce the likelihood of them from happening. “If issues are discovered after the fact, an amendment needs to
be issued,” Gustafson said. “You don’t have to start all over. And
Their breakout session covered such topics as procurement make sure everyone knows what the changes are.”
analysis and oversight, standardized procurement documents, due
diligence using co-op contracts, procurement ethics and gifting
prohibitions when doing procurement. The Auditor General does
follow-up sessions to help districts avoid problems.

AASBO members were told they should carefully plan their
spending. Your spending analysis should include looking at the
data provided by suppliers. “Where are you spending your money
as you plan for future spending?” Gustafson said. “Monitor
spending, your current spending levels, so you won’t get into
trouble. Maybe you didn’t get the right quote.”

Questions to consider include: What are we buying? How much
did we spend? Where can we save money? Are we spending faster
than we anticipated?

It’s always prudent to conduct periodic reviews of your purchases.
In addition, be sure you are communicating well with accounts
payable “so everybody is on the same page,” Gustafson said.
She also recommended doing internet searches for pricing – If vendor responded to a bid that contains a wrong description, the
basically market research. district might determine the vendor was non-responsive. But, if the
description had been correct, the district might have awarded the
Under the procurement process, Gustafson said districts should contract to that vendor.
anticipate projects and expenditures to ensure a fair and open
process. There should be no bid-splitting. “You could run into “Make sure it’s the right school, the right district,” Smith said.
this inadvertently by making several smaller purchases that
cumulatively would push you over a threshold,” she said. On another troublesome issue, you should develop and implement
methods and operational procedures for preparing written
Another issue to avoid is bid manipulation that might favor one determinations. “Unfortunately, we see a lot of those compliance
vendor over another. That could lead to additional change orders, issues,” she said.
driving up the cost.
You should use a determination form or checklist for frequently
If you rely on a consultant to prepare solicitation documentation used procurement types. It should be well written with all the facts.
without a review, which could happen in a small district with a “Document the facts used to make the procurement decision, used
limited staff, that doesn’t remove your responsibility. by the Governing Board to make a decision, and for the benefit
of the public,” Smith said. “If it provides enough information,
Allowing a vendor or grantor to run the procurement can result it has accomplished its purpose. That’s how to avoid written
in a deficiency, such as failing to catch simple mistakes like dates deficiencies.”
and page numbers. Fixes becomes an after-the-fact transaction. CONTINUED ON PAGE 34

|
32 THE EDGE SPRING 2020