REMEDIATION
• The Procurement Policy has been updated to reflect the current procurement requirements and methods under the CFR and all funder contracts for micro and small purchases and competitive proposals.
• Authorization limits for purchases were also revised to reflect and coincide with the...
REMEDIATION
• The Procurement Policy has been updated to reflect the current procurement requirements and methods under the CFR and all funder contracts for micro and small purchases and competitive proposals.
• Authorization limits for purchases were also revised to reflect and coincide with the current procurement threshold limits per the CFR.
• Additional revisions to the policy include random checks and verification on an annual basis for small purchase level ($10,001 up to $250,000) procurements to ensure compliance with the CFR and funder requirements.
• Procurement Period: The Procurement Policy was also updated to include additional guidelines as to a procurement period of five years as a default. The period of procurement is the period of time after the initial procurement procedure, i.e., a quote or request for proposals, and before LAFH must conduct a new procurement process. The frequency at which LAFH conducts procurement processes should be reasonable and should consider funding source requirements as well as the nature of the goods and services procured. Unless otherwise specified, the default period is for LAFH to conduct a procurement every five years.
• Extension/Renewal of Existing Contract/Purchase Order:
1. For procurements > $250,000, if the Procurement Period has not expired, LAFH may amend or renew an existing contract/purchase order to extend its term for the remainder of the Procurement Period if any adjustment in price is deemed reasonable pursuant to a cost analysis, and all other terms remain the same.
Example, if the competitive procurement covered a 5 year period and the initial contract/purchase order was for two years, LAFH may extend the term of the initial contract/purchase order for up to three years so long as the price is deemed reasonable pursuant to a cost analysis and all other terms remain the same.
2. For procurements ≤ $250,000, if the Procurement Period has not expired, LAFH may amend or renew an existing contract/purchase order to extend its term for the remainder of the Procurement Period if any adjustment in price is deemed reasonable and all other terms remainder the same.
• Existing or contemplated vendors who are widely known or accepted entities or have established lengthy business relationships with LAFH would also be exempt from formal competition as long as there are no significant changes to the terms per section [H.6, e] of the Procurement Policy.
• Due diligence checks and contract review for new vendors are managed by the Director of Contract Management.
RECOMMENDATIONS
• It is recommended that each department establish its own business process and workflow as to their procurement needs, subject matter experts or designees who are responsible for managing their procurement.
• An agency level procurement manager or designee would be beneficial to ensure consistency and compliance across all departments as well as ongoing monitoring of formal competitive bid processes.
• Training as to the procurement policy and procedures would ensure compliance with internal and regulatory requirements.