Although most of us have very little federal funding relative to our total
budget, there are some local agencies that receive significant federal
funding through grants.

My question for the membership is with regard to purchasing procedures and
purchasing thresholds.  The federal OMB considers any purchases under
$100,000 to be a "small purchase" for procurement compliance purposes,
requiring competitive bidding for purchases that exceed the $100,000
threshold.  However, the local agency's finance office considers purchases
over, say $10,000, $5,000 or even $2,500 to include competitive bidding
documentation (excluding public works projects).

For single audit purposes, are our federal awards being held to a higher
standard by following local purchasing policies rather than the federal
guidelines?  Do any cities have a separate purchasing/procurement policy for
"federally-funded" operating costs vs. professional service contracts?

I'm working with a local JPA that receives roughly 65% of its funding, or
about $13 million, from federal grants and your comments on this issue would
be appreciated.

Thank you,


John Herrera, Administrative Services Director
City of Imperial Beach
(619) 628-1361

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