HomeMy WebLinkAboutN-562 - Procurement Policy for Block Grant FundsCITY OF PASCO
ADMINISTRATIVE ORDERS
Administrative Order No. 562
Community & Economic Development
Subject: Procurement Policy for Block Grant Funds
Initial Effective Date:
October 12, 2010
Revised
02/17/16
Aoroved
The following Administrative Order is effective February 17, 2016, and replaces Administrative
Order No. 562, dated 10/12/10.
I. PURPOSE:
This Policy outlines the procurement process to be adhered to when a project is funded
either wholly or in part with grant funds received from the US Department of Housing
and Urban Development (HUD). Information in this document describes various methods
of procurement, code of conduct, and suspension and debarment conditions that apply to
HUD funded projects.
II. DEPARTMENTS AFFECTED:
All Departments receiving HUD assistance for projects.
III. REFERENCES:
1. 24 CFR 570.502, Applicability of uniform administrative requirements.
2. 24 CFR 85.36, Procurement
3. 2 CFR 200 Uniform Administrative Requirements
W. ATTACHMENTS
1. HUD Methods of Procurement Summary Table
2. Procurement File Checklist
V. DEFINITIONS:
The term "Procurement," as used in this Policy, includes the procuring, purchasing,
leasing, or renting of. (1) goods, supplies, equipment, and materials; (2) construction and
maintenance, consultant services; (3) Architectural and Engineering (A/E) services; (4)
Social Services; and (5) other services.
Administrative Order No. 562 - Procurement Policy for Block Grant Funds
Attachment No. 2
The City Manager may delegate procurement authority as is necessary and appropriate to
conduct the business of the City to the responsible Department Director to act as the
"Contracting Officer."
VI. POLICY:
Methods of Procurement
The City of Pasco's CDBG and HOME funds procurement process follows regulations
set forth in 24 CFR 85.36. The City generally has four different Methods of
Procurement:
1. Small Purchase Procedures
2. Sealed Bids
3. Competitive proposals
4. Non -Competitive proposals
Procurement for Small Purchases
This procedure is used for the relatively simple and informal procurement methods for
securing services, supplies or other property that do not cost more than the simplified
acquisition threshold fixed at 41 U.S.C. 403(l 1) (currently set at $150,000). When small
purchase procedures are used, price or rate quotations shall be obtained from at least two
qualified sources. This shall be documented with a quote or invoices from all contacted
sources or in a signed memo with information on all qualified sources contacted with
prices. Generally these purchases shall be made from lowest quote, but if lowest quote is
not selected a detailed explanation shall be documented.
Procurement by Sealed Bids (formal advertising)
Bids will be publicly solicited in the local newspaper and/or another publication outside
the immediate area, for a period of fifteen calendar days and a firm -fixed-price contract
(lump sum or unit price) will be awarded to the responsible bidder whose bid,
conforming with all the material terms and conditions of the invitation for bids, is the
lowest in price. The sealed bid method is the City's preferred method for procuring
construction.
In order for sealed bidding to be feasible, the following conditions should be present:
• A complete, adequate, and realistic specification or purchase description is available;
• Two or more responsible bidders are willing and able to compete effectively and for
the business; and
• The procurement lends itself to a firm fixed price contract and the selection of the
successful bidder can be made principally on the basis of price.
If sealed bids are used, the following requirements apply:
• The invitation for bids will be publicly advertised in the local newspaper and/or
another publication outside the immediate area for a period of 15 calendar days from
bid opening and bids shall be solicited from an adequate number of known suppliers;
• The invitation for bids, which will include any specifications and pertinent
attachments, shall define the items or services in order for the bidder to properly
respond;
Administrative Order No. 562 - Procurement Policy for Block Grant Funds
Page 2
All bids will be publicly opened at the time and place prescribed in the invitation for
bids;
A firm fixed-price contract award will be made in writing to the lowest responsive
and responsible bidder. Where specified in bidding documents, factors such as
discounts, transportation cost, and life cycle costs shall be considered in determining
which bid is lowest. Payment discounts will only be used to determine the low bid
when prior experience indicates that such discounts are usually taken advantage of;
and
• Any or all bids maybe rejected if there is a sound documented reason.
Procurement by Competitive Proposals
Competitive proposals will be conducted with more than one source submitting an offer,
and either a fixed-price or cost -reimbursement type contract will be awarded. It will
generally be used when conditions are not appropriate for the use of sealed bids. If this
method is used, the following requirements will apply:
• Requests for proposals will be publicized in the local newspaper and/or another
publication outside the immediate area for a period of fifteen calendar days. Any
response to publicized requests for proposals shall be honored to the maximum extent
practical;
• Proposals will be solicited from an adequate number of qualified sources;
• City staff will have a method for conducting technical evaluations of the proposals
received and for selecting awardees;
• Awards will be made to the responsible fine whose proposal is most advantageous to
the program, with price and other factors considered; and
• City will use competitive proposal procedures for qualifications -based procurement
of architectural/engineering (A/E) professional services whereby competitors'
qualifications are evaluated and the most qualified competitor is selected, subject to
negotiation of fair and reasonable compensation. The method, where price is not used
as a selection factor, can only be used in procurement of A/E professional services. It
cannot be used to purchase other types of services though A/E firms are a potential
source to perform the proposed effort.
Procurement for Non-competitive Proposals
This procurement is done through solicitation of a proposal from only one source, or after
solicitation of a number of sources, competition is determined inadequate. Procurement
by noncompetitive proposals will be used only when the award of a contract is infeasible
under small purchase procedures, sealed bids or competitive proposals and one of the
following circumstances applies:
• The item is available only from a single source;
• The public exigency or emergency for the requirement will not permit a delay
resulting from competitive solicitation;
• The awarding agency authorizes noncompetitive proposals; or
• After solicitation of a number of sources, competition is determined inadequate.
Administrative Order No. 562 — Procurement Policy for Block Grant Funds
Page 3
Code of Conduct
The City hereby establishes this code of conduct regarding procurement issues and
actions and will implement a system of sanctions for violations. This code of conduct,
etc., is consistent with applicable federal, state,or local law.
Conflicts of Interest
No employee, officer, or agent of the City may participate directly or indirectly in the
selection, award, or administration of any contract if a conflict of interest, either real or
apparent, would be involved. This type of conflict would be when one of the persons
listed below has a financial or any other type of interest in a firm competing for the
award:
A. An employee, officer, or agent;
B. Any member of his/her immediate family;
C. His or her partner; or
D. An organization which employs, or is about to employ, any of the above.
Gratuities, Kickbacks, and Use of Confidential Information
No officer, employee, or agent will ask for or accept gratuities, favors, or items of more
than a minor economic value from any contractor, potential contractor, or party to any
subcontract, and will not knowingly use confidential information for actual or anticipated
personal gain.
Suspension and Debarment
Contracts must not be awarded to debarred, suspended, or ineligible contractors.
Contractor eligibility must be verified and documented prior to contract award.
Contractors may be suspended, debarred, or determined to be ineligible by HUD in
accordance with HUD regulations (24 CFR Part 24) or by other federal agencies, e.g.,
Dept of Labor for violation of labor regulations, when necessary to protect the City in
their business dealings.
Vendor Lists
All interested businesses will be given the opportunity to be included on prequalified
vendor lists, small work rosters, etc. Any lists of persons, firms, or products which are
used in the purchase of supplies and services (including construction) shall be kept
current and shall include sufficient resources to ensure competition.
Independent Cost Estimate
For all purchases above the Micro Purchase threshold, the City will prepare an
Independent Cost Estimate (ICE) prior to solicitation. The level of detail will be
commensurate with the cost and complexity of the item to be purchased.
Cost and Price Analysis
The City shall require assurance before entering into a contract that the price is
reasonable, in accordance with the instructions below.
Administrative Order No. 562 — Procurement Policy for Block Grant Funds
Page 4
Petty Cash and Micro Purchases
No formal cost or price analysis is required. Rather, the execution of a contract by the
Contracting Officer (through a Purchase Order or other means) will serve as the
Contracting Officer's determination that the price obtained is reasonable, which may be
based on the Contracting Officer's prior experience or other factors.
Small Purchases
A comparison with other offers will generally be sufficient determination of the
reasonableness of price and no further analysis is required. If a reasonable number of
quotes is not obtained to establish reasonableness through price competition, the
Contracting Officer will document price reasonableness through other means, such as
prior purchases of this nature, catalog prices, the Contracting Officer's personal
knowledge at the time of purchase, comparison to the ICE, or any other reasonable basis.
Sealed Bids
The presence of adequate competition should generally be sufficient to establish price
reasonableness. Where sufficient bids are not received, and when the bid received is
substantially more than the ICE, and where the City cannot reasonably determine price
reasonableness, the City must conduct a cost analysis, consistent with federal guidelines,
to ensure that the price paid is reasonable.
Competitive Proposals
The presence of adequate competition should generally be sufficient to establish price
reasonableness. Where sufficient bids are not received, the City must compare the price
with the ICE. For competitive proposals where prices cannot be easily compared among
offerors, where there is not adequate competition, or where the price is substantially
greater than the ICE, the City must conduct a cost analysis, consistent with federal
guidelines, to ensure that the price paid is reasonable.
Contract Modifications
A cost analysis, consistent with federal guidelines, shall be conducted for all contract
modifications for projects that were procured through Sealed Bids, Competitive
Proposals, or Non -Competitive Proposals, or for projects originally procured through
Small Purchase procedures and the amount of the contract modification will result in a
total contract price in excess of $150,000.
Administrative Order No. 562 — Procurement Policy for Block Grant Funds
Page 5
Attachment No. 1
HUD - Methods of Procurement
Summary Table
Administrative Order No. 562 — Procurement Policy for Block Grant Funds
Attachment No. I
Small Purchases
Sealed Bids
Competitive
Non -
Proposals
Competitive
Micro
$3,000 to
$150,000 and
$150,000 and
Purchases
$150,000
higher
higher
Up to $3,000
• Scope of
Solicit ONE
Solicit
Work
Quote
REASONABLE
• Specification
• RFP
ONLY
Obtain Bids
In Writing
number of quotes
• IFB
• Factors
ONE
Or
• Advertise
•Relative
Verbally
In
In Writing or
• Open Publicly
Importance
Verbally
• Evaluate
• Advertise
• Available only
• Requires
from a single
Competition
. Requires
source
• Requires
. Always an
Competition
. Public
Single Quote
Competition
Apparent Low
. Awarded to
exigency or
Award
d Contract
no
a
minimum of three)
Bidder
Most
emergency
Competition
. Awarded to
. Awarded to
Advantageous
exits
"Best Value"
Lowest Cost
(Best overall
• HUD
• Fixed Firm
value)
Approval
Price Contract
• Lack of
completion
1. Price Analysis
Signature
g
Apparently
pP y
{Qualifications &
Prove Cost
signifies that
obvious or price
Price Analysis
Cost}
Cost Analysis
Reasonableness
the cost is
analysts
2. Cost Analysis
reasonable
(Qualifications
ONLY
Independent Cost
Not Required
Required
Required
Required
Required
Analysis
Bonding
Required for
Required for
Required for
Not Required
contracts $35,000
contracts $35,000
Not Required
contracts $35,000
Requirements
to $150,000
to $150,000
to $150,000
Wage Rates
Required for
Required for
Required for
Required for
Labor Standards
Not Required
construction
construction
construction
construction
HLID4010
contracts over
contracts over
contracts over
contracts over
Labor Compliance
$2,000
$2,000
$2,000
$2,000
Suspension &
Debarment &
Required
Required
Required
Required
Required
Excluded Parties
List Check/Print
Mandatory Bidder
Responsibility
Required
Required
Required
Required
Required
Checklist
Documenting
Historical
Historical Data or
Historical Data or
Written
Written
Rationale for
Data
written summary
written summary
Summary
Summary {Fiaaing
Award
(Finding of Fact)
{Finding of Fact}
{Finding of Fact}
of Fact}
Administrative Order No. 562 — Procurement Policy for Block Grant Funds
Attachment No. I
Attachment No. 2
PROCUREMENT FILE CHECKLIST
Contract: Project No. Date:
Administrative Order No. 562 — Procurement Policy for Block Grant Funds
Attachment No. 2
Micro Small Purchase Sealed Bid Competitive Non -
Purchase $3,000 to $150,000 and Proposals Competitive
Up to $3,000 $150,000 Higher $150,000 and Proposals
Hi her
Pre -Solicitation
Independent Cost Estimate ICE
Individual Procurement Plan
Rationale for Contract Method: (if not
apparent)
Rationale for Contract Type (if not
apparent)
Evaluation Plan
Labor Compliance Checklist
Solicitation
Sources(mailing lists, advertisements, etc.
Solicitation Notice and Amendments
IFB/RFP
Notes of Pre-Bid/Proposal Conferences
IFB/RFP Correspondences
Record of Bids/RFPs Requested
Quotes, Bids or Proposals Received
Justification for Other than Full/Open
Competition
Evaluation
Bid Opening
Evaluation Panel Disclosures and Ethics
Statement
Technical Evaluation
Price Evaluation
Competitive Range Determinations
Evaluation Findings of Fact
Memo of Negotiation and Selection
Decision
Suspension & Debarment Check Printouts
Mandatory Bidder Responsibility Checklist
Award
Contract and Award Documents
Notification to Unsuccessful Bidders
Appeals all correspondence)
Post -Award and Contract Administration
PW Contracting Requirements Chart
Performance & Payment Bonds
>$35K /Lien Release(Lump Sum
Records of Post-Award/Pre-Construction
Conferences
Notice to Proceed
Contract Modifications and Supporting
Documentation
Receiving Reports
General Contract Correspondence
Payment Record/Documentation
Inspections and Field Reports
Council Acceptance/Completion Certificate
Retainage Release
Administrative Order No. 562 — Procurement Policy for Block Grant Funds
Attachment No. 2