Policy committee recommends consolidated procurement policy, procurement-card rules and renumbering for board review March 24

The Hatboro-Horsham School District policy committee reviewed several proposed revisions to finance and procurement policies on March 10, 2024 and recommended that the board consider first readings and renumbering at the March 24 legislative action meeting.

Bill Stone, Director of Business Affairs, told the policy committee the administration proposes to consolidate several purchasing policies into a single procurement policy (new/updated policy 610) and retire policies 611, 612 and 613. Stone said, "we're combining 4 policies into 1," and that the change is meant to simplify district purchasing practices and align thresholds with state and federal adjustments.

The committee discussed delegation, thresholds and federal compliance. Stone said the state bid threshold currently in state code is $23,800 and recommended delegating authority to the superintendent or designee to approve contracts below the state bid threshold and to bring those contracts to the board for ratification at the next meeting. Stone said the administration will not delegate authority for contracts that "modify or negate or enter into any significant policy decision that has not been previously brought forward by the board." He also said the policy language will refer to adjustable thresholds (rather than hard-coded dollar amounts) so the district automatically aligns with future state or federal changes.

The committee considered federal procurement requirements for federal funds and ESSER monitoring. Stone said the district is updating policy attachments to reflect the federal Uniform Guidance thresholds and practice; he noted the federal procurement threshold for formal procurement referenced in the attachments is $250,000 and that the policy language will indicate that federal thresholds will be adjusted if federal rules change. The committee also discussed travel reimbursement references and the use of General Services Administration limits.

The committee proposed a new procurement-card policy (policy 631) to codify cardholder agreements, permitted uses, low card limits and internal controls. Stone said the new policy is intended to ensure that procurement cards are not used to circumvent required purchasing procedures: "a procurement card is not to be a workaround for district purchasing practices." Committee members asked whether card limits would remain low; administration said current limits are "pretty low" and will be maintained.

Members asked procedural questions about policy attachments and how changes to attachments would be handled. Stone said attachments should be treated like the policy and would require first and second readings for substantive changes; the PSBA format places lengthy procurement details in attachments to keep the main policy shorter. In response to a question about telephonic quotes, Stone said the statute still allows telephonic quotes and the district would document date, time and the amount provided; he noted the telephonic option is "a little outdated given that we can obtain so much via the Internet or by email."

The policy committee recommended first readings for revised policies (610 and related federal compliance policies), a first reading for new policy 631 (procurement cards), renumbering of fund-balance policy 625 to 620 to align with PSBA, and renumbering electronic-records policy 616.1 to 800.1. The committee asked that these proposed actions be posted for board consideration at the March 24 legislative action meeting.

No final board action on the policies occurred at the March 10 meeting; the committee's recommendation moves the items to the full-board agenda for formal consideration.