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Housing Authority tightens procurement policy to match HUD rules, allows CEO limited noncompetitive authority with quarterly reporting

Housing Authority of the City and County of San Francisco Board of Commissioners · February 29, 2024
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Summary

The Authority adopted comprehensive procurement-policy revisions to align with HUD regulations, add micro‑purchase rules and forbid bid‑splitting; the board authorized the CEO to approve micro purchases and sole‑source justifications under the CEO's $100,000 threshold, with quarterly reporting on such actions.

The Housing Authority adopted a revised procurement policy aimed at strengthening compliance with HUD procurement standards and clarifying internal procedures.

Attorney Sawadee Lange told commissioners the overhaul added a definitions section, procurement planning, funding-availability language, a prohibition on bid‑splitting and explicit inclusion of micro purchases among allowable noncompetitive procurement categories. The revision also aligns noncompetitive procurement language with 2 C.F.R. 200.320 and HUD guidance.

Under the updated policy, staff proposed — and the board accepted with conditions — that the CEO retain authority to approve written justifications for micro purchases (under $10,000) and for sole‑source procurements under the CEO's $100,000 authorization threshold, rather than requiring a board resolution for each such instance. Commissioners asked for quarterly summaries of micro purchases and sole sources and emphasized the need for robust documentation and HUD‑compliant justifications.

Board members discussed historical concerns about procurement integrity and asked that internal controls and monthly/quarterly summaries be made available for oversight. The policy passed on a unanimous roll‑call vote; staff said training had already been provided to staff and that the revision matrix and justification documents would be available to the commission.