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Procurement Compliance in Our New Reality 2020

This article was previously published in the AASBO Edge

By Bill Munch, CPPO, CPPB


Our new reality includes an emphasis on living in the online world as we cope with trying to remain compliant with the School District Procurement Rules which demand transparency.

Procurement Challenges that Impact Public Entities

As the Stay-At-Home order came down in mid-March and many of us began telecommuting. It became apparent that solutions were needed to remain compliant with public receipt of bids, bid openings, and other transparent requirements of our procurement rules. These challenges impact public entities throughout the country. The AASBO rules committee that includes Michelle Hamilton, Gary Barkman, Ken Carter, Lari Staples, Lila McCleery, Claudia Leon, Anita McLemore, Kevin Startt and I reached out to the Auditor General and Attorney General asking for guidance to help school districts remain compliant.  

Richard Baek, with the office of the Attorney General, stepped up and worked with his office to help draft an AG Opinion that would help guide us.  The opinion issued March 23, 2020, can be found here. Very quickly thereafter the release of the AG Opinion, the Auditor General sent an email giving procurement guidance during school closures.  That guidance which includes reference to the AG Opinion has been posted in the FAQ section of the Auditor General Website.  Further updates will be posted there as they become available.

Federal Funding for Education

At the Bi-Monthly AASBO Webinar on May 13, 2020, a ton of information was given about the CARES Act. In addition, discussions on much-needed funding that has been made available to our schools in Arizona and across the nation. Please be aware that when using CARES Act funds you should be following Federal Procurement guidelines. Firstly, we know from past historical federal audits around the country, that the Feds will not hesitate to recoup funds that are not spent in compliance with federal requirements.  Therefore, it is important to follow the federal guidelines for these purchases and all other purchases funded by federal dollars.

Now more than ever it is important to embrace every procurement tool we have in our toolbox.  Cooperative purchasing can be one of the most important tools we have.  Cooperative contracts that are competitive and meet our due diligence requirements can allow us to expeditiously make our purchase in an efficient and compliant manner.  1GPA and Mohave are a couple of the co-ops out there that have done an excellent job of incorporating federal requirements into their procurement contracts.  Almost all of their contracts have a federal language that could make them compliant for CARES Act purchases.  Follow the advice of President Reagan and “Trust but verify”.

Remaining Procurement Compliant

As we move forward in our new reality, the challenges will be many. It will take a team effort to overcome these challenges.  Along with the resources provided by the State, our association can provide support to all of us.  I am confident that we as public school business officials are up to the challenge and can remain procurement compliant in our ever-changing world.

Bill Munch, CPPO, CPPB is the Procurement Compliance and Training Officer for Valley Schools Management Group. He was previously a recipient of the 2018 AASBO Bill Lovett Award and the 2016 NIGP National Purchasing Manager of the Year.  Mr. Munch provides consultation on public procurement matters for school districts and vendors across the State of Arizona and across the country.  He may be reached at

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