Procurement

CSF is committed to ensuring that all procurement activities are conducted with integrity, transparency, and fiscal responsibility. This policy establishes uniform standards for purchasing goods and services, promoting open and fair competition, and ensuring that all expenditures serve the best interests of CSF’s mission and donors.


General Policy

CSF will maintain a procurement system that:

  1. Promotes full and open competition to the maximum extent practicable.

  2. Ensures that purchases are made based on merit, quality, and cost-effectiveness, without favoritism or personal interest.

  3. Provides for documented justification and approval for all purchases.

  4. Guards against waste, fraud, abuse, or conflict of interest in all transactions.

  5. Reflects sound business judgment consistent with applicable laws, ethical standards, and funding requirements.


Authority and Oversight

  • The Designated Officer is responsible for procurement oversight and ensuring adherence to this policy.

  • The Board of Directors retains ultimate authority to review or approve large or high-risk procurements, as defined in CSF’s financial thresholds.

  • No employee, contractor, or volunteer may obligate CSF financially without written authorization.


Procurement Methods

CSF will use one of the following methods, based on the total cost and complexity of the purchase:

  1. Micro-Purchase (≤ $10,000):

    May be awarded without competitive quotations if the price is reasonable and documented.

  2. Simplified Acquisition (>$10,000 – ≤ $250,000):

    Requires price or rate quotations from at least two qualified sources.

  3. Competitive Proposal (>$250,000 or complex services):

    Requires a formal request for proposals (RFP), written evaluation criteria, and documented selection based on best overall value.

  4. Noncompetitive (Sole-Source) Procurement:

    Permitted only when one or more of the following apply:

    • The item or service is available from a single source.

    • Public emergency does not allow for competition.

    • Written authorization is obtained from the Designated Officer explaining the necessity.

All procurement actions must be documented and retained per CSF’s Records Retention Policy.


Contract Provisions

All contracts must be:

  • In writing and signed by authorized parties.

  • Clear in describing the scope of work, deliverables, payment schedule, and performance measures.

  • Reviewed for compliance with CSF standards and any applicable funding terms.

  • Monitored throughout performance to ensure contract obligations are met.


Cost and Price Review

Before awarding any contract, CSF will:

  • Conduct a price reasonableness review for purchases under simplified acquisition thresholds.

  • Conduct a cost or price analysis for contracts above $250,000 or when no competition exists.

    All analyses will be documented and filed with the procurement record.


Conflict of Interest

No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by any funds if they have a real or apparent conflict of interest.

All potential conflicts must be disclosed in accordance with CSF’s Conflict of Interest Policy.


Vendor Integrity

Vendors must be reputable and capable of fulfilling contractual obligations.

Prior to contract execution, CSF will verify vendor eligibility, including:

  • Active status in the System for Award Management (SAM.gov) when federal funds are involved.

  • Absence from debarment or suspension lists.


Procurement Records

For every purchase, CSF will maintain records sufficient to detail the history of the procurement, including:

  • Rationale for method of procurement

  • Selection criteria and basis for award

  • Contract terms

  • Cost or price analysis

  • Written approvals

Records will be retained in accordance with CSF’s Record Retention Policy (minimum of five years).


Procurement Threshold and Approval Table

This table establishes clear approval, documentation, and competition requirements for all CSF purchases. It ensures consistency, transparency, and accountability across all procurement activities.

Purchase Type
Dollar Range
Competition
Documentation
Approval

Micro-Purchase

≤ $10,000

No competitive quotes required if price is reasonable and customary.

Receipt or invoice showing fair market price.

Designated Officer or authorized staff.

Simplified Acquisition

$10,001 – $250,000

Minimum of two (2) written or verbal quotes from qualified vendors.

Quote comparison form and justification for vendor selection.

Designated Officer; notify Treasurer for purchases over $50,000.

Formal (Competitive) Procurement

Over $250,000

Written Request for Proposals (RFP) or Invitation for Bids (IFB) with public notice or direct solicitation of at least three qualified vendors.

Full procurement file including RFP, bids, evaluation, selection rationale, and cost/price analysis.

Board of Directors approval prior to award.

Noncompetitive (Sole Source)

Any dollar amount

Allowed only if one or more of the following apply: (1) Only one source available; (2) Public emergency; (3) Written authorization by Designated Officer explaining necessity.

Sole-source justification memo, cost/price analysis, and written approval from Designated Officer.

Designated Officer; Board approval required if over $50,000.

Subrecipient Agreement

Any dollar amount

Must include subrecipient risk assessment and monitoring plan.

Written subaward agreement and justification file.

Designated Officer with Board notification.

Contract Modification / Amendment

Any dollar amount

None unless changes affect cost or scope.

Amended contract and justification summary.

Same level of authority as original contract.

Policy Review

This policy will be reviewed annually and updated as necessary to maintain compliance with applicable laws and funding requirements.

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