To: Contra Costa County Housing Authority Board of Commissioners
From: Joseph Villarreal, Executive Director
Report Title: APPROVE THE EXECUTIVE DIRECTOR TO AMEND THE HOUSING AUTHORITY’S PROCUREMENT POLICY TO INCREASE THE PURCHASE THRESHOLDS FOR PETTY CASH, MICRO AND SMALL PURCHASES
☐Recommendation of the County Administrator ☐ Recommendation of Board Committee
RECOMMENDATIONS:
APPROVE the Executive Director to amend the Housing Authority’s (HACCC) procurement policy to increase the purchase threshold for petty cash, micro, and small purchases.
BACKGROUND:
The current petty cash ceiling of $50 no longer meets the needs of routine business operations and has created inefficiencies in processing low-value purchases. Increasing this threshold will allow for greater flexibility and responsiveness in small, day-to-day transactions.
The micro purchase threshold is currently set at $3,000. Increasing it would make it consistent with HUD’s updated guidance. This change is specifically intended to reduce the administrative burden of requiring full approvals and competitive procedures for routine purchases up to $10,000. By increasing this threshold, HACCC staff will be able to make low-value purchases more efficiently while maintaining fiscal accountability and compliance with federal standards.
The small purchase threshold for purchases supporting day-to-day operations is currently set at $150,000. While the U.S. Department of Housing and Urban Development (HUD) has increased the federal small purchase threshold to $250,000, HACCC proposes to adopt a threshold consistent with the County’s procurement standards. This alignment ensures consistency across local government procurement practices while still remaining within HUD’s allowable limits. It also simplifies procurement administration, improves programmatic efficiency, and reduces unnecessary administrative burden, all while preserving necessary oversight.
HACCC intends to make the following changes to the procurement thresholds:
• Increase the Petty Cash purchase threshold from $50 to $250.
• Raise the Micro Purchase threshold from $3,000 to $10,000, consistent with updated HUD guidance, with the exception of construction procurements which remains at $2,000.
• Increase the Small Purchase threshold, including for petty cash, micro, and small-purchase non-complex service contracts, from $150,000 to $200,000, bringing it in alignment with the County’s threshold.
HACCC’s Procurement Procedures will include the following:
• For any amounts above the petty cash ceiling ($250) but not exceeding $200,000, HACCC may use small purchase procedures.
• Under small purchase procedures, a reasonable number of quotes (preferably three) should be obtained.
• For purchases under $10,000 (except for construction, which remains at $2,000), defined as Micro Purchases, only one quote is required, provided it is deemed reasonable.
• To promote competition, small purchases should be distributed among qualified sources to the greatest extent feasible.
• Quotations (QSPs) may be obtained orally (in person or by phone), by fax, in writing, or through e-procurement platforms.
• The following must be documented and maintained as a public record (unless otherwise restricted by law): names, addresses, or telephone numbers of offerors, the date of each quote, and the quoted amount.
• Awards will be made to the responsive and responsible vendor offering the lowest price, unless justified with supporting documentation in the contract file.
• HACCC shall not split purchases that exceed the applicable thresholds into smaller transactions for the purpose of avoiding procurement rules or using less stringent procedures.
These updates reflect current HUD regulations, align with County practices, and enhance operational efficiency while maintaining transparency and accountability.
FISCAL IMPACT:
No direct financial impact.
CONSEQUENCE OF NEGATIVE ACTION:
Failure to approve the updated thresholds and procedures will leave HACCC operating under outdated limits that no longer reflect market realities, reducing operational agility and efficiency.