Policy CH: Purchasing and Acquisition | Conroe ISD Policy Tracker

Conroe ISD's Purchasing and Acquisition policy governs how the district buys goods and services, including when Board approval or competitive bidding is required based on purchase amounts.

Local Changes (5)

2026-07-21adopted · Meeting notes

This update to CH (Purchasing and Acquisition) adds new defined terms for "Service provider" and "Vendor," expands purchasing authority oversight requirements, introduces a new Conflict of Interest section tied to HB 210 (89th TX Leg.), restructures the Purchasing Method language, and requires service providers and vendors to comply with specific Board Policies. Several legacy phrases and redundant cross-references are removed and replaced with updated, more precise language throughout.

Added

Service provider means a person who provides services to the District. The term includes: (A) A contractor, or subcontractor for the District; (B) A provider of tutoring services for the District; (C) An entity that has entered into a contract to operate a school district campus under Texas Education Code Section 11.174; (D) A staffing provider for the District; and (E) A person employed by or under the control of a person described by Paragraph (A), (B), (C), or (D) above, including its representatives, employees, subcontractors, or any other individuals acting on its behalf.
Vendor means a person, company, individual, contractor, subcontractor, or professional services provider with whom the District enters into an agreement, contract, memorandum of understanding, interlocal agreement, fee schedule, retainer, or similar instrument for goods or services.
Substantial interest in a vendor is defined as an individual who: 1. Owns more than 10 percent of the voting interest in the vendor; or 2. Has a direct or indirect participating interest by shares, stock, or otherwise, regardless of whether voting rights are included, in more than 10 percent of the profits, proceeds, or capital gains of the vendor.
However, any non-routine and discretionary purchases, not previously included in a Board-approved contract or memorandum of understanding, to a single vendor shall require the Superintendent to notify the Board in writing before a transaction may take place. If two or more Board members timely raise a concern with the purchase to the Superintendent, the purchase shall be timely placed on a Board agenda for Board approval or disapproval. If Board notification is not possible without delaying needed goods or services for District operations, the District may purchase the goods or services but shall notify the Board as soon as practicable thereafter.
All service providers and vendors shall comply with all Board Policies, including EMB(LOCAL), EFA(LOCAL), EFB(LOCAL), FFG(LOCAL), and FFF(LOCAL), and all other Board Policies or District procedures, as appropriate, for that service provider or vendor.
include, but are not limited to, goods or services that are:
District-level awards and honors in excess of $2,500
District purchasing procedures
methods allowed by Texas law CH(LEGAL) or CBB(LEGAL), as appropriate, except as provided by Board Policy CV(LOCAL).
Texas Education Code Section 44.031(h).
Conflict of Interest section: A vendor that bids on or receives a contract from the District commits an offense if any individual serving on the Board: 1. Has a substantial interest in the vendor or a subcontractor hired by a vendor; 2. Is related in the second degree by consanguinity or affinity, as determined under Chapter 573, Government Code, to an individual who has a substantial interest in the vendor; or 3. Has received or has been promised a gift or in-kind services with a value of more than $250.
The District shall adopt procedures to help ensure neither the Board nor a vendor violates the conflict-of-interest provision in this Board Policy.
District administrative procedures (in Electronic Bids Or Proposals section)
Board Policy (in Personal Purchases section)

Removed

vendor, agent, (from Service provider definition subparagraph A)
above, including its representatives, employees, subcontractors, or any other individuals acting on its behalf. (from Service provider definition subparagraph E)
from a vendor (from Purchasing Authority delegation sentence)
Non-routine and discretionary purchases, include (old phrasing without 'but are not limited to')
Except as provided by Board Policy CV(LOCAL), T (from beginning of Purchasing Method sentence)
[See also CB, CBB, CH(LEGAL), and COA] (cross-reference in Purchasing Procedures)
CH(LEGAL) or CBB(LEGAL), as applicable (old legal reference language in Purchasing Method)
except as provided by Board Policy CV(LOCAL) (moved/replaced in Purchasing Method)
all Board Policies, including (from vendor compliance sentence)
administrative (from Electronic Bids Or Proposals — 'District administrative procedures' changed to 'District procedures')

Legal Compliance Summary

AI-generated assessment. Verify citations independently before relying on this analysis.

Conflict of Interest Rules: State law HB 210 (TEC §11.067), effective September 1, 2025, makes it a criminal offense for a vendor to do business with the district if a board member has a significant financial stake in that vendor, is closely related to someone who does, or has received a gift or service worth more than $250 from that vendor. This policy adds those rules and also extends them to subcontractors hired by vendors, which goes beyond what the state law requires.
Vendor Definition: HB 210 (TEC §11.067) introduced the term 'vendor' into state law, and the district's policy defines it to mean any person or company that enters into an agreement with the district to provide goods or services. The policy's definition also covers MOUs, fee schedules, and retainers, which are additions the district made on its own beyond what the statute specifies.
Purchasing Oversight Steps: The district added its own rules requiring the superintendent to notify the board in writing before completing certain large or non-routine purchases from a single vendor. If two or more board members raise a concern, the purchase must be placed on a board meeting agenda before moving forward, with a limited exception for emergencies.
Service Provider Definition: The district created a broad definition of 'service provider' that covers contractors, tutoring providers, campus operators under TEC §11.174, staffing companies, and their representatives. This definition was written by the district and goes beyond any single state law requirement.
Vendor Policy Compliance: The district added a requirement that all vendors and service providers must follow specific board policies, including policies on employee standards, curriculum materials, and student safety. No state law identified in this review requires districts to include this kind of policy compliance obligation in vendor agreements.
Purchasing Methods Update: The policy reorganizes how it describes allowed purchasing methods, now pointing to TEC §44.031(h) as the basis for certain emergency purchasing options. The overall structure of cross-references to other district policies — such as CH(LEGAL) and CBB(LEGAL) — reflects local organizational choices rather than a specific state mandate.

Legal Compliance Details Mixed

AI-generated assessment. Verify citations independently before relying on this analysis.

Definition of 'Service provider' (six-part definition including contractors, tutoring providers, campus operators under TEC §11.174, staffing providers, and related persons/representatives) Locally Discretionary

Statutory basis: TEC §11.174 (partial reference only)

Verified via: verbatim statute text

Local additions: District created a broad definitional framework that references TEC §11.174 campus operators as one category but extends well beyond any statutory definition to include contractors, tutoring providers, staffing providers, and all related representatives — no statute requires or expressly authorizes this comprehensive definition

Definition of 'Vendor' (person or entity entering into agreements, contracts, MOUs, interlocal agreements, fee schedules, retainers, or similar instruments for goods or services) Required by Law

Statutory basis: TEC §11.067 (HB 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Local additions: The district's definition of 'Vendor' appears to track HB 210's usage; however, the statute analysis does not include a verbatim statutory definition of 'vendor' itself. To the extent the district's definition expands beyond statute (e.g., adding MOUs, fee schedules, retainers), those expansions are locally discretionary.

Definition of 'Substantial interest in a vendor' (owns >10% voting interest OR has >10% direct or indirect participating interest in profits, proceeds, or capital gains regardless of voting rights) Required by Law

Statutory basis: TEC §11.067(c) (HB 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Local additions: None — policy tracks statutory definition verbatim

Conflict of Interest section: vendor commits offense if board member (1) has substantial interest in vendor or subcontractor, (2) is related in second degree by consanguinity or affinity to person with substantial interest, or (3) has received or been promised gift or in-kind services >$250 Required by Law

Statutory basis: TEC §11.067(b) (HB 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Litigation: None identified; HB 210 effective September 1, 2025, no active challenges or injunctions confirmed as of July 2026

Local additions: Policy adds 'or a subcontractor hired by a vendor' to element (1), which is a local expansion beyond the statute's express language

District shall adopt procedures to help ensure neither the Board nor a vendor violates the conflict-of-interest provision Locally Discretionary

Verified via: verbatim statute text

Local additions: TEC §11.067 establishes a criminal prohibition on vendor conduct; it does not mandate that the district adopt administrative procedures to prevent violations. This affirmative procedural obligation is a local choice.

Non-routine and discretionary purchases to a single vendor require Superintendent written Board notification before transaction; if 2+ Board members raise concern, purchase placed on Board agenda; emergency exception with after-the-fact notification Locally Discretionary

Verified via: verbatim statute text

Local additions: Entire governance structure — superintendent gatekeeping, conditional board review triggered by member objections, and emergency exception with post-hoc notification — is a local design with no statutory requirement or express authorization identified in the statute analysis

All service providers and vendors shall comply with all Board Policies, including EMB(LOCAL), EFA(LOCAL), EFB(LOCAL), FFG(LOCAL), and FFF(LOCAL), and all other Board Policies or District procedures as appropriate Locally Discretionary

Verified via: verbatim statute text

Local additions: No statute identified in the analysis requires districts to obligate vendors and service providers contractually to comply with all board policies. This is an entirely local policy choice.

Purchasing Methods restructuring: reference to 'methods allowed by Texas law CH(LEGAL) or CBB(LEGAL), as appropriate, except as provided by Board Policy CV(LOCAL)' and addition of TEC §44.031(h) citation Mixed

Statutory basis: TEC §44.031(h)

Verified via: verbatim statute text

Local additions: The citation to TEC §44.031(h) reflects a statutory permission for alternative purchasing methods in emergencies (Permitted by Law component). The cross-reference structure organizing this via CH(LEGAL), CBB(LEGAL), and CV(LOCAL), and the decision to restructure and consolidate the purchasing method language, are locally discretionary editorial and organizational choices.

District-level awards and honors in excess of $2,500 included in scope of non-routine and discretionary purchases Locally Discretionary

Verified via: verbatim statute text

Local additions: The $2,500 threshold for district-level awards and honors, and their inclusion within the purchasing oversight framework, has no statutory basis in the analysis provided. This is a fully local policy determination.

Removal of legacy cross-references (e.g., [See also CB, CBB, CH(LEGAL), and COA]), redundant phrases, and editorial restructuring throughout Locally Discretionary

Verified via: verbatim statute text

Local additions: All deletions of cross-references, removal of redundant language, and editorial restructuring are locally discretionary housekeeping choices not compelled or expressly authorized by any identified statute.

2026-06-16first_reading · Meeting notes

This update to Conroe ISD's Purchasing and Acquisition (CH LOCAL) policy adds new definitions for "Service provider," "Vendor," and "Substantial interest in a vendor," expands Board oversight over non-routine and discretionary purchases, adds a conflict-of-interest section with specific criteria and a procedure requirement, and clarifies the purchasing method authority by adding a CV(LOCAL) exception and referencing methods allowed by Texas law. The revisions align with House Bill 210 from the 89th Texas Legislature (TEC §11.067) while expanding certain protections beyond what the statute requires.

Added

Service provider means a person who provides services to the District. The term includes: (A) A contractor, vendor, agent, or subcontractor for the District; (B) A provider of tutoring services for the District; (C) An entity that has entered into a contract to operate a school district campus under Texas Education Code Section 11.174; (D) A staffing provider for the District; and (E) A person employed by or under the control of a person described above, including its representatives, employees, subcontractors, or any other individuals acting on its behalf.
Vendor means a person, company, individual, contractor, subcontractor, or professional services provider with whom the District enters into an agreement, contract, memorandum of understanding, interlocal agreement, fee schedule, retainer, or similar instrument for goods or services.
Substantial interest in a vendor is defined as an individual who: 1. Owns more than 10 percent of the voting interest in the vendor; or 2. Has a direct or indirect participating interest by shares, stock, or otherwise, regardless of whether voting rights are included, in more than 10 percent of the profits, proceeds, or capital gains of the vendor.
from a vendor (in Purchasing Authority paragraph, specifying purchases are from a vendor)
All service providers shall comply with all Board Policies, including EMB(LOCAL), EFA(LOCAL), EFB(LOCAL), FFG(LOCAL), and FFF(LOCAL), and all other Board Policies or District procedures as appropriate.
District-level (added as qualifier before 'awards and honors in excess of $2,500')
Except as provided by Board Policy CV(LOCAL), t (added exception clause to Purchasing Method paragraph)
methods allowed by Texas law CH(LEGAL) or CBB(LEGAL), as appropriate (replacement reference in Purchasing Method)
Conflict of Interest [entire new section]: A vendor that bids on or receives a contract from the District commits an offense if any individual serving on the Board: 1. Has a substantial interest in the vendor or a subcontractor hired by a vendor; 2. Is related in the second degree by consanguinity or affinity, as determined under Chapter 573, Government Code, to an individual who has a substantial interest in the vendor; or 3. Has received or has been promised a gift or in-kind services with a value of more than $250.
The District shall adopt procedures to ensure neither the Board nor a vendor violates the conflict-of-interest provision in this Board Policy.
District (replacing 'administrative' before 'procedures' in Electronic Bids Or Proposals section)
Board (added as qualifier before 'Policy' in Personal Purchases section: 'this Board Policy')
Texas (added before 'Education Code Section' in emergency contracts section)
Section (added before '44.031(h)' in emergency contracts section)
District (added before 'purchasing procedures' in Purchasing Procedures section)
include, (replacing comma after 'purchases' and before 'but are not limited to' in non-routine purchases intro)

Removed

[See also CB, CBB, CH(LEGAL), and COA] (cross-reference removed from Purchasing Procedures section)
CH(LEGAL) or CBB(LEGAL), as appropriate (old reference text in Purchasing Method replaced)
administrative (removed from 'administrative procedures' in Electronic Bids Or Proposals, replaced with 'District')
Non-routine and discretionary purchases, include (old comma removed and replaced with 'include,')

Legal Compliance Summary

AI-generated assessment. Verify citations independently before relying on this analysis.

Conflict-of-Interest Rules (H.B. 210): Texas House Bill 210 from the 89th Legislature, now codified in Texas Education Code §11.067, required school districts to prohibit board members and employees from certain dealings with vendors. This policy update adds those required prohibitions, including restrictions based on financial interests, family relationships up to the second degree, and gifts or in-kind services worth more than $250.
New Key Definitions: The policy adds definitions for 'vendor,' 'service provider,' and 'substantial interest in a vendor,' with the vendor and service provider definitions going beyond what state law specifies. The district wrote these broader definitions as a local policy choice to clarify who is covered by the new conflict-of-interest rules.
Internal Compliance Procedures: The policy requires the district to create internal procedures for following the new conflict-of-interest rules. Texas Education Code §11.067 sets out the conflict-of-interest requirements but does not specifically tell districts to create these procedures, so this step was added at the district's discretion.
Board Oversight of Purchases: The updated policy gives the Board greater oversight over non-routine and discretionary purchases from vendors. No state law required this specific expansion; it reflects a local governance decision by the district.
Emergency Contracting Authority: The policy now includes a direct reference to Texas Education Code §44.031(h), which allows districts to use alternative contracting methods in emergencies when a delay would prevent or seriously disrupt school operations. The statute permits this option but does not require districts to reference it in local policy.
Service Provider Policy Compliance: The policy states that all service providers must follow several specific board policies covering areas such as safety and student services. No state law requires this particular requirement; it is a local contract management decision made by the district.

Legal Compliance Details Mixed

AI-generated assessment. Verify citations independently before relying on this analysis.

Definition: 'Substantial interest in a vendor' (owning more than 10% voting interest or 10%+ profits/proceeds/capital gains) Required by Law

Statutory basis: TEC §11.067 (H.B. 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Local additions: The district's definition adds a second prong covering indirect participating interests (shares, stock, or otherwise) in more than 10% of profits, proceeds, or capital gains regardless of voting rights. The statute references 'substantial interest' without defining it in the analysis provided; the specific 10% thresholds and dual-prong definition reflect local choices to operationalize the statutory term.

Definition: 'Vendor' Locally Discretionary

Statutory basis: TEC §11.067 (H.B. 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Local additions: The statute uses the term 'vendor' but does not define it in the provided analysis. The district's definition expansively includes persons, companies, contractors, subcontractors, and professional services providers entering into agreements, contracts, MOUs, interlocal agreements, fee schedules, retainers, or similar instruments. This definitional scope is a local policy choice with no verbatim statutory basis in the analysis.

Definition: 'Service provider' (including contractors, tutoring providers, campus operators under §11.174, staffing providers, and agents) Locally Discretionary

Verified via: verbatim statute text

Local additions: No statute in the analysis requires the district to define or regulate 'service providers' as a separate category. TEC §11.174 establishes requirements for campus partnership contracts but does not require the district to include campus operators in a service provider definition. This entire definition is a local policy choice.

Conflict-of-Interest Section: Prohibition — Substantial Interest (prong 1) Required by Law

Statutory basis: TEC §11.067 (H.B. 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Local additions: None. Policy mirrors statutory prohibition verbatim.

Conflict-of-Interest Section: Prohibition — Second-Degree Consanguinity or Affinity (prong 2) Required by Law

Statutory basis: TEC §11.067 (H.B. 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Local additions: None. Policy mirrors statutory prohibition verbatim.

Conflict-of-Interest Section: Prohibition — Gift or In-Kind Services Over $250 (prong 3) Required by Law

Statutory basis: TEC §11.067 (H.B. 210, 89th Leg., R.S.)

Verified via: verbatim statute text

Local additions: None. Policy mirrors statutory prohibition verbatim.

Procedure Requirement: District shall adopt procedures to ensure compliance with conflict-of-interest provision Locally Discretionary

Verified via: verbatim statute text

Local additions: TEC §11.067 establishes the vendor offense but contains no verbatim requirement in the statute analysis that the district adopt internal compliance procedures. The district's self-imposed procedural mandate is a local governance choice to operationalize the statutory prohibition.

Service Provider Compliance Requirement: All service providers shall comply with listed Board Policies Locally Discretionary

Verified via: verbatim statute text

Local additions: No statute in the analysis requires the district to impose compliance obligations with specific board policies (EMB, EFA, EFB, FFG, FFF) on all service providers. This is an entirely local contract management and governance decision.

Board Oversight Expansion: Non-routine and discretionary purchases from a vendor Locally Discretionary

Verified via: verbatim statute text

Local additions: No statute cited in the analysis requires or expressly authorizes the district to expand Board oversight specifically over non-routine and discretionary purchases from vendors. This is a local governance choice.

Exception Clause: 'Except as provided by Board Policy CV(LOCAL)' added to Purchasing Method paragraph Locally Discretionary

Verified via: verbatim statute text

Local additions: The carve-out for CV(LOCAL) creates a local policy hierarchy. No statute in the analysis requires or authorizes this specific exception structure.

Purchasing Method Reference: 'methods allowed by Texas law CH(LEGAL) or CBB(LEGAL), as appropriate' Locally Discretionary

Verified via: verbatim statute text

Local additions: While Texas law (TEC §44.031 et seq.) does govern permissible purchasing methods, the specific cross-reference structure pointing to CH(LEGAL) or CBB(LEGAL) is a local drafting and policy organization choice. No statute in the analysis requires this particular reference formulation.

Emergency Contracts: Statutory reference added ('Texas Education Code Section 44.031(h)') Permitted by Law

Statutory basis: TEC §44.031(h)

Verified via: verbatim statute text

Local additions: The district chose to expressly reference the statutory emergency contracting authority. The statute permits (but does not mandate) use of alternative contracting methods when the board determines delay would prevent or substantially impair conduct of classes or essential school activities.

District-level qualifier added before 'awards and honors in excess of $2,500' Locally Discretionary

Verified via: verbatim statute text

Local additions: The $2,500 threshold and 'District-level' qualifier are local purchasing authority specifications with no statutory basis in the analysis.

Terminology change: 'administrative procedures' to 'District procedures' in Electronic Bids or Proposals section Locally Discretionary

Verified via: verbatim statute text

Local additions: A local stylistic clarification with no statutory basis.

Grammatical and stylistic corrections (capitalization of 'Board Policy'; 'include,' punctuation fix; addition of 'Texas,' 'Section,' 'District' qualifiers throughout) Locally Discretionary

Verified via: verbatim statute text

Local additions: These are non-substantive editorial corrections with no statutory basis.

Removal of cross-reference '[See also CB, CBB, CH(LEGAL), and COA]' from Purchasing Procedures section Locally Discretionary

Verified via: verbatim statute text

Local additions: Removal of a cross-reference is a local policy organization decision with no statutory basis.

2026-02-17adopted · Meeting notes

This update to Conroe ISD's Purchasing and Acquisition (CH Local) policy replaces the prior dollar-threshold trigger for Board approval with a broader "non-routine and discretionary" purchase framework requiring Superintendent notification, adds a detailed definition list of what qualifies as non-routine/discretionary, requires an annual vendor report to the Board, raises the competitive procurement threshold from $50,000 to $100,000, and adds a requirement for the District to adopt procedures to implement the policy.

Added

non-routine and discretionary purchases, not previously included in a Board approved contract or memorandum of understanding, that costs or aggregates to a cost of $50,000 or more to a single vendor over the course of a 12-month fiscal period beginning September 1 of each year shall require the Superintendent to notify the Board in writing approval before a transaction may take place. If two or more Board members timely raise a concern with the purchase to the Superintendent, the purchase shall be timely placed on a Board agenda for Board approval or disapproval. If Board notification is not possible without delaying needed goods or services for District operations, the District may purchase the goods or services but shall notify the Board as soon as practicable thereafter.
Non-routine and discretionary purchases, include but are not limited to, goods or services that are: 1. Non-recurring or one-time purchases; 2. Unusual purchases; 3. Pilot programs; 4. District level awards and honors in excess of $2,500; 5. Purchases that materially differ in type, scope, purpose, or cost from prior purchases; 6. Purchases that do not align with Board Policy EMB (Local), EFA (Local), or EFB (Local); or 7. Purchases for professional services, consulting services, technology systems or software platforms, and large equipment or infrastructure items.
The Board shall be provided annually with a report of all District vendors paid in the previous fiscal year.
$5100,000 (competitive procurement threshold raised to $100,000)
$5100,000 (bids, quotes, and other proposals under threshold raised to $100,000)
The District shall adopt procedures to implement this Policy.

Removed

that costs or aggregates to a cost of $50,000 or more
over the course of a 12-month fiscal period beginning September 1 of each year
approval
$50,000 (competitive procurement threshold)
$50,000 (bids, quotes, and other proposals under threshold)

Legal Compliance Summary

AI-generated assessment. Verify citations independently before relying on this analysis.

Competitive Bidding Threshold: State law S.B. 1173 raised the point at which school districts must use a competitive bidding process from $50,000 to $100,000. This policy update reflects that new legal requirement under TEC §44.031(a), effective September 1, 2025.
Non-Routine Purchase Oversight: No state law requires this, but the district chose to create its own category called 'non-routine and discretionary' purchases. Under this locally created rule, the Superintendent must notify the Board in writing before the district completes certain purchases of $50,000 or more with a single vendor in a fiscal year.
Board Escalation Option: The district added a local rule allowing any two Board members to require that a flagged purchase be placed on a Board agenda for a formal vote. This mechanism is not required by state law and was created entirely by the district under the permissive authority of TEC §44.031(d).
Defining Non-Routine Purchases: The district wrote its own list of seven purchase types that automatically qualify as non-routine, including pilot programs, technology systems, consulting services, and awards over $2,500. No Texas statute defines or requires these categories; they reflect choices the district made on its own.
Annual Vendor Report: The district added a requirement that the Board receive a yearly report listing all vendors the district paid during the prior fiscal year. State law under TEC §44.0331(b) only requires a narrower report on cooperative contract fees; this broader reporting requirement was created locally.
Emergency Purchase Exception: The policy allows the district to skip the pre-purchase notification requirement if waiting would harm district operations, as long as the Board is informed as soon as possible afterward. This exception is not required by state law and was added by the district to its own locally created notification framework.

Legal Compliance Details Mixed

AI-generated assessment. Verify citations independently before relying on this analysis.

Competitive procurement threshold raised from $50,000 to $100,000 Required by Law

Statutory basis: TEC §44.031(a) as amended by S.B. 1173, 89th Leg., R.S. (eff. Sept. 1, 2025)

Verified via: web search confirmed — LegiScan enrolled text, TEA guidance (TAA Sept. 25, 2025 and Nov. 6, 2025 letters), Texas Capitol enrolled bill text, and multiple secondary sources all confirm S.B. 1173 amends TEC §44.031(a) to replace $50,000 with $100,000, effective September 1, 2025

Local additions: None — district policy language mirrors the statutory floor. Note that S.B. 1173 raises the floor at which competitive procurement is required; the district aligned its policy precisely to the new statutory threshold with no meaningful discretionary deviation.

Bids, quotes, and other proposals reference threshold also raised from $50,000 to $100,000 Required by Law

Statutory basis: TEC §44.031(a) as amended by S.B. 1173, 89th Leg., R.S. (eff. Sept. 1, 2025)

Verified via: web search confirmed — same enrolled bill text and TEA guidance as above; conforming reference in the policy to the statutory threshold

Local additions: None — this is a conforming update to the same statutory threshold change.

Non-routine and discretionary purchase framework — Superintendent written notification to Board required before transaction for qualifying purchases of $50,000 or more to a single vendor in a 12-month fiscal period Locally Discretionary

Statutory basis: None — no Texas statute or TAC rule mandates a 'non-routine and discretionary' purchase category or a Superintendent pre-purchase written Board notification requirement. TEC §44.031(d) authorizes the board to adopt rules and procedures using permissive 'MAY' language but does not compel this specific mechanism.

Verified via: web search confirmed — TEC §44.031(d) text verified; no statute found imposing this notification obligation

Local additions: Entirely locally created framework. Statute uses permissive 'MAY' language (TEC §44.031(d)); district chose to create a mandatory pre-purchase written notification obligation from the Superintendent to the Board for non-routine/discretionary purchases at or above $50,000. The $50,000 internal trigger for this notification requirement is also locally chosen and is deliberately set below the new $100,000 statutory competitive procurement threshold, effectively filling an oversight gap the district identified in the space between $50,000 and $100,000 where S.B. 1173 removed the mandatory competitive bidding requirement.

Two-board-member escalation mechanism — if two or more Board members raise a concern, the purchase must be placed on a Board agenda for approval or disapproval Locally Discretionary

Statutory basis: None — no Texas statute requires or authorizes this specific two-member escalation trigger. TEC §44.031(d) authorizes local rules and procedures using permissive 'MAY' language.

Verified via: web search confirmed — no statute found requiring or prescribing this mechanism

Local additions: Entirely locally created governance mechanism. Statute uses permissive 'MAY' language; district chose to establish a minority-of-board veto/escalation pathway. This goes beyond any statutory requirement and reflects a local board governance choice about how to exercise oversight.

Emergency exception — District may proceed with purchase without prior Board notification if delay would harm operations, but must notify Board as soon as practicable Locally Discretionary

Statutory basis: None mandating this specific exception. TEC §44.031 contains a separate emergency exception limited to school facility damage/catastrophic failure, but no statute requires or prescribes this broader operational-delay emergency carve-out. TEC §44.031(d) permits local rules using 'MAY' language.

Verified via: web search confirmed — TEC §44.031 emergency provision verified as limited to facility/equipment emergencies; no statute found mandating or prescribing this broader operational-urgency carve-out

Local additions: Locally crafted safety valve. The district exercised discretion to create a workable exception to its own locally created notification requirement. This is a local policy design choice built on top of a locally created obligation.

Detailed definitional list of what qualifies as 'non-routine and discretionary' — seven enumerated categories including pilot programs, awards over $2,500, technology systems/software platforms, professional/consulting services, large equipment/infrastructure, purchases differing materially from prior purchases, and purchases not aligning with Board Policies EMB, EFA, or EFB Locally Discretionary

Statutory basis: None — no Texas statute defines or requires a 'non-routine and discretionary' purchase category or any of the seven enumerated sub-categories. TEC §44.031(d) permits local rules using permissive 'MAY' language.

Verified via: web search confirmed — no statute found defining these categories or requiring their enumeration

Local additions: Entirely locally drafted taxonomy. The district exercised substantial discretion in defining each category, including the specific $2,500 award threshold, the cross-references to Board Policies EMB (Local), EFA (Local), and EFB (Local), and the enumeration of technology systems, software platforms, consulting services, and large equipment as per se qualifying purchases. These reflect local policy judgments about financial oversight, not statutory commands.

Annual vendor report — Board shall be provided annually with a report of all District vendors paid in the previous fiscal year Locally Discretionary

Statutory basis: None — no Texas statute requires a district-wide annual vendor payment report to the board of this scope. TEC §44.0331(b) requires an annual board report only for cooperative contract management fees, a far narrower obligation. TEC §44.031(d) permits the board to adopt rules using permissive 'MAY' language.

Verified via: web search confirmed — TEC §44.0331 text verified and is limited to cooperative purchasing contract-related fees; no broader annual vendor payment reporting mandate found in TEC Chapter 44 or elsewhere

Local additions: Entirely locally created transparency and oversight mechanism. The district chose to require a comprehensive annual vendor-payment report as a Board oversight tool. This goes substantially beyond the narrower cooperative contract fee reporting required by TEC §44.0331(b) and reflects a local governance choice.

Requirement for the District to adopt procedures to implement the policy Locally Discretionary

Statutory basis: TEC §44.031(d) authorizes — but does not require — the board to adopt rules and procedures using permissive 'MAY' language. No statute compels a district to adopt implementing procedures for a locally created purchasing oversight framework.

Verified via: web search confirmed — TEC §44.031(d) text verified as permissive

Local additions: Statute uses permissive 'MAY' language; the district chose to self-impose an obligation to create implementing procedures. This is a locally chosen structural governance requirement layered on top of a locally created policy framework.

2026-01-20unknown · Meeting notes

This update to Conroe ISD's Purchasing and Acquisition (CH) policy raises the threshold requiring Board approval and competitive procurement from $50,000 to $100,000, adds an exception for purchases made under Texas Education Code §44.031, and adds a new section on contracting with Historically Underutilized Businesses (HUBs).

Added

unless the purchase is made in accordance with Texas Education Code §44.031
$100,000 (replacing $50,000 as the threshold in Purchasing Authority)
$100,000 (replacing $50,000 as the threshold in Competitive Procurement Requirements)
$100,000 (replacing $50,000 in the 'Bids, Quotes, And Other Proposals Under $100,000' heading)
Contracting with a Historically Underutilized Business (HUB) — full new section: 'Nothing in Board Policy may be construed to limit or prohibit the District from contracting with historically underutilized businesses or businesses owned by members of a minority group or by women in accordance with applicable state law; however, all vendors, including historically underutilized businesses, must meet the same qualifications, performance standards, and requirements applicable to all District vendors.'

Removed

$50,000 (prior threshold in Purchasing Authority — replaced by $100,000)
$50,000 (prior threshold in Competitive Procurement Requirements — replaced by $100,000)
$50,000 (prior threshold in 'Bids, Quotes, And Other Proposals Under $50,000' heading — replaced by $100,000)

2025-08-19first_reading · Meeting notes

This update to Conroe ISD's Purchasing and Acquisition policy (CH Local) raises the board-approval threshold from $50,000 to $100,000, replaces prior pre-approval requirements with quarterly cumulative reporting to the Board, and adds a new "Vendor Alignment" section requiring vendors who interact with students to acknowledge and agree to district policies—explicitly prohibiting content on topics such as gender fluidity, Critical Race Theory, DEI, and anti-American sentiments.

Added

$100,000 (replacing $50,000 as the purchasing authority threshold)
shall be reported to the Board in a quarterly report. The District shall provide the Board a cumulative report in December, March, June and September, detailing year-to-date expenditures by vendor that exceed $100,000. Each report shall clearly identify all new vendors for the quarter and include the associated commodity category.
Vendor Alignment section heading (new bold/underlined heading)
To ensure alignment with the District's adopted policies, educational goals, community standards, and all applicable state and federal laws, any vendor or contractor providing services through direct interaction with students—whether in person or via digital means such as online courses, video conferences, video streaming, or other virtual platforms—or through the development, delivery, or distribution of print or digital materials, shall, prior to purchase, acknowledge and agree through a process designed by the Superintendent and approved by the Board to comply with the requirements of EMB (Local). This vendor alignment process specifically prohibits the inclusion of the following topics, except to the extent that the topic is expressly required as part of the Texas Essential Knowledge and Skills (TEKS):
1. Gender fluidity, sexual orientation, gender, transitioning;
2. Pronoun usage inconsistent with biological sex;
3. Social and Emotional Learning Concepts that are divisive, conflict with District policy, and are inconsistent with the District's education goals;
4. Critical Race Theory;
5. Systemic Discrimination Ideologies;
6. Diversity, Equity, Inclusion (DEI); and
7. Unpatriotic, anti-American sentiments.
This requirement includes, but is not limited to services involving curriculum design, in-district professional development concerning direct student outcomes, athletic or professional coaching, student advisory services, specialized lessons, or similar educational or instructional support activities.
Failure to adhere to the terms of this Vendor Alignment, or any verified misalignment with the District's policies or community values as stated, may constitute grounds for immediate termination of the contract, subject to applicable contractual and legal provisions.
$100,000 (in competitive procurement threshold on page 3)
$100,000 (in 'Bids, Quotes, and Other Proposals Under $100,000' subheading on page 3)

Removed

$50,000 (prior purchasing authority threshold — shown as $5̶0̶,000)
beginning September 1 of each year shall require Board approval before a transaction may take place,
$50,000 (in competitive procurement threshold on page 3 — shown as $5̶0̶0,000)
$50,000 (in 'Bids, Quotes, and Other Proposals Under $50,000' subheading on page 3)