Purchasing and Acquisition

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• 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.

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• 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.

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• 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.

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