Untitled Texas Attorney General Opinion

QBfficeof tty JZlttornep@enera diMateof Qexas DAN MORALES ATTORNEY GENERAL June 6,199s Mike Moses, Ph.D. Opiion No. DM-350 Commissionerof Education Texas Education Agency Re: Whether purchases made by a local 1701 North Congress Avenue government through the state catalogue Austin, Texas 78701-1494 purchasing procedure established by article 6Olb, section 3.081, must be competitively Honorable John W. Segrest bid (RQs-744,754) CriminalDistrict Attorney McLennan County 209 North Sii Street, Suite 200 Waco, Texas 76701 Dear CommissionerMoses and Mr. Segmst: We have been asked whether purchases made by local governments through the state catalogue purchasing procedure establishedby article 6Olb. section 3.081, V.T.C.S., must be competitively bid. Section 3.081 establishes a state catalogue purchasmg procedure whereby vendors wishing to sell or lease automated information systems to certain state agencies apply to the General Services Commission (the “commission”). A state agency may purchase or lease automated information systems directly frbm vendors who have been designated as qualified information systems vendors by the commission. Subsection (g) of section 3.08 1 provides as follows: The commission shall make the catalogue purchasing procedure enumerated in this section availableto local govemments that qualify for cooperative purchasing under Sections 271.082 and 271.083, Local Guvemtnent Code. In this subsection, “local government”has the meaning assigned to it by Section 271.081, Local Government Code.1 V.T.C.S. art. 6Olb. 8 3.081(g) (footnote added). ‘See Local God code 5 271.081 (ddioing “local govmmmt- to mm0 -II afmlty, mlmicipality, q&al dirtriff s&Jo1 disuic& juoior aluege distriq or other lcgdly constiMcd politicd -00 of thestate”). Mike Moses, Ph.D. - Page 2 (DM-350) Honorable John W. Segrest Subchapter D of chapter 271 of the Local Government Code provides for state cooperation in local government purchasing programs. Section 271.081 of the Local Government Code ddines “local government”to mean “a county, municipality, special district, school district, junior college district. or other legahy constituted political subdivision of the state.” Section 271.082 requires the commission to “establish a program by which the commission performs purchasmg services for local governments.” The services must include the following: (1) the extension of state contract prices to participating local governmentswhen the commissionconsiders it feasible; (2) solicitation of bids on items desired by local governments if the solicitation is considered feasible by the commission and is desiied by the local government; (3) provision of tiormation and technical assistance to &al governments about the purchasingprogram. Local Gov’t Code 8 271.082(a)(l) - (3). Section 271.083 provides that a local govemment may participate in this purchasing program by 6ling a resolution with the commission adopted by its governing body requesting that the local govetnment be permitted to participate. Id. 8 271.083(a)(l). The resolution must also state that the local government will designate a representative to act for the local government with respect to the program, will be responsible for submitting requisitions to the commission and for payment to the vendor, and wig be responsible for the vendor’s compliance with all conditions of delivery and quality. Id. 8 271,083(a)(2), (3). SignGantly, subsection (b) of section 271.083 provides as follows: A local government that purchases an item under a state contract satisfies any state law requiting the local government to seek competitive bids for the purchase of the item. Mr. Segrest explains that McLennan County (the “county”) is a member of the cooperative purchasing program established under sections 271.082 and 271.083 of the hc.al Government Code. The commissionrecently advised the county of the opportunity to purchase automated information systems through the state catalogue purchasing procedure. The commission’sletter states in pertinent part: Article 601b, Section 3.081(g), V.T.C.S., mandates that the General Services Commission “make the Catalog Purchase Proce- dure . . gy&& to local govemments that qua@ for Cooperative Purchasing. . . r]; however, this procedure may not satisfy p. 1865 Mike Moses, Ph.D. - Page 3 (DM-350) Honorable John W. Segrest competitive bidding requirements that govern a local government. The rules for this procedure are enclosed and you should seek cmmsel from your legal statf as to whether you may use this procedure or not. Mr. Segrest asks us to resolve the issue raised but not answered by the commission, that is, whether the county is exempted from otherwise applicable competitive bidding requirements when it makes a purchase through the state catalogue purchasing procedure. ~Commissioner Moses’predecessor in office asked essentiallythe same question: Does a purcham by a school district using the catalogue purchasing procedure established by the General Services Commission under Section 3.081 of the State Purchasing and General Services Act satisfy competitivebidding requirements in the same manner as a purchase by a school district under a state contract as provided by Section 271.083(b), Local GovernmentCode? Based upon our review of the applicable statutes,’ we conclude that a local government satisfies otherwise applicablecompetitivebidding requirementswhen it makes a purchase through the state catalogue purchasing procedure. As noted above, section 3.081(g) of article 601b requires the commission to “make the catalogue purchasing procedure. . available to local governments that qualify for cooperative purchasing” under sections 271.082 and 271.083 of the Local Government Code. Section 27 1.083 of the Local Government Code expressly provides that a local government that makes a purchase under a state contract through the cooperative purchasing program “satisties any state law requiring the local government to seek competitive bids for the purchase of the item.” Local Gov’t Code 8 271.083(b). We believe that the legislature, in requiring the commission to make the state catalogue purchasing procedure available to local governments that participate in cooperative purchasing, intended to incorporate the state catalogue purchasing procedure into that program. Thus it follows that a local government purchase made through the state catalogue purchasing procedure “satisfies any state law requiring the local government to seek competitive bids for the purchase of the item”as provided by section 271.083(b) of the Local Government Code. We also believe that subsection (g) of article 6Olb. section 3.081 requires local governments that use the’state catalogue purchasing procedure to abide by the same requirements applicable to state agencies. The state catalogue purchasing procedure p. 1866 Mike Moses, Ph.D. - Page 4 (DM-350) Honorable John W. Segrest requires a state agency, and local governments by virtue of subsection (g), to determine that a purchase or lease is “based on the best vah~ii available and is in the state’s best interest.‘~ See V.T.C.S. art. 6Olb, § 3.081(d) (footnotes added). The requirement that state agencies obtain the “‘best value” demonstrates the state catalogue purchasing procedure is intended as an alternative to competitivebidding for purchases and leases of automated information systems at the state level. See id. 8 3.081(t) (?urchases of automated infonnation systems shall be made through the catalogue procedure enumeratedin this section unless the commissionor state agency determines that the best ‘SccIion1.02(5)of8nkIe 601bdctim the tetm “beatvpluc”to meanthe (F)tbctccbnicalsupponfequircmcntsformaintaunceofdataactossa lb%wWkplPtfnmaadmanaganaItoftherutworl’cbard~alld~and (0) atm@ii with qpliable stathde standa& adopted by tbc DcpMmcnt of lnfonn8tion llclmac MIrubfalucntmtityUvalidatedby critcriaatablirhedbythcdcppNnentM8rubsequmt~ti~inin de. *Subsection(d) of ration 3.081of article 6Olbrequiresa state agencyto considerthe following factorsinderminingwhichpmductsor leIvkes8rclathclI8t8’rbcltimerrrt: (I) installationcost5and hardwareasts; (2) tbeover8lllifeqclea3ltofthrynanMcquipmcnt; (3)eslimatedcostofunployccuaiaingarldertimatcdioacuein~ produc(ivitr, (4) clw8taircdtwpn.8odm8in-colll;88d tpmP~-PwithwP~~le-~adDptcdpy~Dcprtmat RaGlrasM8~aImy8cv8hd8I8dbyultori8 enabliSbCdbytbcdepsr(mcntManrbstqumt~d~~~~e. p. 1867 Mike Moses, Ph.D. - Page 5 (DM-350) Honorable John W. Segrest value available accrues from an alternative purchase method authorized by this Act.“).5 We believe that the legislature intended the same result for purchases and leases of automated information systems at the local level.6 Piiy, it has been suggested that subsection (g) merely requires the commission to make information, i.e., vendor catalogues, available to local governments and that subsection (g) is not intended to make the catalogue purchasing procedure available to local governments as a mechanism to actually purchase products and services. We disagree. Subsection (9) provides that “the commission shall make the catalogue purchasing prucedure enumerated in this section available to local govemments.” (Emphasis added.) Subsection (g) on its face requires that the cstalogue purchasing procedure in its entirety, not just the information compiled in vendor cetalogues about products and services, be made availableto local govemments. %c bills propoktg to amend article 6Olb, V.T.C.S., by adding CCCIIM3.081 and its acoompaoytngdefinitions.section 1.02(4)-(a),wao inttodmxdin the Sovcnty-thirdLegislaturelargelyin mponst to a report fmm the Texas PcrformancoReview.see 2 Tat. Comptrollerof Poblic Aaxmnu, AONNSTTHEGFWN:HIOHQJALITY LOWCOSTGOVEWMENT Fat TEMS (1993). in which the comptrollctofpublic accountsproposednmnorousK&Win8 moasmmfor stategoWnmat. scr Home l’temamht3rganimtion,Bill Analysis,C.S.S.B.381, 73d Lo8. (1993). As immdo@ the bills did not pmposc to establii the catdoguc pomhasingpromdom now set forth in section 3.081; indcod, the comptrollerbad not suggestedthat sucha proccdnmbe implemontcd.Tbe bills wme amauled to add the catalogocpurchasingprom&e wlun they worn in aWmittce. Src Hearingson S.B. 381 Bofomthe SmaIc &MI. on State Affairs, 73d Log. (Mar.3, 1993)(statementof Se&or &Joy, author) (tape availablefrom Senate Staff SW&S); HearingsM H.B. 2626Beforethe Home Comm.on State A5aia. 73d Log. (Apr. 5, 1993)(statamnt of RcprmcntativcE&k) (tape availablefrom HouseVidoo/Aodio ServicesG&e). Senator Haly explainedthat the amendmentwoold enable state agency pxsonncl dirdy to pmdasc computersystems,cofhwc, and tclcc~~onkations badwarc. Hearingson S.B. 381 Beforethe Senate Comm.on State NT&s. 73d Log. (Mar. 3. 1993)(statemomof Senator Haley, author)(tapeavailablefrom HcuscVidcdAudioservicesOf&). Hc liulhcr explainedthat the proposed catalogocpmchasingprocodumwouldallow state agacics to avoid the competitivebiddingp- and inscad find the bca buyson automatedinformationsystems.Id. %okction (t) of section3.081 providesthat ‘~bncha.~ of mttomatul information systems shall be madethroughthe catalogucprocodommmmmatcdin tbir sectiononlcmthe commimionor state agency dctennincsthat the bcc~value availableaccromfrom an altcmativcpurcbaccmcthod.” Gn tbc basis that sobmotion (9) mattes all pmvisiotu applicable to state agencies also applicable to local gctvammts, we believethat a local govamncntmayomanabanativcstatotorypmch&ngmdhodif determine5that it is ncce5saryto&soinor&rtecbUinthebcstvalucavailable. p. 1868 Mike Moses, Ph.D. - Page 6 (DM-350) Honorable John W. Segrest SUMMARY A local government that participates in the cooperative purchasing program established under sections 271.082 and 271.083 of the Local Government Code satisfies otherwise applicable competitive biddmg requirements when it makes a purchase through the catalogue purchasing procedure established by article 601b. section 3.081, V.T.C.S. DAN MORALES Attorney General of Texas JORGE VEGA First Assistant Attorney General SARAH J. SHIRLEY Chair, Gpiion Committee RCparedbyMaryRCrouta Assistant Attorney General p. 1869