AGENDA TITLE:
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Approve Revisions to the Purchasing Policy That Include the Federal Transit Administration (FTA) Procurement Requirements (IS - BUD)
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MEETING DATE:
October 7, 2026
PREPARED BY:
Jennelle Baker, Budget Manager
recommendation
RECOMMENDED ACTION:
Approve revisions to the Purchasing Policy that include Federal Transit Administration (FTA) procurement requirements.
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BACKGROUND INFORMATION:
The City’s Purchasing Policy was most recently revised on July 1, 2026. Since that revision, the Transit Division
of the Public Works Department underwent an extensive Federal Transit Administration (FTA) audit. As a result
of the audit, the FTA requested that the City update its Purchasing Policy to more clearly incorporate Federal
procurement requirements applicable to FTA-funded purchases. The proposed revisions are intended to
strengthen the City’s compliance procedures and help ensure the continued eligibility of expenditures for federal
funding and reimbursement.
DISCUSSION
The proposed updates to the Purchasing Policy to comply with FTA purchasing requirements are summarized
below:
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22-23 |
Establishes general requirements for FTA-funded rolling stock and related equipment purchases, including compliance with federal requirements, coordination with grant specialists, and retention of certifications and supporting records. Rolling stock refers to vehicles used to transport passengers or support public transportation services. |
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23 |
Requires Buy America pre-award and post-delivery reviews for applicable rolling stock purchases and requires staff training and documentation. The Federal Transit Administration’s (FTA) Buy America requirements apply to purchases funded with FTA grants and generally require manufactured products used in federally funded transit projects to be produced in the United States. For transit vehicles and other rolling stock, at least 70 percent of component costs must be produced domestically, and final assembly must occur in the United States. |
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23 |
Clarifies that using a cooperative or intergovernmental purchasing agreement does not relieve the City of its responsibility to verify federal clauses, certifications, Buy America compliance, and suspension and debarment requirements. |
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23-24Requires an Independent Cost Estimate before receiving bids or proposals and a documented cost or price analysis for federally funded procurements exceeding the federal Simplified Acquisition Threshold, including applicable contract amendments. |
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25Establishes a Federal Clauses Checklist to ensure required federal provisions are reviewed and incorporated before a federally funded contract is executed. It also requires periodic review of federal requirements and staff training. |
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26 |
Adds language explaining that FTA-specific requirements may apply to federally funded transit procurements, including requirements related to rolling stock and related equipment acquisitions. Departments shall consult applicable FTA guidance and ensure applicable requirements are incorporated into procurement documents, contracts, and supporting documentation. |
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27 |
Requires contractors and applicable lower-tier participants to be checked in SAM.gov for suspension or debarment, with evidence of the verification retained in the procurement file. |
FISCAL IMPACT:
If these recommended revisions are not incorporated into the Purchasing Policy, the City’s ability to make purchases using FTA funds and receive reimbursement for eligible expenditures may be affected. Noncompliance could result in delayed or denied reimbursements, questioned costs, or other corrective action by the FTA.
FUNDING AVAILABLE:
Not Applicable.