REVIEW PRACTICE 4 · IN DEVELOPMENT
Procurement Integrity Review
The largest recurring transfer out of most governed bodies is not compensation. It is what they buy, from whom, at prices nobody tested.
Procurement is where a governance failure becomes a number. A board that never sought a second quote has not necessarily overpaid — but it has made it impossible for anyone, including itself, to know.
The gap this addresses
Many member-governed and quasi-public bodies operate with no bid threshold, no conflict register, and no disclosure of what the intermediary who recommended the vendor receives from that vendor. The spending is visible in the financial statements. The process that produced it is not documented anywhere.
These points are answerable from minutes, contracts, and invoices. Where the answer is that no record exists, that is the finding.
What this review is not
- It makes no allegation that any price was inflated or that any payment was improper. It measures whether the process was capable of detecting either.
- It is not an audit, examination, or investigation within the meaning of any professional standard, and it produces no assurance.
- It is not legal, accounting, or tax advice. See our Terms.
- A review point that resolves against an entity is a question, not a conclusion. Every published finding is designed to state the document it came from and the answer that would close it.
- Where a TASFGA researcher, founder, or board member is a member, party, or complainant in a matter concerning an entity, TASFGA does not publish a review of that entity. See Methodology.
The review points
11 points, grouped by what each tests. This set is a draft. It would be versioned, opened for public comment, and re-applied to every prior review when it changes, in line with our Methodology.
The process
- Threshold policy. Whether an adopted policy sets a value above which competitive quotes are required, and who set it.
- Bids actually obtained. For each material award, how many quotes were sought, how many were received, and whether the minutes record them.
- Scope parity. Whether competing bids priced the same scope, or whether the comparison was between different jobs.
- Sole-source justification. Where only one vendor was approached, the stated reason and whether the board recorded accepting it.
The intermediary
- Referral and rebate income. Whether the manager, agent, or professional who recommended the vendor receives anything from that vendor, and whether it was disclosed to the board in writing.
- Supervision markups. Fees charged for overseeing work, how they are calculated, and whether the calculation appears in the management agreement.
- Affiliates. Vendors under common ownership or control with the manager, an officer, or a board member.
- Insurance placement. Who places the entity’s coverage, what commission is earned on the placement, and whether the market was tested.
What happened after the award
- Change orders. Cumulative change orders against the original award, and whether any threshold that triggered competitive bidding was re-tested.
- Contract term and renewal. Duration, automatic-renewal terms, notice required to exit, and when the engagement was last competed.
- Vendor concentration. Share of total expenditure going to any single vendor, and whether the financial statements disclose it.
Where this applies
- Residential community governance — managing-agent referral economics, capital-project awards, insurance placement.
- Municipal governance — Business Improvement District contracting and sole-source awards.
- Public agencies — emergency-procurement exceptions and their frequency.
- Hospital & health boards — group-purchasing arrangements and trustee-connected suppliers.
- Corporate & institutional boards — pension and endowment manager selection and fee structures.
How this connects to the rest of the work
A bid threshold, a written conflict disclosure from the recommending intermediary, and disclosure of any vendor taking more than a stated share of expenditure are the three provisions that make this reviewable at all. They belong in a model procurement standard.
The in-field evidence base for Focus 1 — building by building, firm by firm — is published at condoscoopsnyc.org, which documents the underlying statutory gaps this practice was built to detect.
Other review practices
Audit & Financial Records Review
Audited statements, budgets, and the records behind them, tested against the governing instrument.
REVIEW PRACTICE 2Election Conduct Review
Ballot access, notice, proxy custody, and who counts the votes.
REVIEW PRACTICE 3Records Retention & Access Review
A right to inspect is worth nothing if nothing was required to be kept.
REVIEW PRACTICE 5Member Speech & Retaliation Review
What happens to the member who asks, and who pays for the answer.
REVIEW PRACTICE 6Data Governance & Payment Security Review
Who can move the money, who holds the credentials, and who is told when it goes wrong.
REVIEW PRACTICE 7Vendor & Professional Credential Review
The qualifications of whoever wrote the report the board is relying on.
TASFGA is pre-incorporation. This review practice is a published draft, not an offered service, and no engagement is available. Members of a governed body who wish to apply these points to their own entity are free to do so.