Public Forum Transcript

ST OF CA-REHABILITATION-CAL2

Moderator: Christina Burgoa
November 17, 2017
11:00 am CT

Cara:

Welcome and thank you for standing by.  At this time, all participants are in a listen only mode until the question and answer session of today’s conference.  At that time, you may press Star One on your phone to ask a question.  I would now like to turn the conference over to Miss Connie Nakano.  Thank you, you may begin.

Connie Nakano:

Thanks, Cara. Welcome, everyone. This is Connie Nakano, the Public Information Officer for the Department of Rehabilitation. I wanted to thank everyone for joining the call. Today weíre very pleased to share information regarding a change of expenditure approvals.

At the end of the call, transcripts will be provided.  We will get those translated and it’ll take approximately two to three weeks before we post it on our website. So with that in mind, I will now toss it over to Kelly Hargreaves, our Chief Deputy Director.

Kelly Hargreaves:

Good morning, thank you all for joining us.  It looks like we have a very big crowd participating in our phone call.  The holding public forums, such as this call, became customary in 2014 after the propagation of the Workforce Investment Opportunity Act, so that we could share what we were learning with our internal and external stakeholders, both individuals and groups and for them to also anticipate changes to their organizations and operations. It's also consistent with our core value of seeking stakeholder input, and our commitment to transparency.

The specific reason for the call today is to alert you to potential delays in the Department approval and granteeís approvals of goods and services.

Before I explain the history, Iíd like to have each of our folks who are around this table with me introduce themselves by name and title, so that you know whoís in the room and who is available to ask questions of when we get to the question and answer period. And Iíll start to my left with Mark Erlichman.

Mark Erlichman:

Good morning, my name is Mark Erlichman. Iím an Assistant Deputy Director in our Employment Division.

Peter Harsh:

Good morning, my name is Peter Harsh. Iím the Deputy Director for our Employment Division.

Simone Dumas:

Good morning, my name is Simone Dumas. Iím the Chief of Contracting and Procurement.

Fariba Shahmirzadi:

Good morning, Iím Fariba Shahmirzadi. I am the Deputy over the Administrative Services Division.

Kerry Gantt:

Good morning. Iím Kerry Gantt. Iím a Supervising Management Auditor in the Executive Division.

Kathi Mowers-Moore:

Good morning. Iím Kathi Mowers-Moore, Deputy Director for Vocational Rehabilitation Policy and Resource Development.

Morgan Staines:

Good morning, everyone. This is Morgan Staines, Iím Chief Counsel here.

Nelson Sheya:

Hi, Nelson Sheya, Communications and Legislative Analyst.

Michele Reynolds:

Hi, everyone. Michele Reynolds, Deputy Director of Legislation and Communications here at the department.

Connie Nakano:

Good morning, this is Connie Nakano, Public Information Officer.

Kelly Hargreaves:

And our director, Joe Xavier is traveling right now back from South Carolina where he was meeting with several other states around the nation where we talked about the issue weíll be talking about this morning along with other things.

The specific issue is regarding a prior approval by our oversight agency, US Department of Education Rehab Services Administration. In 2014 the Department of Education adopted a regulation which had the effect of imposing requirements on other department and all grantees nationwide for not only the Vocational Rehabilitation Grant, but Independent Living Services Grant.

Since 1995 as part of the paperwork reduction act at the Federal level, the department and other VR agencies and independent living grantees were exempt from these provisions, because the Secretary of Education had specifically found that the paperwork involved with seeking preapproval outweighed the additional benefit of the checks and balances.

We are in good company nationwide with the majority of states being surprised that the preapproval requirement for goods and services applies now. So we are all coming up to speed with the expectations of the US Department of Education. These are folks nationwide did not recognize that there was this impact or assumed that it was exempt because of the 1995 exemption.

The Rehab Services Agency has really changed its approach in providing support and technical assistance to departments. And in that effort we have been receiving advice and assistance for the last, most intensively the last couple of weeks regarding its expectations of the documentation thatís required in order to speed their review.

We submitted a request for preapproval in accordance with their expectations and got a response back as soon as one day, but there have been other accounts by other states of not receiving approval for up to eight weeks. So weíre new at this, weíre not sure how much it will impact you or be a matter delay, but weíre working on our side to streamline our processes to get the information to the Rehab Services Agency as quickly as possible to minimize any impact.

We may, we are considering, we may be joining other states in asking the Secretary of Education to once again exempt vocational rehab and independent living services because of the potential impact on consumers and our grantees. Absent that change, however, weíre moving forward with the requirements of the Federal regulations for preapproval and working with RSA around the next steps.

At this point, Iíd like to turn it over to Kerry Gantt to begin discussing some of the areas in which we anticipate a delay.

Kerry Gantt:

Thank you, Kelly. So as Kelly was mentioning, the Federal guidance that specifies the items of cost that will require preapproval is located in Title Two of the Code of Federal Regulations Part 200. There are several items of cost identified there in, however in recent conversation with RSA, we have learned there are about 15 items that we will be working with them directly to clarify how we shall seek prior approval on those specific items.

Today, for the purpose of this call, we wanted to highlight a few of those items of cost that we feel will be most impactful or that are most prevalent to the work we do on a daily basis.

So the first item relates to equipment. And the parameters surrounding equipment identifies that we, as a department, may not encumber or may not authorize equipment until we seek out and receive that prior written approval from our Federal awarding agency. Equipment is typically defined as a personal item of property that we would purchase. It could be information technology or part of an integrated system, or an item of equipment for use by a consumer. And it would have to have a useful life of more than one year or an item cost of $5,000 or more.

So we feel that is one particular item that may have the most impact because in our normal course of business, we may purchase a significant amount of equipment for use in both administrative purposes and/or for use by our consumers in accordance with their individual plan for employment.

The next item, Morgan is going to talk with you a bit about, relates to our capital expenditures.

Morgan Staines:

Thanks, Kerry. Capital expenditures are expenses rather than equipment, but typically are improvements. Common examples are improvements to real estate, such as tenant improvement. They could also be higher cost improvements to equipment as opposed to the purchase of the equipment.

And those are, we anticipate thereíll be a price level there of $5,000 based in part on our own accounting standards and practices. The Federal rule actually doesnít have that same threshold that it has for equipment, but we anticipate that it will likely be in that area.

So the areas of our business where we think these are most likely to take place. We have some consumer purchases which, from time to time, which could be in this area if we determine that it was appropriate to provide a consumer service such as some improvement to real property, to their home or apartment for access purposes. Or to be able to use other equipment that we provide to them. Thatís a possibility.

Vehicle modifications, which we provide from time to time, would also be in this category of a capital expenditure. We think this one will also affect our Business Enterprises Program for the blind or blind vendors as we sometimes do tenant improvement in the site that those vendors work in. So those would be affected by this also.

Of course our own purchases here for the departmentís use. If we improve our, we pay for tenant improvements in our offices, which we do from time to time, depends on our relationship with the landlord. Sometimes they pay, sometimes we do. If we pay, presumably would be subject to this obligation.

And then finally the last category is some of our grantees in independent living and older individuals who are blind grant program, if capital expenditures are made there, again the most common area for this is tenant improvement. Those will also be subject to it, and weíll be working our process to approve those specifically for grantees. There are some possibilities for us to simplify the approval process a little bit in that area with cooperation of our federal partners.

So those are capital expenditures. They are not our most common item, but they do affect the range of our stakeholders and consumers.

And Iím going to hand it off to Kathi Mowers-Moore now whoís going to talk a little bit about traveling expenditures. Kathi.

Kathi Mowers-Moore:

Oh, thanks. Good morning, everyone, and we really appreciate the large number of you who have joined us on this call today. And we greatly appreciate your participation and your interest on these critical areas.

Iím going to be speaking about an area thatís identified in the Regulation as Participation Support Cost. The citation is 2CFR200.456. This is specifically regarding travel and per diem and costs associated with travel and with non DOR employees.

One of the critical elements here is that there is not a dollar threshold. So that the other areas weíre speaking of here utilizes $5,000 or more. In this circumstance, when weíre talking about non-employee travel, there is no dollar threshold. If itís a hundred dollar travel expense, we would need to acquire pre-approval. At this time, we do not believe that this impacts consumers. We are working together with RSA for clarity in this area. We do believe the primary area of impact in this area of the regulation is in regards to travel associated with our advisory body and other nonemployee committee participation.

It requires that in advance of any travel that we seek and acquire the preapproval of the Rehabilitation Services Administration. So Iím going to use a real life example. This week our state rehabilitation counsel was meeting for its regularly scheduled quarterly meeting. In advance of this, we were required to reach out to RSA with very specific information that included the names of the individuals traveling, the cost of each component of that individualís travel including the cost of meals, the cost of transportation, even the cost of Uber. And we needed to send all of that information as a spreadsheet to our partners at Rehabilitation Services Administration.

I must here very publicly thank them for acting so very quickly on this request that we submitted last week. And because of their expedited approach to this, we were able to move forward with our regularly scheduled quarterly meeting of our very important advisory committee.

There are other advisory committees that we did need to cancel this week because we were not able to complete the request for preapproval for travel. We are working with our federal oversight entity and for other boards and commissions that may be impacted by approval of other entities other than Rehabilitation Services Administration. It would be important for your boards and commissions to identify to whom you need to seek preapproval. But in this circumstance, we will be working with RSA for the state rehabilitation counsel as one example of getting preapproval for calendar year 2018 meeting travel expenses.

Again, at this point, we do not believe that this will impact consumer travel and we are seeking additional information regarding other partners. Particular contracted partners we donít have clarity on that yet.

With this Iím going to pass the conversation back to Kerry to speak of membership of civic and community organizations.

Kerry Gantt:

Thank you, Kathi. So this particular item of cost, membership, subscriptions and professional activity costs is identified in Citation 200.454 and the premise of this particular item discusses that cost of membership in any civic or community organization are allowable with prior written approval from the federal awarding agency. Those types of organizations could include Rotary Club, Lions Club and similar types of organizations.

Prior written approval; however, is not required for cost of membership or subscriptions to business, professional and technical organizations and/or periodicals. Those might include CSAVR, LinkedIn, and perhaps even the Chamber of Commerce.

We are continuing to seek clarity surrounding that particular item of cost, but that could possibly be impactful for both our staff and the consumers we serve.

We just also want to assure you that as we continue to do business here at the department, we will be diligent in presuming and clarifying that the items we put forward to purchase are both necessary and allowable.

That will continue to be the case even though we are now having to seek an additional layer of approval; we will be diligent in our regular course of business, as we always have been. So we do not anticipate, while it may take additional time to seek the approval, we do not anticipate that RSA will be disallowing any particular cost that we put forth.

Iím now going to turn it over to Fariba whoís going to talk a little bit about next steps in this process.

Fariba:

Thank you, Kerry. And again thanks to all of our callers today. We appreciate this opportunity to hear from you as well. So for our next steps we plan to continue receiving clarification from the Rehab Services Agency on the questions that we receive today and continue to receive regarding this topic and share our responses, and the responses we receive on a frequently asked questions format posted on our website as soon as we can.

Weíre also going over our internal processes to mitigate any unnecessary delay and minimize the impact on our consumers and services. Weíll be tracking the timeline of the requests sent to federal agencies, and when we receive them back to inform the requesters right away and to use the timeline for any future necessary planning that we can offer.

I think at this point, Iím going to turn it to Connie to open for questions.

Connie Nakano:

Thank you, Fariba. At this time we are going to move to your questions. We will be unmuting the line and Cara will be assisting us with the questions in queue.

I know weíve got a lot of people on the line and weíd like to thank you for your participation, especially for staff thatís listening in. We want to just remind staff to hold on to your questions since weíve got an internal channel for you to ask your questions. Weíd like to leave this time for our external partners to ask their questions.

So, Cara, letís open up the line.

Cara:

Thank you. We will now begin the question and answer session. If you would like to ask a question, please press Star One, unmute your phone and record your name clearly. Your name is required to introduce your question. If you need to withdraw your question, please press Star Two.

Again, to ask a question, please press Star One. It will take a few moments for the questions to come through. Please stand by.

Our first question comes from Mitch Pomerantz. Your line is open.

Mitch Pomerantz:

Yes, good morning. I have a number of questions, but Iíll confine it to two. First and most importantly, the $5,000 figure, does that include things such as sales tax, training, which usually goes along with the purchase of assistive technology, and does it include specifically for BEP vendors, the installation of equipment which is also not free.

Second question has to do with when will your counselors be made aware of the new regulations? Thank you.

Kelly Hargreaves:

This is Kelly Hargreaves. We did send out information to our staff yesterday. As the team here has indicated we donít have all the answers. And they all, I would say most if not all on the phone right now listening in as well, theyíll receive additional training.

We have a process internally for those goods like vending machines that automatically go up through a channel in our central office to comply with the state requirements about procurement for items over that dollar amount, so that all gets funneled into our contract section already. And so there wonít be, other than the awareness, any change in the counselorís approach. As Kerry described, weíre going to continue with business as usual. Weíre not going to be declining to make certain purchases because of this preapproval.

So thatís for things like the BEP vendor. Equipment, anyway, that is going through our contracts office has been very much involved. And our Chief of Contracts, Simone Dumas, is here at the table.

Whether or not the procurement includes taxes I donít think it does. And Simone is shaking her head, no, it doesnít. And I am not aware of, although weíll double check whether the installation and any of the service, it doesnít appear that the service would be covered.

Oh, may I say anybody else at the table that might be able to provide you additional information.

Kathi Mowers-Moore:

So this is Kathi. The only area where there might be some overlay is as Morgan previously noted, there is some areas of tenant improvement type expenditures. The example used in the regulations, were things such as removing cubicle walls. So if as part of installation, which may be a separate service, but if there are identified areas that could be considered tenant improvement that might hit that threshold.

Mitch Pomerantz:

I asked you about training.

Kelly Hargreaves:

Oh, you didnít say training.

Mitch Pomerantz:

I did.

Kathi Mowers-Moore:

Your line is open, Mitch.

Mitch Pomerantz:

Let me ask what about training, because training again is an important aspect of the provision of assistive technology.

Kelly Hargreaves:

So this is Kelly again. We all do not believe that training the consumers or BEP vendors will be affected. However as Kathi mentioned, if there is travel, for instance when the BEP vendors assemble like they did last weekend, that is subject to the approval process. Traveling expenses, if they exceed $5,000 as a group, they have to be approved. But notÖ Oh, Iím sorry. No price limit on that one. The traveling does have to receive preapproval before we can utilize the grant fund. But the actual training itself is not subject.

Mitch Pomerantz:

No, Iím sorry. Iím not talking about training of vendors. Iím talking about the training of the consumer who is having the assistive technology purchased for them. That adds to the cost, and may in many cases take the cost of a purchase order over that $5,000 threshold. So thatís the training Iím referring to.

Simone Dumas:

Hi, this is Simone. I just want to clarify that based on the CFR200, our interpretation is this only has to do with the purchasing of equipment, so training would not be included in that total. Does that help clarify your question?

Mitch Pomerantz:

It does. Thank you very much.

Kelly Hargreaves:

Thank you, Mitch.

Cara:

The next question comes from Steven Clark. Your line is open.

Steven Clark:

Thank you. During the presentation on the purchase of equipment, the statement was made that the department can encumber equipment that has a useful life of more than one year, or a per unit acquisition cost. That was said during the presentation. But in the actual write up it says one year and per unit acquisition cost of $5,000 or more. So I just wanted to clarify itís the and in there. And my question about that is how are we defining per unit acquisition cost? Is that a single purchase order over $5,000? Is it a single item on the purchase order over $5,000?

And then I have a second question about travel for FPF vendors. We often quote a line item of travel to go, if weíre traveling significant distance to do training. Is that affected by any of these changes and regulations?

Kathi Mowers-Moore:

There are questions, Steven, this is Kathi. Iím going to turn this over to Kerry just really quickly as it relates to the per item cost. What I can tell you is that RSA looked directly at our state standards around the way in which items are cost here in California. And it is the per item cost. And so Iím going to use a different example and then turn it over to Kerry.

In general we would use, if we are purchasing two hearing aids at the cost of $2,700 each for a consumer. Each hearing aid is a specific cost. And so because each of the hearing aids does not rise above the $5,000 threshold, we would not be required to obtain prior approval.

So Iím going to turn it over to Kerry as well.

Kerry Gantt:

Thank you, Kathi. Yes, I wanted to confirm that your understanding was correct. It is a useful life of more than one year and a per unit acquisition cost. And it is per item, as weíre understanding it. However, the caveat to that would be say we were purchasing an information technology system or an integrated system therein, there could be several lesser price components. But the system collectively would be the $5,000 or more threshold.

Steven Clark:

So if a person is getting a computer with a lot of stuff that goes with a computer, and $4,000 braille display thatís going to put it up over the $5,000 limit. Is that considered a single per unit or is that still two units because itís a computer and itís a separate braille display?

Kerry Gantt:

I believe those would be separate as they are not necessarily an integrated system, they just complement one another. But we will continue toÖ

Steven Clark:

Well they are technically under the way that weíve been working for the last year or so, I think that was an integrated system because the braille display requires the computer system in order to function.

Kerry Gantt:

So we will, Iím going to let Simone jump in here and just to assure you that we are going to get absolute clarity on those items of cost. Simone?

Simone Dumas:

Oh, hi. So just a little bit of clarification, what Kerry mentioned, is if itís an integrated system, and you are correct, we made the purchase order as assistive technology device associated with an integrated system.

However, if we purchase that system on one authorization, yes, would be prior approval would be required. So we will be taking a closer look at it and if you would like further clarification, please submit your questions and we will be gathering those for FAQís.

Steven Clark:

Okay, thank you. And then on the travel question, primarily for STF vendors, are we affected by this?

Simone Dumas:

No, youíre not affected.

Steven Clark:

Okay, thank you.

Kathi Mowers-Moore:

Thank you, Steven. Weíre ready for the next question, Cara.

Cara:

The next question comes from Susan Levesque. Your line is open.

Susan Levesque:

Good morning. Just kind of concerned about what you guys discussed regarding travel guidelines. I just want to clarify as RDR counselors, we facilitate them access to our schools to do intakes and participate in activities and services. Will those kinds of travel events be affected by your new guidelines?

Kathi Mowers-Moore:

Susan, thank you so much for your question. This is Kathi. As we noted this does not impact DOR employee travel.

Susan Levesque:

Okay.

Kathi Mowers-Moore:

So this is nonemployee travel. This may, however, and we are seeking clarification, as you know with our third party cooperative agreement there is line items in our third party cooperative agreement as it relates to travel. That is one of the areas where we are seeking additional clarification, as we speak. But in regards to all of our staff reaching out and as part of their normal and customary business, going to our school sites, this does not impact that at all.

Susan Levesque:

All right, thank you.

Kelly Hargreaves:

Thank you, Susan.

Cara:

The next question comes from Toni Chapman. Your line is open. Toni Chapman?

Toni Chapman:

Yes, good morning. Yes, hello there. I just wanted to find out with the travel every quarter, how far in advance do we need to know or to give you information about where weíre going for the trip? Because weíre working with CRS, so thank you.

Kathi Mowers-Moore:

Good morning, this is Kathi. Let me frame the issue around travel. The primary issue around travel that we are speaking of is travel associated with advisory bodies, boards and committees. The staff associated with each of our advisory bodies will be working to obtain preapproval in advance of all meetings that are scheduled.

RSA is asking for 30 daysí notice in those requests. Having said that, Iím not sure whether your question is in regards to that. Could you give me a little bit more about the travel that you were speaking of? Toni Chapman:

No, that was exactly right. That was it. Thatís what I was, thank you.

Kathi Mowers-Moore:

Okay, so if you are a member of an advisory body that gathers together utilizing grant funds, we are working internally with all of the staff associated with those advisory bodies to ensure that they have an excellent template and have the tools they need to work with each of their members to plan for those travel expenditures and preapproval. You need not do anything as a specific member. We just wanted to insure that the members of all of our advisory bodies and organizations understood that this is a new wrinkle in planning for your meetings. Thank you for your questions.

Cara:

As a reminder, if you would like to ask a question please press Star One on your phone.

The next question comes from Lisa Nash. Your line is open.

Lisa Nash:

Hi, good morning. With regard to the travel provision, Iím speaking as it relates to DOR contractors. Do the contractors need to seek approval directly from RSA or do we continue to submit our request and the spreadsheet that was talked about earlier to our contract administrators?

Kathi Mowers-Moore:

This is Kathi. Could you repeat that question again? My apologies.

Lisa Nash:

With regard to the travel provision do contractors need to send their travel approval request directly to RSA for preapproval with a spreadsheet, or do we continue to provide our request for preapproval to our contract administrators at DOR?

Kathi Mowers-Moore:

Thank you so much for the question. None of our stakeholders and contractors will be asked to nor will you be involved with the direct request to RSA. We will handle that. We will work with all of our advisory bodies as well as our contractors. I want to make sure that I also identify that weíre talking about travel costs as well as registration fees associated with training projects as well.

So in the arena of our community partners traveling for their daily business doing the business of the department, we will seek additional clarification, but do not expect that to be impacted. It is impacted absolutely as it relates to conferences and registrations for things such as that and then particularly for our advisory bodies it impacts our quarterly meetings or other meetings that are scheduled for the business of those advisory bodies.

Lisa Nash:

I understand. Can I ask one more question just for clarification?

Kathi Mowers-Moore:

Yes.

Lisa Nash:

Okay, so with regard to our program staff as it might travel to conferences related directly to providing services to the consumers, the spreadsheet that details the who, what, where, when and all of the details and anticipated costs, is there any allowance if there is any type of expense that might be incurred during the course of that that was not expected in advance?

Kathi Mowers-Moore:

This is Kathi and thank you for your question. To date we have not received confirmation that such allowance for unexpected expenditures would be allowed.

Lisa Nash:

Okay, thank you.

Kathi Mowers-Moore:

Thank you.

Cara:

The next question comes from Robert Hand. Your line is open.

Robert Hand:

Hi. I guess maybe this is the same question. Iím just trying to make clear, so like if as an independent living center, if weíre going to a state association meeting, do we need to get preapproval for that expense?

Kathi Mowers-Moore:

Bob, itís so nice to hear your voice. This is Kathi. I hope you are well. In regards to the independent living centers and state association meetings, we are presuming yes, it would require prior approval for that travel. We will be working with RSA and ACL to confirm this. And Victor Duron is involved with some of the communications in regards to this and I know that he will be providing additional information as we have it.

Robert Hand:

Great, thank you.

Cara:

The next question comes from Harry Bezine. Your line is open.

Harry Bezine:

Hi. I donít have a question, I have a comment expressing I think the opinion of the vendors in this process. Most of you know that we are in a very difficult situation regarding the procurement of the equipment because of the layers of the bureaucracy that is already in place for this process.

The reason I donít have a question because we know whatís going to happen in this process. Itís going to add another layer of bureaucracy. And I donít know how they can think of this issue this way and try to set a procedure without thinking that Ė the reason Iím saying this is because the way we are calculated there are almost a thousand orders for procurement per week nationwide. And in this process, most probably, even if you take one quarter of it, more than 5,000. Because every equipment is not, I mean although itís not a vending machine, but the equipmentís all run so things like that and many other equipment which are more than 5,000.

And how theyíre going to handle this because already with whatever communication the department has with RSA, and I donít know how theyíre going to handle it and how they can think of this without any further inquiries and so on.

But I just want to express the vendorsí opinion on this issue that this is going to make it a difficult situation much more difficult.

Thank you.

Kelly Hargreaves:

Hi, Harry. This is Kelly Hargreaves. Yes, indeed we do have some concerns about the additional delay. As you know, California state government already has a number of steps that we have to comply with in making purchases over $5,000 and that vending machines fall under one of those routine purchases.

And we are concerned that even the bids that we get might be outdated by the time we get RSA approval. In September of this year, we did submit comments to the US Department of Education. And among those comments was a position that vendors should not be treated, vendor equipment, equipment thatís purchased for the benefit of the vendor, should not fall under this requirement for prior approval.

So weíve gotten no response back from that. And as I mentioned earlier in the call, we may be pursuing along with other states and organizations asking the US Department of Educationís secretary to once again apply the exemption because of the delay. At that time weíll have more information to demonstrate the amount of delay that itís taken. But internally, we know that we need to be more proactive and anticipate purchases much earlier and streamline those processes.

So Elena Gomez, as you know the Deputy Director from Administrative Services Division is working with the BEP management to internally do what we can to reduce the amount of time and that it wonít actually result in longer periods of time.

But we absolutely understand and we do have concerns ourselves and thatís why weíre having this soft call.

Harry Bezine:

Thank you.

Cara:

As a reminder, if you would like to ask a question, please press Star One on your phone.

The next question comes from Lesley Gibbons. Your line is open.

Lesley Gibbons:

Thanks, this is Lesley Gibbons. I just wanted to follow up on a question that Steven Clark asked, and this is with regards to understanding of a per unit.

The example that he gave was of an integrated laptop computer with a braille display. And we all understood that the braille display did require that lap top to be functional. And I think I understood from Simone that the understanding was that if both items are on a single purchase order and the total amount of the purchase did exceed 5,000 then preapproval would be needed.

I wanted to ask, provide a slightly different example and see if they also were the same. There are many, many purchase orders that are issued for two or more items that are not related or connected or reliant on each other. An example would be a lap top computer and then a standalone video magnifier. Typically those purchases, if on a single purchase order, they will exceed $5,000. So is it understood that that kind of purchase would also require preapproval?

Kathi Mowers-Moore:

This is Kathi. And, Lesley, thank you so much for your question and I think it is a very valid distinction of what youíre saying. If they are two distinct items and not one integrated system, it would be similar to the example I used regarding two hearing aids on one purchase order, obviously for the same consumer, but each of the hearing aids is less than $5,000 and thus it would not require preapproval.

In your circumstance that you just provided, two items that are not one integrated setting on one purchase order would be not requiring preapproval and we would never ask to have two different purchase orders being developed for that circumstance. That is not necessary.

(Lesley Gibbons):

Okay, thank you, Kathi. I think thatís going to be a challenge to clarify in both the field and to the other vendors, so yes, thank you for the clarification.

Kathi Mowers-Moore:

Of course. Your clarification for this conversation is very helpful. Thank you.

Cara:

The next question comes from Rochelle Martin. Your line is open.

Rochelle Martin: Hello.

My name is (Rochelle Martin) and my question is will this conversation, will this teleconference be available recorded and available for maybe someone else to listen to that wasnít present today?

Connie Nakano:

Hi, this is Connie. Yes, this conference, this public forum will be, right, so we will have the transcripts available for people that could not participate.

Rochelle Martin:

Okay. And how would I get that?

Connie Nakano:

We will have it posted on our website as soon as we have it available. Typically it takes about a two week time frame for us to get the transcript.

Rochelle Martin:

Okay. Okay, sounds good.

Connie Nakano:

Thank you, Rochelle.

Cara:

The next question or comment comes from Lucy Kong. Your line is open.

Lucy Kong:

Hi. I would like to know for the 5,000 equipment expenditure, do we need three quotes before we get approval?

Kathi Mowers-Moore:

Lucy, this is Kathi. Iím understanding your question, to paraphrase your question as I understand it, normally and customarily the State requires us to obtain multiple bids. And Simone is identifying two bids in addition to the bid or two bids total? Two bids total in order to move forward with our state procurement. That has not changed. We are not changing any of those requirements.

It is simply important for you to know that after all of that information is received by our contracts and procurement section, we will be forwarding those items that require preapproval to RSA to obtain that before those items can be purchased.

Lucy Kong:

Okay, thank you.

Cara:

As a reminder, if you would like to ask a question or make a comment, please press Star One on your phone. One moment.

We show no further questions at this time.

Connie Nakano:

Thank you, Cara. So thank you everybody that participated and had some questions. That concludes our Q&A portion of the forum, but if you have any additional questions later that come up, feel free to direct them to the DOR.

As we conclude the Q&A portion, Iíd like to turn this back over to Kelly Hargreaves for closing.

Kelly Hargreaves:

Thank you all for participating. As we indicated weíre going to create a frequently asked questions or a Q&A to answer questions that weíve received in advance or that we received on this phone call. And thereís an email address to which you can direct your questions. Itís priorapproval@DOR.ca.gov. Thatís P-R-I-O-R-A-P-P-R-O-V-A-L @DOR.ca.gov. Thank you again.

Connie Nakano:

And that concludes our public forum for today. We want to thank you everyone for participating. And once again, if you have any questions please direct it to that email address. And we will have transcripts available for those that could not participate or those that want to review what was said in this forum again. So weíll have that available in a couple of weeks for you and it will be posted on our website. And we want to thank you all for your time today.

Cara:

That does conclude todayís conference. Thank you for participating. You may disconnect at this time.

 

END