PPP Authority requesting public commentary on regulations of procurement activity

You know the ELA is in trouble when they are soliciting public commentary on the procurement process. http://p3.gov.pr/Eng/News.html

The following is a my public commentary on regulations governing procurement for Puerto Rico:



PPP should set up a procurement policy board to oversee the procurement policy board rules that govern procurement of public sector resources for various contract purposes. The procurement policy board would clarify procurement rules and policies that pertain to soliciting funds for the purpose of doing business with all public sector agencies and missions (as long as all public sector agencies fall under one public sector jurisdiction).

NYC is an example of a procurement policy board that governs the clarification of procurement policies and rules that determine how contracts are administered.
http://www.nyc.gov/html/mocs/ppb/html/rules/rules.shtml

Although it is important for the government to work effectively and in a timely manner, it should not sacrifice speed with transparency and oversight. Very important.

Also, any office that is responsible for procurement of services cannot simultaneously be in charge of any budget. Budgeting and procurement should be separate, so as to avoid corruption and lack of oversight. Procurement should never be confused with the budgeting process and ensuring that resources are available for the said project.

A procurement policy board should clarify whether existing contracts will fall under a general body of procurement policy that is written under an independent procurement board, and it should determine which contracts fall under this general body of procurement. Ideally, all procurement should fall under a body of procurement rules that are created by an Independent policy procurement board.

The rules on procurement should avoid any language that ties procurement methods to ideology, particularly the preference for "privatization" or "nationalization" but on the the most efficient manner of procuring goods and services for the people of Puerto Rico.
it should be assumed that every manner of procurement may not be the best solution to solving a particular issue for the government and people of Puerto Rico.

Procurement contracts should demonstrate measurable outputs and the contracts should report to an independent committee to determine contract measurables, efficiency requirements, and intended outcomes for the government and the people of Puerto Rico.

Procurement Offices should ensure that funds are available (from an independent functioning budget office), but should ensure that contracts are administered in a fair and judicious manner. Procuring private services should not replace public sector functions, when the costs exceed public sector functions, unless it is deemed that contracted services serve as a low risk investment and does not take away from the basic services and needs that are provided by the government for the people of Puerto Rico.

A procurement oversight committee should review the daily functioning of a procurement office that is implemented with the PPP. This procurement oversight committee can consiste of a public advocate, ombudsman, Independent Budget Examiner, and Comptroller personnel to oversee and audit any procurement practices that are occurring throughout this system.

The stated efficiency goals shoudl exceed the net total increase in resources that were committed to creating the PPP process inthe first place. So if an additional net $1million are added (after some existing resources have been allocated for this purpose) to implement this system, then the PPP stated goal is to exeed $1million in savings throughout the system, whether by contracting out existing services, re-allocating existing contracts to more efficient vendors or re-examining other contracts to extract savings.