City of San Pablo, California
Analysis of Procurement-Related Monetary Thresholds
Prepared by Eide Bailly LLP
June 28, 2026
City of San Pablo, California
BACKGROUND
As a component of Eide Bailly’s advisory engagement with the City of San Pablo, the City requested our assistance with assessing the City’s current monetary thresholds associate d with 1) the delegated authority to the City Manager to enter into contracts and make other purchases and 2) the requirement to utilize formal and informal procurement methods for construction, services, materials, and equipment. Based upon our assessment of the City’s current procurement policies, our assessment of the procurement policies of similar agencies in the region as further de scribed below, and our knowledge of best practices, this report provides information to assist the City’s Management and the City Council with evaluating proposed changes to the current monetary thresholds to account for 1) inflation since the y were last updated, 2) the thresholds employed by peer agencies, and 3) industry best practices that facilitate efficient procurement.
Our services consisted of consulting services and do not constitute an audit, examination, review, or compilation of historical financial information conducted in accordance with generally accepted auditing standards or with other standards established by the American Institute of Certified Public Accountants (AICPA). Accordingly, we are unable to express an opinion or any other form of assurance with respect to any historical financial information. Our engagement was not designed and cannot be relied upon to disclose errors, fraud, or illegal acts that may exist. Other matters of possible interest to the City might not be specifically addressed in this report.
EXECUTIVE SUMMARY
In summary, t he analysis detailed in the remainder of this report supports a recommendation to increase the City’s current procurement-related monetary thresholds. Since the City’s procurement-related monetary thresholds were last updated in 20 09 (formal and informal bidding) and 2017 (budget authority), the impact of inflation has resulted in:
• The City Manager’s budget authority threshold amount of $50,000 increasing to approximately $67,000 when adjusted for the increase in the CPI and approximately $80,000 when adjusted for the increase in the CCCI.
• The formal bidding threshold amount of $25,000 increasing to approxim ately $41,000 when adjusted for the increase in the Consumer Price Index (CPI) for the San Francisco-Oakland- Hayward MSA and $48,000 when adjusted for the increase in the California Construction Cost Index (CCCI).
The average delegated approval authority reflected in our survey of peer agencies is:
• $182,000 for construction procurements.
• $92,500 for services procurements.
• $97,500 for materials and equipment procurements.
City of San Pablo, California
The majority of the cities included in our survey of peer agencies:
• Adhere to the formal and informal procurement thresholds outlined in the California Uniform Construction Cost Accounting Act (CUPCCAA), as does the City. • Have a formal procurement threshold for non -construction procurements of $100,000 or more and an informal procurement threshold for non-construction procurements of $10,000 or more.
City of San Pablo, California
ANALYSIS OF INFLATION
Per the City’s request, we analyzed the impact of inflation on the City’s monetary thresholds between the time the City last amended the procurement-related sections of its municipal code in November 2009 (formal and informal bidding) and January 2017 (budget authority) versus today. There are two industry standards for assessing inflation related to procurement in California local governments:
• The change in the Consumer Price Index (CPI) for the City’s metropolitan statistical area • The change in the California Construction Cost Index (CCCI) Our analysis of the impact of inflation on the City’s historical monetary thresholds is summarized in the table below.
Value 2009 2017 2026 Change
CPI 222.166 271.626 363.211
CPI-Adjusted Budget
Authority Threshold $50,000 $66,859 33.72%
CPI-Adjusted Formal
Procurement Threshold $25,000 $40,872 63.49%
CCCI 5,309 6,373 10,159
CCCI-Adjusted Budget
Authority Threshold $50,000 $79,703 59.41%
CCCI-Adjusted Formal
Procurement Threshold $25,000 $47,839 91.35%
This data supports the assertion that there has been a significant reduction in the purchasing power of the current $25,000 and $50,000 monetary threshold since 2009 and 2017, respectively.
City of San Pablo, California
SELECTION OF PEER CITIES FOR SURVEY
Eide Bailly developed an appropriate selection of peer cities for purposes of surveying current monetary thresholds related to procurement using the following methodology. We started with the cities located in Alameda and Contra Costa County within proximity to the City of San Pablo and then filtered this list to eliminate cities with a total population and/or a total expenditure budget that was in our judgment significantly different that San Pablo’s population and total budget. The resulting sample of 2 0 regional cities was utilized to gather survey data regarding procurement -related monetary thresholds. The table below lists the key data points for these 20 cities.
Following completion of the survey, Eide Bailly analyzed the data to narrow the list of survey cities , as appropriate, to eliminate cities that for various reasons were not suitable in our judgment to include in the survey data. Cities were eliminated for one of the following reasons:
• The City’s procurement policies are informal and not documented, or only partially documented, via their municipal code (four cities).
• The City has not updated its monetary thresholds for 25 years or more (three cities). • The City allows for non-construction procurements of any amount to be administratively approved if included in the adopted budget (two cities). • The City’s procurement policies are unusually conservative and inconsistent with best practices (one city).
Agency Name County Population City Type 2025/26 Total Expenditure Budget
City of San Pablo Contra Costa County 31,468 General Law $68 Million City of Alameda Alameda County 80,023 Charter City $152 Million City of Berkeley Alameda County 127,654 Charter City $783 Million City of Clayton Contra Costa County 10,759 General Law City $6 Million City of Concord Contra Costa County 122,494 General Law City $285 Million Town of Danville Contra Costa County 43,190 General Law City $43 Million City of Dublin Alameda County 74,769 General Law City $140 Million City of El Cerrito Contra Costa County 26,166 Charter City $75 Million City of Hercules Contra Costa County 26,323 General Law City $47 Million City of Lafayette Contra Costa County 25,321 General Law City $43 Million City of Livermore Alameda County 86,118 General Law City $254 Million City of Martinez Contra Costa County 36,521 General Law City $97 Million City of Orinda Contra Costa County 19,412 General Law City $29 Million City of Pinole Contra Costa County 18,891 General Law City $95 Million City of Pleasant Hill Contra Costa County 33,853 General Law City $49 million City of Pleasanton Alameda County 76,149 General Law City $248 Million City of Richmond Contra Costa County 113,695 Charter City $594 Million City of San Leandro Alameda County 87,431 Charter City $273 Million City of San Ramon Contra Costa County 84,220 General Law City $149 Million City of Union City Alameda County 66,665 General Law City $184 Million City of Walnut Creek Contra Costa County 70,288 General Law City $184 Million City of San Pablo, California
BUDGET AUTHORITY SURVEY
The table below summarizes the results of Eide Bailly’s survey of the authority delegated to the City Manager to enter into contracts and make other purchases in the 10 cities remaining from the original 20 cities surveyed.
As illustrated in the table, the majority of the surveyed cities have delegated monetary thresholds exceeding the City’s current threshold of $50,000. Specifically, for construction projects, the average amount is $182,000, with most cities aligning their thresholds with the current formal bid threshold under CUPCCAA of $220,000. For services and materials and supplies procurements, the average amounts are $92,500 and $97,500, respectively. This data supports a recommendation to increase the City Manager’s delegated authority from $50,000 to $100,000.
From a best practices perspective, delegated monetary authority for approving procurements should be set at a level that balances administrative efficiency with oversight by elected officials. In modern procurement departments operating in alignment with best practices and with comprehensive policies and procedures , higher monetary thresholds provide for more efficient and timely procurement processes and service delivery to constituents . To ensure appropriate oversight, expenditures are approved via the budget process and reported through the check register or other reporting mechanisms to elected officials and the public. In our experience, the higher thresholds reflected in the table above are consistent with similar cities throughout California.
Agency Name Materials and
Equipment
City of San Pablo $50,000 $50,000 $50,000
City of Berkeley $200,000 $50,000 $100,000
City of Concord $220,000 $95,000 $95,000
City of Dublin $220,000 $100,000 $100,000
City of Hercules $100,000 $50,000 $50,000
City of Livermore $220,000 $200,000 $200,000
City of Orinda $220,000 $60,000 $60,000
City of Pinole $220,000 $45,000 $45,000
City of San Leandro $100,000 $100,000 $100,000
City of San Ramon $100,000 $100,000 $100,000
City of Walnut Creek $220,000 $125,000 $125,000
Peer City Average $182,000 $92,500 $97,500
Construction Services
City of San Pablo, California
FORMAL AND INFORMAL PROCUREMENT SURVEY
At a high level, formal procurement processes require detailed specifications, formal advertisement, and a bid or proposal opening process, while informal procurement processes allow for the solicitation of multiple quotes (typically three or more) and an accelerated procurement process. It is common in public agencies and consistent with best practices to utilize informal procurement for most procurements, recognizing that formal procurement can be utilized on a discretionary basis, as needed and appropriate, even if not required. It should be noted that the City’s thresholds for formal and informal procurement applicable to non-construction procurements were not updated in 2017 and have been in place since November of 2009.
The table below summarizes the results of Eide Bailly’s survey of the thresholds at which formal and informal procurement are required in the 10 cities remaining from the original 20 cities surveyed.
Several of the cities included in the survey have not opted into the provisions of CUPCCAA, which accounts for their $5,000 formal construction procurement threshold as required by the California Public Contract Code in the absence of opting into CUPCCAA p articipation. Several cities also did not have informa tion readily available detailing their monetary thresholds for non -construction procurements.
As illustrated in the table, the majority of the surveyed cities have construction procurement thresholds in alignment with the City’s thresholds. For non -construction procurements, all of the surveyed cities have delegated monetary thresholds for formal and informal procurements exceeding the City’s current threshold s of $25,000 and $5,000, respectively. This data supports a recommendation to increase these thresholds to $100,000 and $10,000, respectively. Aligning the threshold for formal non-construction procurement with the threshold for City Council approval of procurements also provides for a single monetary threshold that can be consistently applied.
From a best practices perspective and similar to the thresholds for City Council approval of procurements, these thresholds should be set at a level that balances administrative efficiency with oversight by elected officials. In modern procurement departments operating in alignment with best practices and with comprehensive policies and procedures, higher monetary thresholds for formal and informal procurement also provide for more efficient and timely proc urement processes and service delivery to constituents. In our experience, the higher thresholds reflected in the table above are consistent with similar cities throughout California.
Formal Informal Formal Informal Formal Informal
City of San Pablo $220,000 $75,000 $25,000 $5,000 $25,000 $5,000 City of Berkeley N/A N/A N/A N/A N/A N/A
City of Concord $220,000 $75,000 $85,000 $10,000 $85,000 $10,000 City of Dublin $220,000 $75,000 $100,000 $50,000 $100,000 $50,000 City of Hercules $220,000 $75,000 N/A N/A N/A N/A
City of Livermore $220,000 $75,000 $100,000 $10,000 $100,000 $10,000 City of Orinda $220,000 $75,000 $60,000 $10,000 $60,000 $10,000 City of Pinole $220,000 $75,000 N/A N/A N/A N/A
City of San Leandro $5,000 N/A $200,000 $60,000 $200,000 $60,000 City of San Ramon $5,000 N/A N/A $15,000 N/A $15,000
City of Walnut Creek $220,000 $75,000 $100,000 $50,000 $50,000 $10,000 Agency Name Materials and Equipment Construction Services