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Analysis for the people who run public procurement

Notes on New York procurement law and practice — what changed, what it means, and what to do about it.

Piggybacking Under GML §103(16): The Conditions That Must All Be Met
02 Sep 2026

The piggybacking exception has three prerequisites, a four-element consistency test, an authorization trap for best value contracts, and a sunset date of June 30, 2027. Every one of them has caught a district. Here is the whole framework in one place.

John Brucato
When Federal Money Is in the Purchase: The Rules That Stack on Top of GML §103
25 Aug 2026

Title I, IDEA, and Child Nutrition purchases carry a second rulebook most districts have never read. What the Uniform Guidance is, how it stacks on GML 103, the requirements with no state analogue, and the two federal rulemakings moving this fall.

John Brucato
Your §104-b Procurement Policy: What Belongs in It, and the Annual Review Almost Nobody Does
11 Aug 2026

The statute tells you exactly what your procurement policy must contain, including a purchaser roster with a biennial update clock that quietly expires. And the annual board review required by subdivision 4 is the item most districts cannot find in their minutes.

John Brucato
When Competitive Bidding Is Actually Required — and the Aggregation Rule That Catches Districts Out
29 Jul 2026

The thresholds are the easy part. The twelve-month aggregation rule — measured across all vendors, forward from the date of purchase — is where districts actually get caught, and it has a renewal trap almost nobody reads.

John Brucato
NYSED Just Tied Building Aid to the Piggybacking Ruling. Here's What Changed.
23 Jul 2026

NYSED has attached a Building Aid consequence to the Maine-Endwell piggybacking decision — and it reaches districts outside the Third Department.

John Brucato