DATE: | November 9, 2015 | |
POLICY MEMO: | SP04 CACFP04 SFSP04-2016 | |
SUBJECT: | Local Agency Procurement Reviews: School Year 2015-16 | |
TO: | Regional Directors Special Nutrition Programs All Regions |
State Directors All States |
Program integrity is essential in all aspects of program administration and state agencies contribute to this by overseeing program operations. To this end, this memorandum provides guidance on state agency oversight of program operator procurement procedures while FNS is currently developing a Local Agency Procurement Review Tool to aid state agencies. This tool will be pilot tested to determine effectiveness in SY 2015-16. To assist state agency staff with oversight while the tool is under development, the FNS developed a list of questions that may guide the state’s assessment of program operator procurement activities. (See attached.)
As has always been the case, state agencies must ensure compliance with procurement requirements in program regulations (7 CFR Parts 210.21, 215.14a, 220.16, 225.17, and 226.22, as applicable), and the government-wide regulations in 7 CFR Part 3016 and 3019, as applicable. In SY 2014-15, programs operated using 7 CFR Parts 3016 and 3019 as federal/state agreements were already in place and 2 CFR Part 200 was not finalized. Compliance, therefore, should be assessed by reviewing documentation of the procurement procedures using the regulations in effect at that time. State agencies must distribute this memorandum to program operators. Program operators with questions should contact their state agency. State agencies with questions may contact the appropriate FNS regional office.
Sarah Smith-Holmes
Division Director
Program Monitoring and Operational Support