The previous version of this memorandum contained incorrect references to state agencies throughout. FNS is correcting this memorandum to remove the incorrect references and so that it more clearly and accurately reflects the federal regulations. This memorandum notifies state agencies and child nutrition program operators of the changes made by OMB to the federal informal procurement method, micro-purchases and the micro-purchase threshold.
The Study of School Food Authority (SFA) Procurement Practices is the first study from the U.S. Department of Agriculture (USDA), Food and Nutrition Service to comprehensively describe and assess the decision-making process regarding school food procurement practices at the SFA level. The sample for this study was a subset of the 1,679 SFAs that participated in the Child Nutrition Operations Study II (CN-OPS-II), which included a module on SFA procurement practices in school year (SY) 2016–17. Findings are based on the perceptions and experiences of the SFA and they may not reflect actual regulations and policies; this study was not an audit.
The purpose of this audit guidance policy memorandum is to clarify the options available to state distributing agencies or recipient agencies in assigning value to USDA donated foods for audit purposes.
This memorandum provides general guidance on the various procurement groups FNS has identified, how to use each group in a way that complies with federal procurement standards, and supersedes SP 35-2012, Procuring Services of Purchasing Cooperatives, Group Purchasing Organizations, Group Buying Organizations, etc., dated June 12, 2012.
Recent communications between FNS and state agency program staff during procurement trainings and management evaluations conducted in fiscal year 2014-2015 indicated a need for guidance on competitive procurement standards. This page lists where to find the standards.
FNS is aware that school food authorities and program operators may be operating NSLP, SBP, and other child nutrition programs, in a way that includes offering reimbursable meals and non-program foods (a la carte sales, catering, adult meals, etc.) using foods from popular franchise restaurants through a franchise agreement.
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.
FNS has received many questions related to implementation of 2 CFR Part 200 and understands that changes to financial and procurement systems are costly and require time to develop and implement. Therefore, FNS will work with state agencies during this transition period and will seek to answer questions and provide guidance as needed.
OMB published the Super-Circular at 78 FR 78590 on Dec. 26, 2013, for USDA and other federal grant-making agencies. Section 200.10(a) requires federal agencies to implement the policies and procedures set out in the Super-Circular by promulgating regulations effective Dec. 26, 2014. USDA published such regulations at 2 CFR Parts 400, 415, 416, et al. (79 FR 75981, Dec. 19, 2014).