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.
Under previous interpretation of 2 CFR 200.325, FNS communicated that “subcontracts exceeding the Simplified Acquisition Threshold” not only applied to subcontracts related to construction or facility improvement contracts, but also applied to food service management companies as the contracts they have with school food authorities were considered to be subcontracts and, therefore, fell under the scope of the bonding requirements in 2 CFR 200.325
The purpose of this memorandum is to emphasize the importance of the state agency and school food authority oversight and monitoring of contracts with food service management companies and to provide guidance for these activities.
The purpose of this memorandum is to call attention to previously published memoranda providing clarification on the requirement to oversee and monitor school food authority contracts with Food Service Management Companies and to ensure ongoing technical assistance and training provided by state agencies includes this information.