The purpose of this memorandum is to amend guidance provided in SP 45-2016 Draft Tool for Local Agency Procurement Reviews for School Food Authorities in SY 2016-17 and to clarify FNS expectations for state agency oversight of school food authority procurement procedures.
This memorandum replaces SP 24-2016, Compliance with and Enforcement of the Buy American Provision in the National School Lunch Program. It provides several updates, including suggested contract language to be utilized in solicitations, and serves to reinforce the importance of the Buy American provision to our economy and its positive effects on small and local businesses.
The purpose of this memo is to inform you that USDA will not release a SNAP national payment error rate for FY 2016.
The memorandum that follows is intended to clarify the three ways in which FNS measures timeliness of initial SNAP application processing. This memorandum does not represent new policy, but seeks to clarify the three existing data collection and monitoring procedures.
In order to ensure efficient and effective program delivery, this memorandum clarifies existing statutory, regulatory and policy guidance regarding the documentation required for a QC case file, second party reviews, state quality control requests for policy interpretations, and requirements for federal access to state systems.
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.
SNAP’s QC system uses a tolerance level to set the threshold for determining which errors are included in the national payment error rate calculation. For FY 2017, the tolerance threshold will remain at $38.
The SNAP quality control system measures the accuracy of State eligibility and benefit determinations. In fiscal year (FY) 2012, QC's measurement of errors in cases that were denied, terminated and suspended was renamed from the negative error rate to the case and procedural error rate. The name change was accompanied by a new review process that takes into account customer service aspects of negative actions, such as timeliness and correctness of the notice, in addition to the accuracy of the determination.
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
This memorandum is intended to clarify existing regulatory and policy guidance to ensure awareness of our shared responsibility to preserve the integrity of SNAP's quality control system, based on findings from recent FNS reviews of state quality control operations.