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).
This memorandum responds to a number of recent questions and requests to provide clarifying guidance to state agencies and child nutrition program operators, including the National School Lunch Program, School Breakfast Program, Child and Adult Care Food Program, and Summer Food Service Program, regarding the expectation and enforcement of ethical conduct by their employees engaged in procurement of program goods and service.
This memorandum clarifies how school food authorities may use funds provided under Sections 4 and 11 or 19 of the National School Lunch Act to purchase fresh fruits and vegetables from DoD Fresh Fruit and Vegetable Program vendors.
In an effort to simplify procurement requirements for SFSP sponsors, this memorandum links existing procurement and contract thresholds referenced in the program regulations to the federal small purchase threshold currently set at $150,000.
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.
The purpose of this memorandum is to address recent inquiries on the application of the geographic preference option in the procurement of unprocessed locally grown or raised agricultural products.
Following the Jan. 26, 2012, issuance of the final rule titled Nutrition Standards in the National School Lunch and School Breakfast Programs, several questions have been raised regarding its effect on current contracts between school food authorities and food service management companies.
In this policy memorandum, we clarify that the SFA may, in some cases, include bids for procurement of end products in its solicitation for procurement of commercial food products from commercial distributors, rather than conduct two separate solicitations.