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).
The Food Plans represent a nutritious diet at four different cost levels. The nutritional bases of the Food Plans are the 1997-2005 Dietary Reference Intakes, 2005 Dietary Guidelines for Americans, and 2005 MyPyramid food intake recommendations. In addition to cost, differences among plans are in specific foods and quantities of foods. Another basis of the Food Plans is that all meals and snacks are prepared at home. For specific foods and quantities of foods in the Food Plans, see Thrifty Food Plan, 2006 (2007) and The Low-Cost, Moderate-Cost, and Liberal Food Plans, 2007 (2007). All four Food Plans are based on 2001-02 data and updated to current dollars by using the Consumer Price Index for specific food items.
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 Food Plans represent a nutritious diet at four different cost levels. The nutritional bases of the Food Plans are the 1997-2005 Dietary Reference Intakes, 2005 Dietary Guidelines for Americans, and 2005 MyPyramid food intake recommendations. In addition to cost, differences among plans are in specific foods and quantities of foods. Another basis of the Food Plans is that all meals and snacks are prepared at home. For specific foods and quantities of foods in the Food Plans, see Thrifty Food Plan, 2006 (2007) and The Low-Cost, Moderate-Cost, and Liberal Food Plans, 2007 (2007). All four Food Plans are based on 2001-02 data and updated to current dollars by using the Consumer Price Index for specific food items.
This memo clarifies the small purchase threshold applicable to procurements under FNS programs.