Are all components of an APD indicated in FNS
Handbook 901, required?
The list of components of an APD as listed in Handbook 901 is all
encompassing - a list of all possible information that may be included. The FNS
State Systems Office encourages State agencies to collaborate with them to
customize the list when appropriate. For example, requests for hardware
replacement may not require a significant functional requirements discussion but
may require a capacity study.
Are Planning APDs (PAPDs) optional?
No. If a State agency wishes to use Federal funding for WIC or Federal
financial participation (FFP) for SNAP for their planning activities, a PAPD has
to be submitted and approved by FNS. WIC requires a PAPD be submitted for each
project. SNAP requires a PAPD be submitted when the total project cost is >
May FNS require more documentation than defined in
FNS Handbook 901, such as quarterly or monthly status reports?
Yes. FNS Handbook 901 states that FNS has the discretion to request more or
less documentation on a case-by-case basis. Depending upon the risks associated
with a project, FNS may request additional reporting beyond the required APDU
Annual and As Needed.
May a State agency submit more than one document for FNS approval at the same
time, such as the IAPD and RFP?
Yes. A State agency may submit more than one document concurrently, but
each document will have its own 60 day review period. However, FNS will
probably review the planning document (a PAPD or IAPD) before the procurement
document (an RFP) to ensure the project itself is sound and allowable before
permitting the procurement to proceed. If significant problems are found
in the project plan which may also affect the procurement, an RFP may be
returned for related corrections or changes without further review. We
typically advise a State agency to submit an APD first, to assure approval of
the project, before submitting an RFP or other procurement documents.
May a State
submit APDs and related documents electronically or do they have to send hard
FNS encourages State agencies to submit all APDs and related documents
electronically. A scanned copy of the transmittal letter, signed by a
State official authorized to commit State resources, should accompany all
documents. Also States should remember to submit the electronic copy to the
Director of the FNS State Systems Office as well as the cognizant FNS Regional
Administrator or his/her designee.
Some APD-related submissions are quite large; can
they be sent electronically?
FNS’ system can accommodate attachments to emails up to 5MG in size. If any
one document or combination of documents is larger than this limit, they should
either be split up into multiple email attachments, compressed using WinZip
software, or sent to FNS on a CD. Following is a link on how to use WinZip:
What can a State agency do to get a document approved faster than 60 days?
A State agency should always build at least 60 days into its project
timeline for Federal review of documents. The most frequent reason for
delays based on document reviews is not the number of days it takes FNS to
review a document, but the number of changes and corrections that must be made
by the State after initial submission. Things a State agency can do to
ensure a timely approval:
- Make sure all documents are written carefully, with
all required sections of Federal provisions included, cross-references between
sections and formulas checked for accuracy, and all documents proof-read for
- When submitting revisions or APDUs, clearly identify
all changes to the previous document, so that reviewers can go straight to those
changes, without having to re-read the whole document to find out what changed.
- Use the checklists provided on this APD website, to
make sure that all required content is included, and may even complete the
checklist and submit it along with the document, to help FNS identify where all
required materials or provisions are in the document.
Finally, although State agencies want a rush review on
every document, communicating with FNS as you prepare the document will help us
identify when a true emergency exists.
If FNS takes longer to review a document than the 60
days allotted, does this mean the project is automatically approved?
FNS regulations at 7 CFR 277.18 allow for provisional approval of
Supplemental Nutrition Assistance Program (SNAP) projects after 60 days only if
the State agency has received no communications from FNS during the 60 days
regarding the projects. WIC does not allow for provisional approval at any
time. If a State agency is nearing end of the 60 days timeframe, which begins
when FNS receives the APD or related documents, and has not heard from FNS, the
State agency should contact the State Systems Office immediately.
What is a "waiver of depreciation"? When is this
A waiver of depreciation is a written request to change the
method of accounting and claiming for the cost of equipment. The Federal cost
circulars require that individual items of equipment which cost more than
$25,000 per item, must be charged over the useful life of the equipment.
(Useful life is as proscribed by the Internal Revenue Service. Workstations
have a useful life of three years, while mainframes are normally charged over a
period of 7 years) The written request would ask for FNS permission to charge
the entire cost of the equipment acquisition at the time of acquisition (more
commonly known as “expensing”). Unless FNS approval is received, the equipment
cost must be based on depreciation over the life of the equipment. This may be
advantageous to the State agency due to limited funding or a limited life of the
funds available for the acquisition. FNS evaluates a request for waiver of
depreciation based upon the following criteria:
- Documentation from the State agency justifies that expensing costs in the
period acquired will be more cost beneficial to the Federal government than
depreciating the costs;
- Sufficient funds exist within the current year Federal appropriation to allow
expensing of costs within the period of acquisition;
- Approval of the waiver of depreciation will be consistent among the Federal
funding agencies (although different funding constraints may apply).
What is required for FNS to approve sole source
FNS mandates the use of competitive, full and open procurements. FNS also
recognizes that instances may occur where a noncompetitive procurement
(solicitation of a proposal from only one source) is unavoidable. In these rare
cases, the State agency has to submit justification for at least one of the
following four criteria as set forth in
7 CFR 3016.36:
- The item is available only from a single source.
- Public emergency when the urgency for the requirement will not permit a delay
incident to competitive procurement.
- After soliciting several sources, competition is determined inadequate.
- FNS authorizes noncompetitive procurement.
May State agencies give preference to contractors
that are based in their State?
No. Geographic preference is disallowed in accordance with regulations
7 CFR 3016.36(c)(2) and
7 CFR 3016.60(c).