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May a State
submit APDs and related documents electronically or do they have to send hard
copies?
FNS encourages states to submit all APDs and related documents
electronically. A scanned copy of the signed 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 State Systems Branch Chief as well as the cognizant Regional
Administrator.
Are Planning APDs
optional?
No. If a State agency wishes to use Federal funding for WIC or Federal
financial participation (FFP) for FSP for their planning activities, a Planning
APD has to be submitted and approved by FNS. WIC requires a Planning APD be
submitted for each project. FSP requires a Planning APD be submitted when
the total project cost is > $5M.
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 SFR 277.18 allow for provisional approval of Food Stamp
Program 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 Branch immediately.
What is a "waiver
of depreciation"? When is this applicable?
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
$100,000 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 asks for agency permission to charge the
entire cost of the equipment acquisition at the time of acquisition (more
commonly known as “expensing”). Unless agency permission 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).
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 State Systems Branch encourages the State agencies to work with them to
customize the list as much as possible. For example, requests for hardware
replacement may not require a significant functional requirements discussion but
may require a capacity study.
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.
What is required to approve sole source
procurements?
FNS mandates the use of competitive, free 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 meet 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 3016.60(c).
Last modified:
08/28/2007
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