3. May FNS require more documentation than defined in FNS Handbook 901, such as quarterly or monthly status reports?
4. May a State agency submit more than one document for FNS approval at the same time, such as the IAPD and RFP?
5. May a State submit APDs and related documents electronically or do they have to send hard copies?
8. If FNS takes longer to review a document than the 60 days allotted, does this mean the project is automatically approved?
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.
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 > $6M.
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.
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.
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.
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: http://file-compression-software-review.toptenreviews.com/how-to-use-the-winzip-basics.html.
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 errors.
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.
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.
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).
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.