FNS Documents & Resources

The previous version of this memorandum contained incorrect references to state agencies throughout. FNS is correcting this memorandum to remove the incorrect references and so that it more clearly and accurately reflects the federal regulations. This memorandum notifies state agencies and child nutrition program operators of the changes made by OMB to the federal informal procurement method, micro-purchases and the micro-purchase threshold.

Recent communications between FNS and state agency program staff during procurement trainings and management evaluations conducted in fiscal year 2014-2015 indicated a need for guidance on competitive procurement standards. This page lists where to find the standards.

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.

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 purpose of this memorandum is to update the definition of what is considered “unprocessed” for the purposes of applying the optional geographic preference for procurement in the child nutrition programs.

Please be aware that the procurement questions from July 22, 2009 have been revised. This new set of procurement questions supersedes the previous set, as a change has been made to the second Q&A under “Local Purchasing."

This memorandum updates and revises memoranda SP30-2008: Applying Geographic Preferences in Procurements for the Child Nutrition Programs, SP08-2009: Procurement Questions, and SP28-2009: Procurement Questions, regarding school food authorities’ and other institutions’ application of a geographic preference in procurements for the child nutrition programs.

Today’s unpredictable economy has made it important to consider accounting for the fluctuating costs of goods and services that are beyond the control of either the school food authority or the vendor.

Recently, we have received numerous concerns regarding the improper application of the new procurement rule, Procurement Requirements for the National School Lunch, School Breakfast and Special Milk Program, which was published in the Federal Register on Oct. 31, 2007 and became effective on Nov. 30, 2007.