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).
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.
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.
This memo clarifies the small purchase threshold applicable to procurements under FNS programs.
The purpose of this memorandum is to address recent inquiries on the application of the geographic preference option in the procurement of unprocessed locally grown or raised agricultural products.
Following the Jan. 26, 2012, issuance of the final rule titled Nutrition Standards in the National School Lunch and School Breakfast Programs, several questions have been raised regarding its effect on current contracts between school food authorities and food service management companies.
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.