FNS Documents & Resources

This memorandum provides general guidance on the various procurement groups FNS has identified, how to use each group in a way that complies with federal procurement standards, and supersedes SP 35-2012, Procuring Services of Purchasing Cooperatives, Group Purchasing Organizations, Group Buying Organizations, etc., dated June 12, 2012.

The purpose of this memorandum is to strongly encourage local educational agencies to accept eligibility determinations from a transferring student’s former LEA to minimize disruptions in meal benefits for low-income students and avoid student debt resulting from unpaid meal charges.

There has been confusion about how unpaid meal charges must be handled when all collection efforts have been exhausted. To help address these situations, this memorandum clarifies the processes of designating delinquent debt that has been determined to be uncollectable as bad debt and obtaining assistance to offset bad debt losses.

The purpose of this memorandum is to address the need for school food authorities participating in the National School Lunch Program and School Breakfast Program to institute and clearly communicate a meal charge policy, which would include, if applicable, the availability of alternate meals.

Under previous interpretation of 2 CFR 200.325, FNS communicated that “subcontracts exceeding the Simplified Acquisition Threshold” not only applied to subcontracts related to construction or facility improvement contracts, but also applied to food service management companies as the contracts they have with school food authorities were considered to be subcontracts and, therefore, fell under the scope of the bonding requirements in 2 CFR 200.325