Sneak Preview: FNS Clarifies Procurement Review Requirements

August 3, 2017 | By Jerry Ashworth | Post a Comment

xgran_bookshotThe following was excerpted from a recent article in the Federal Grants Management Handbook.) The U.S. Department of Agriculture’s Food and Nutrition Service (FNS) recently issued guidance, in the form of a memo — SP-39-2017, to states clarifying that they may either conduct procurement reviews of local school nutrition programs during the same three-year cycle as their administrative reviews, or they may opt for an alternate cycle, if necessary, to conduct the procurement reviews.

State nutrition programs typically receive federal School Lunch and School Breakfast program funding, then pass funds through to local nutrition authorities for their programs. In a recent memo to state directors of child nutrition programs and to regional directors of special nutrition programs, FNS clarified previous guidance issued in June 2016 pertaining to procurement reviews of local school food authorities (SFAs). Statutory requirements related to procurement for FNS award recipients are located at 7 C.F.R. Parts 210.21, 215.14a and 220.16, as applicable, and in the Office of Management and Budget’s uniform guidance at §200.318-.326.

To meet these requirements, FNS established a three-year cycle for states to conduct local school food authority procurement reviews. In June 2016, FNS released guidance entitled “Draft Tool for Local Agency Procurement Reviews for School Food Authorities in School Year 2016-2017.” This guidance included a tool to assist state agencies in conducting reviews of local procurement oversight procedures. State agencies had the option to use the tools, develop an alternative approach to a procurement review or modify an existing review process that meets federal, state and local procurement requirements. FNS planned to gather feedback on the draft version to develop a final tool for school year 2017-2018.

The 2016 guidance encouraged, but did not require, state agencies to conduct procurement reviews during the same three-year review cycle as their administrative reviews, which ensure that SFAs are complying with general program requirements. FNS anticipated that the procurement review cycle would correspond with the existing requirement for state authorities to review SFA contracts with food service management companies every three years, as required by 7 C.F.R. 210.19(a)(5). However, based on feedback received from numerous state agencies, FNS concluded that the lack of resources, reviewer expertise and budget constraints were causing challenges for states attempting to conduct the procurement reviews.

Therefore, in its new guidance, FNS explained that it will grant states discretion to continue completing procurement reviews on the same three-year cycle as the administrative reviews, or as another option, conduct these reviews on an alternate cycle. The alternate cycle may be longer than the current three-year cycle requirement. State agencies that received an FNS waiver from the three-year administrative review cycle to an alternative four-year or five-year review cycle also may, but are not required to, conduct the procurement review during the same year as the administrative reviews.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)

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