Nutrition Services Division Management Bulletin |
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Action Required |
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| To: Child and Adult Care Food Program Independent Centers and Center Sponsors |
Number: USDA-CACFP-04-2008 |
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| Attention: Food Program Director |
Date: October 2008 |
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| Subject: Small Purchase Threshold |
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| Reference: United States Department of Agriculture, Food and Nutrition Service, Policy Memo CACFP-09-2008 and SFSP-08-2008 and Title 7, Code of Federal Regulations, Part 3016.36 | |||
This Management Bulletin reiterates long-standing guidance regarding the small purchase threshold for public and private nonprofit day care centers. It also implements the federal policy that extends the same threshold to private, for-profit day care centers for the first time.
Consequently, all day care centers now have a small purchase threshold of $100,000 for the purchase of meals, food, supplies, equipment, and goods and services. Practically, this threshold means that a center may use the small purchase method to buy any number of items for its food service operation, as long as any single purchase does not exceed $100,000. The small purchase method is an informal but competitive process to purchase goods and services that are reasonable, necessary, and allowable.
If a single purchase exceeds $100,000, a center must initiate a formal bid process that will result in a fixed-price contract. Most likely, a center will employ the formal bid process if it seeks to purchase all of its meals from a food service vendor. Typically, the total amount for the meal preparation and delivery will exceed $100,000.
In time, the United States Department of Agriculture (USDA) will revise the program regulations to incorporate the appropriate references to the small purchase threshold contained in Title 7, Code of Federal Regulations, Part 3016, and the United States Code. For now, the USDA Memo CACFP-09-2008 provides the necessary authority and is available as the following Web document:
http://www.fns.usda.gov/cnd/Care/Regs-Policy/policymemo/2007-2009/CACFP-09-2008-OS.pdf (PDF; Outside Source).
If you have any questions regarding this issue, please contact the CACFP specialist assigned to your agency in the Child Nutrition Information Payment System (CNIPS). You will find a list of contact information for specialists in the Download Forms section of the CNIPS. You may also contact the Help Desk by phone at 800-952-5609, option 6.