Federal Micropurchase and Small Purchase Threshold

This management bulletin (MB) supersedes MB CNP-01-2018 and informs all Child Nutrition Program (CNP) Operators that the Office of Management and Budget (OMB) issued Policy Memorandum M-18-18 on June 20, 2018, implementing new thresholds for micropurchase and small purchases under the Uniform Grant Guidance. You can view this Policy Memo on the White House website at https://www.whitehouse.gov/wp-content/uploads/2018/06/M-18-18.pdf.

Effective August 1, 2018, all CNP Operators may use the micropurchase method to procure goods and services equal to or less than the new federal micropurchase threshold of $10,000 (increased from $3,500), and the small purchase method to procure goods or services equal to or less than the new federal small purchase threshold of $250,000 (increased from $150,000). For the procurement of goods and services exceeding $250,000, CNP Operators must use the formal procurement method. As a reminder, on January 1, 2018, amendments to the Public Contract Code (PCC) Section 20111, occurring in the 2017–18 legislative session permitting public school districts (PSD) and County Offices of Education (COE) to follow the federal small purchase threshold, unless their local small purchase threshold is more restrictive. Please note that this amendment only affects purchases made by CNP Operators using federal CNP funds. Local agencies may set a lower threshold than the federal small purchase threshold mandated in Title 2, Code of Federal Regulations (2 CFR), Section 200.320; therefore, CNP Operators should check with their legal counsel to ensure they are following the correct threshold amount and amend their procurement procedures accordingly.

Awarding a Request for Proposal (Effective January 1, 2018)

Prior to Senate Bill 544, PSDs and COE were required to award the contract to the lowest bidder. As of January 1, 2018, all CNP operators using the Request for Proposal (RFP) procurement method for federal CNP purchases, can award contracts to the most responsible and responsive vendor whose proposal is most advantageous to the program with price being the primary factor and other evaluation criteria considered.

Below is an example of an evaluation method for awarding an RFP where price is the primary factor prior to SB 544 becoming effective.

In the example shown above, the CNP Operator stated in the RFP that only vendors who scored ten points or more would be considered for the award. Both Vendors 2 and 3 scored high enough to be considered for the award. Prior to SB 544, the CNP Operator in this example must award the contract to the lowest bidder, which is Vendor 2, even though Vendor 3 scored higher in the evaluation criteria.

Effective January 1, 2018, the CNP Operator can award the contract to the most responsible and responsive bidder where price is the primary consideration, but not the only consideration.

Below is the same example, but price is now one of the scored evaluation criteria.

As a result of the passage of SB 544, Vendor 3 would be awarded the contract because they are the most responsible and responsive bidder whose proposal is most advantageous to the program with price and other factors considered.

Contact Information

If you have any questions regarding this subject, please contact the appropriate Nutrition Services Division staff member for your agency as indicated below.

Procurement Resources Unit (PRU)

You can contact the PRU by email at SFSContracts@cde.ca.gov to be directed to a PRU Specialist.

School Nutrition Programs (SNP)

You can find contact information for the SNP Specialists in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS). You can also contact Jeremy Partsch, SNP Office Technician (OT), by phone at 916-322-3005 or by email at jpartsch@cde.ca.gov.

Child and Adult Care Food Program (CACFP)

You can find contact information for the CACFP Specialists in the Download Forms section of the CNIPS. You can also contact Kayla Christensen, CACFP OT, by phone at 916-324-6153 or by email at kchristensen@cde.ca.gov [Note: The previous information is no longer valid. Please visit the California Department of Social Services CACFP web page or call 1-833-559-2420 for more information].

Summer Meals Unit

You can find contact information for the Summer Meals Unit (SMU) Specialists in the Download Forms section of the CNIPS for a list of SMU Specialists. You can also email SFSP@cde.ca.gov to be directed to an SMU Specialist.