ATTENTION: FEDERAL PROGRAMS; SUPERINTENDENTS; PRINCIPALS; GENERAL BUSINESS MANAGERS; BOOKKEEPERS; CO-OP DIRECTORS; CHILD NUTRITION DIRECTORS
This memorandum notifies all Child Nutrition Program operators of changes in the micro-purchase and simplified acquisition thresholds (small purchase) effective for School Year (SY) 2019-2020.
The United State Department of Agriculture (USDA), Food and Nutrition Services (FNS) received guidance from the Office of Management and Budget (OMB), authorizing increases to the value of the federal micro-purchase and simplified acquisition thresholds (also known as small purchase threshold). The thresholds for Child Nutrition Programs are as follows for SY 2019-2020:
- Federal micro-purchase threshold is $10,000.
Since the state simplified acquisition threshold is lower than the federal, the most restrictive must be followed.
- The Arkansas simplified acquisition threshold is $20,910.
See Commissioners Memo FIN-19-040 which establishes the state of Arkansas’ small purchase threshold for SY2019-2020 as $20,910 for additional information related to the state simplified acquisition threshold.
These changes must be implemented in the terms and conditions of bid awards, and program operators may implement the changes in their internal controls.
State and local agencies may set lower micro-purchase and simplified acquisition thresholds and thereby impose more restrictive procurement procedures as authorized by 7 CFR 210.19(e), 225.18(f), and 226.25(b).
Districts are reminded of the following requirements for micro-purchases in addition to the dollar threshold identified above:
- The transaction is less than the $10,000.
- Must distribute purchases equitably among suppliers.
- The price should be reasonable.
USDA recently released the attached Buy American Fact Sheet. This provides a great resource for a quick reference to the Buy American rules.
Although exceptions to the Buy American provision exist, they are to be used as a last resort. These exceptions are:
- The product is not produced or manufactured in the U.S. in sufficient and reasonable available quantities of a satisfactory quality; or
- Competitive bids reveal the costs of a U.S. product are significantly higher than the non-domestic product.
If a SFA is using one of the above exceptions, there is no requirement to request a waiver in order to purchase a non-domestic product. SFAs must, however, keep documentation justifying the exception(s).
The attached “Buy American Justification Form” is required for each non-domestic product purchased.
Attachments
Buy America Fact Sheet
Buy American Justification Form
SP 20-2019
SP 38-2017