2 CFR 200,
UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS
FOR FEDERAL AWARDS, Part 439 (Equipment and other capital expenditures)
requires that a School Food Authority (SFA) obtain prior written approval from the State Agency (SA - Child Nutrition
Unit (CNU), Division of Elementary and Secondary Education, Arkansas Department
of Education) before incurring the cost of a capital expenditure, including
equipment. According to 2 CFR 200.33, equipment means
tangible personal property (including information technology systems)
having a useful life of more than one year and a per-unit acquisition
cost which equals or exceeds the lesser
of the capitalization level established by the non-Federal entity for financial statement purposes, or
included on the Arkansas Approved Equipment List will receive automatic SA approval. Therefore, the
SFA may purchase those equipment items, following proper Federal, State, or
local procurement policies, as applicable, without submitting a prior written
request to CNU for approval.
under $5,000 must follow proper Federal, State, or local procurement policies,
as applicable, without submitting a request to CNU for approval.
memo does not apply to the Fresh Fruit and Vegetable Program (FFVP) equipment
purchases. Schools participating in the FFVP should contact Myia McBride,
If an SFA wants
to purchase equipment that is NOT on the pre-approved list or that costs $5,000
or more, the district must submit a written request for approval to Suzanne
Davidson (Suzanne.Davidson@arkansas.gov), CNU Director, prior to
purchasing the item. Please use the
attached Prior Approval Equipment Request Form.
If the SFA
chooses to use sole source purchasing for ANY equipment purchase (including
those on the pre-approved list or those under $5,000), the district must submit
a written request for approval to the CNU Director prior to purchasing the item.
Sole source purchasing, in the Child Nutrition Program, occurs when the goods
or services are available from only one manufacturer through only one
distributor or supplier. When faced with an actual sole source situation, the
SFA must first obtain approval, and then go directly to the sole source
provider to negotiate terms, conditions, and prices. See attached Arkansas Equipment Purchasing Flow Chart and Prior Approval Equipment Request Form for more information.
administrative reviews and audits, CNU must ensure appropriate equipment
purchases were made based on the approved equipment list or the prior approval
process. Any equipment purchases of $5,000 or more that are identified as
not being listed on the Arkansas Approved Equipment List or not having received
prior written approval will be considered an unallowable expense for the Child
Nutrition Program and must be paid with some other funds than the non-profit
food service account.
If you have any
questions, please contact your Area Specialist at 501-324-9502.