Procurement Training Webinar

1. ProcurementTrainingWebinar

2. What is procurement? “Procurement” is a multi-step process for obtaining the most responsive goods and services.

3. Why is Procurement Important? • USDA requires that all purchases made by Child Nutrition Programs, whether funded entirely or in part with Child Nutrition funds, are conducted in accordance with all Federal Procurement requirements. • May help sponsors save money in the purchase of food and services

4. A Good Procurement Practice Includes • Free and open competition • Fairness and integrity • Responsible vendor, Responsive bid, and; • Transparency

5. Good Procurement Practice Includes It all starts with a Code of Conduct. Every Sponsor of USDA programs must develop/adopt their own Code of Conduct to be followed by all staff.

6. Sample Code of Conduct for Child Nutrition Programs •  The (Sponsor Name) employees, officers, or agents shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, political contractors, or parties to sub-agreements. Trivial benefits not to exceed a value of XXX incidental to personal, professional or business contracts and involving no substantial risk of undermining official impartiality may be permitted. •  Penalties for violations of the standards of code of conduct of the (Sponsor name)’s Child Nutrition Program may include any or all of the following: • Reprimand or other disciplinary action by Board • Dismissal by Board • Additional legal action as necessary

7. Good Procurement Practice Includes The non-Federal entity must maintain a written code of standards of conduct; establish procurement procedures and all procurement transactions shall be conducted in a manner that provides the maximum of free and open competition. These procedures must reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR 200.318. An institution should not knowingly do business with a company that is debarred or suspended. Consult with local legal advisors on the statutes applicable to each institution so the policy may be tailored to your facility.

8. Solicitations

9. Do you have a Procurement Plan? • What is it? A procurement plan assures that all purchases made with CNP federal funds are handled fairly and in a manner that encourages full and open competition that best meets the needs of your organization

10. Do you have a Procurement Plan? • Procurement procedures play a critical step in the overall process because they determine the type of procurement methods that will be used by the SFA/Sponsor and the type of contracts that will result. • For one reason, 2 CFR 200.318 requires that SFAs have procurement procedures in place. The procedures provide the specific roadmap for how the SFA is conducting procurement and compliance with regulations.

11. Procurement Plan • Delegate Purchasing Authority • Code of Standards of Conduct • Conflict of interest • Simplified Acquisition Threshold • Procurement Method for Informal and Formal Procurement

12. Procurement a Multi-Step Process

13. Federal Procurement Roadmap All CNP Sponsors Purchase/contract greater than $150,000 Purchase/contract less than $150,000 or most restrictive Use Formal Process IFB or RFP Use Informal Process

14. Procurement Methods • Formal • Procurement is over $150,000 or the restrictive threshold.

15. Procurement Methods • Formal • Over $150,000 • Invitation for Bid (IFB) • Request for Proposals (RFP) • Emergency procurement

16. Procurement Methods • Informal • Small procurement under $150,000 or most restrictive Aggregate cost - total amount the Sponsor has determined for a single item or related group of items for a period of time

17. Informal (Small Purchase) MethodSolicitation and Contract

18. Procurement Methods • Informal • Micro purchase under $3,500 or most restrictive per SFA policy • Reasonable cost • Buy American • Distributed equitably

19. Micro-Purchases • Micro-Purchase Threshold = < $3,500 • 2 CFR Part 200.67 and 2 CFR Part 200.320 • Aggregate dollar amount does not exceed the micro-purchase threshold. • Distribute micro-purchases equitably among qualified suppliers. • May be awarded without soliciting competitive quotations if the price is considered reasonable. • Best practice – include this in the procurement procedures.

20. Procurement – Buy American Buy American Provision found at 7 CFR Part 210.21 (d) (2) • An agricultural commodity that is produced in the United States; and food product that is processed in the United States substantially using agricultural commodities that are produced in the United States. • Requirement: The Department shall require that a school food authority purchase, to the maximum extent practicable, domestic commodities or products. • Two situations which may warrant a waiver to permit purchases of foreign food products 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 foreign product

21. Documentation • Retention of Procurement Documents Three years plus the current fiscal year (six + current with DOE) • Administrative Reviews or Audits

22. This institution is an equal opportunity provider.