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Part 5: Micro-Purchase Procurement Method

Part 5: Micro-Purchase Procurement Method. 2 CFR 200.67 2 CFR 200.320(a). Oregon Department of Education “Our Why”. Equity and Excellence for Every Learner The Oregon Department of Education works in partnership with school districts , education service districts and community partners ;

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Part 5: Micro-Purchase Procurement Method

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  1. Part 5: Micro-Purchase Procurement Method 2 CFR 200.67 2 CFR 200.320(a)

  2. Oregon Department of Education“Our Why” Equity and Excellence for Every Learner • The Oregon Department of Education works in partnership with school districts, education service districts and community partners; • Together, we serve over 580,000 K-12 students; • We believe every student should have access to a high-quality, well-rounded learning experience; • We work to achieve the Governor’s vision that every student in Oregon graduates with a plan for their future.

  3. Oregon Department of EducationEducation Equity Stance Education equity is the equitable implementation of policy, practices, procedures, and legislation that translates into resource allocation, education rigor, and opportunities for historically and currently marginalized youth, students, and families including civil rights protected classes. This means the restructuring and dismantling of systems and institutions that create the dichotomy of beneficiaries and the oppressed and marginalized.

  4. Presentation Overview • Today’s Agenda • Define Micro-Purchasing. • Identify when the Micro-Purchase Method may be used. • Understand how to procure using the Micro-Purchase Method.

  5. Planning and Forecasting Menu planning and forecasting based off the program period and average daily participation rate drives the procurement process. Failure to plan and forecast could result in arbitrarily splitting the aggregate dollar amount.

  6. What is Micro-Purchasing? Procurement by micro-purchase is the acquisition of supplies or services when the aggregate dollar amount of which does not exceed the micro-purchase threshold. The aggregate value of the goods or services does not exceed $10,000.00. Program Sponsors must distribute purchases equitably among all qualified suppliers. May be awarded without soliciting quotes if the price is considered reasonable.

  7. What is the Aggregate Dollar Amount? The Aggregate Dollar Amount is: Cost of all goods and services purchased in a transaction. Cost of all items together cannot exceed the micro-purchase threshold which is currently set at $10,000.00.

  8. What is Equitable Distribution when using Micro-Purchasing? Equitable Distribution Means: Purchases must be distributed equitably among all qualified suppliers as long as the price is considered reasonable. Program Sponsor may not purchase from only one supplier repeatedly. Program Sponsor must apportion the cost over the program period so that one supplier does not benefit more than another qualified suppliers from the Federal award. Full and Open Competition is achieved through equitable distribution among all qualified suppliers when using the micro-purchase method.

  9. What is Reasonable Cost? A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Consideration must be given to: Is the cost generally recognized as ordinary and necessary. The restraints or requirements imposed by such factors as: Sound business practices Arm’s-length bargaining Federal, State, Local, Tribal, and other laws and regulations Terms and Conditions for the Federal award Market prices for comparable goods or services. Whether the Program Sponsor significantly deviates from established practices and polices regarding the incurrence of costs.

  10. Recordkeeping Recordkeeping Requirements: Transactions are properly recorded and accounted for. Provides reasonable assurance regarding the achievement of the objective for the procurement method used. Must remain on file for a minimum of three years.

  11. Scenario 1 A Program Operator contracts for janitorial services. The service is provided weekly. The cost is $200.00 per week. The program period contract value equals $10,400.00 The Program Operator is invoiced monthly. Can the Program Operator use the micro-purchase method for this award?

  12. Scenario 1 Response Answer: No The micro-purchase method cannot be used in this situation because the Program Sponsor would be splitting the aggregated dollar amount: The janitorial services should be forecasted and contracted based on contract value for the program period. The value of the transaction over the program period exceeds the micro-purchase threshold. The Program Sponsor would have to use the small-purchase method and receive price or rate quotes from an adequate number of qualified sources.

  13. Scenario 2 A Program Sponsor needs to make a one time purchase at a retail store: The total cost of all goods purchased is less than $10,000.00. Question: Can the Program Sponsor use the micro-purchase method if the prices are considered reasonable or do they have to use the Small-Purchase method by obtaining quotes from other retailers and select the retailer with the lowest prices?

  14. Scenario 2 Response Answer: Yes, the micro-purchase method is an allowable option in this scenario. Cost of the transaction is less than $10,000 The prices are considered reasonable The Program Sponsor must distribute future purchases equitably among other qualified suppliers.

  15. Scenario 3 A Program Sponsor receive monthly deliveries from a food service distributer throughout the program period. The Monthly invoice is $1,000.00 Total contract amount is $12,000.00 Question: Can the Program Sponsor award this purchase using the micro-purchase method?

  16. Scenario 3 Response Answer: No, this would be defined as arbitrarily splitting the aggregated dollar amount. Program Sponsor should plan and forecast their needs based off their menu’s and daily participation rates for the program period. The contract value is $12,000 and exceeds the micro-purchase threshold. Given the $12,000 value of the procurement transaction as a whole, the small purchase method would apply.

  17. Scenario 4 A Program Sponsor did not receive their milk delivery due to a snow storm. The purchase cost from a local grocery store is $500.00. The cost of the product is considered reasonable. Question: Can the Program Sponsor award this purchase using the micro-purchase method?

  18. Scenario 4 Response Answer: Yes, the micro-purchase method is an allowable option in this scenario. Cost of the transaction is less than $10,000 The prices are considered reasonable The Program Sponsor must distribute future purchases equitably among other qualified suppliers.

  19. Summary What is Micro-Purchasing. Definition of terms Examples

  20. Resources Resources 2 CFR 200.67 2 CFR 200.320(a) USDA memo SP 20-2019; CACFP 07-2019; SFSP 06-2019 USDA memo SP 02-2016; CACFP 02-2016; SFSP 02-2016

  21. USDA Discrimination Statement In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA. Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.govThis institution is an equal opportunity provider.”

  22. Here to HelpPlease Contact Us Richard Williams, Child Nutrition Program Procurement Compliance Specialist Richard.Williams@ode.state.or.us Follow us on Twitter! @ORDeptEd

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