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• Procurement is a major responsibility of each SFA – almost half of the SFA's reimbursement is used on the procuring of goods and/ or services.
• Procurement has a major impact on financial stability of the SFA's nonprofit school food service account.
• Not just another “food service" requirement. 2 CFR 200 applies to ALL federal grants and most SFAs receive Federal grants other than just from the Child Nutrition Program.
  

• Obtaining the most economical purchase should be considered in all purchases when using Federal funds.
• All Procurement transactions must be conducted in a manner that provides maximum open and free competition.
• Federal, state and local laws and regulations specify the procurement method, terms and conditions SFAs must follow to competitively procure goods and services, award contracts, and oversee contractor performance, (2 CFR 200.318(b)).
• State agencies are required to ensure that SFAs comply with applicable provisions through audits, administrative reviews, technical assistance, training guidance materials and by other means (7 CFR 210.169(a)(3)). ​
  

• Includes reviewing the SFA's procurement documentation and assessing compliance with the procurement standards.
• The State Agency (ISBE) has the discretion to conduct the procurement review off-site, on-site, or off-site/on-site as long as all procurement documentation needed to conduct the review can be obtained by the State Agency.
• The procurement review may be conducted as part of the Administrative Review, or as a separate review, as determined by the State Agency. State Agencies must conduct a procurement review on all SFAs once in each review cycle.
• Once review is complete, the State Agency (ISBE) may provide technical assistance and establish findings and required corrective action, as applicable. ​
  

The State Agency, the Illinois State Board of Education (ISBE), will conduct the procurement review using a step-by-step approach. From notifying each SFA of a procurement review to closing the review, each step is intended to assess compliance while providing technical assistance in the area of procurement.

Overall, the State agency will:

• Notify SFA of a procurement review
• Schedule the review
• Send the SFA a Procurement Tool to complete and request a list of documentation needed to conduct the review
• Conduct the review either on-site or off-site, or both
• Report review results with the SFA
• Require corrective action, as applicable
• Review and approve the corrective action, as applicable
• Close the review​
  

• Conduct compliant procurement processes
• DOCUMENT! DOCUMENT! DOCUMENT!
• Ensure you have written, detailed procurement procedures
• Ensure you have a compliant code of conduct
• Incorporate language in your procurement procedures, solicitations and contracts for food specification to ensure compliance with the Buy American provision
• Monitor contractors for compliance with specification, terms, and conditions of contracts
• Review your procurement process and procedures annually ​
  

• SP 33-2019: USDA Procurement Tool Guidance
  
• Introduction to the Procurement Review Tool​​
  
• USDA Procurement Tool
  
• ISBE Back to School Procurement Trainings​
  
• Below are optional documents to use if written procedures do not currently exist. This document is a sample and is not intended to be all-inclusive. This document does not replace pre-issuance contracts with Vendors and Food Service Management Companies as required by the Illinois State Board of Education. The School Food Authority/ Sponsoring Organization is ultimately responsible to ensure that the local procurement procedures complies with all Federal Regulations, State Rules and Regulations, and local procurement policies.​
  
• Sample Code of Conduct Template (USDA)
  
• Sample Procurement Procedures: SNP (ISBE)
  
• Sample Procurement Procedures: SNP (ADE)
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