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School Nutrition Program Procurement Reviews
Overview
The procurement of goods and services is a significant responsibility of a School Nutrition Program (SNP) Sponsor, also called a School Food Authority (SFA). Obtaining the most economical purchase should be considered in all transactions when using Federal Funds. Federal, state, and local laws and regulations specify the procurement methods, terms, and conditions that must be used for each procurement and subsequent contracts.
The SNP Procurement Review is required by USDA for all Sponsors participating in SNP. MDE will conduct the review within an Administrative Review cycle (once every five years) and will typically happen in the same year as the Administrative Review and Resource Management Review, The Procurement Review evaluates a Sponsor's procurement policies, procedures, training, internal controls, contract management and a sample of procurement transactions for a complete fiscal year.
Comprehensive Procurement Review Process
For each Sponsor scheduled for review, the Procurement Team will conduct an in-depth Comprehensive Review. Each of the following steps is intended to assess compliance while providing technical assistance and resources related to procurement. The following is a snapshot of the process.
- Notification and Scheduling
- Sponsors receive an email from GEMS/MARS with Procurement Review related details including:
- Date and time for entrance conference meeting
- GEMS/MARS access information
- List of required documents
- Due dates
- Contact information for the Lead Reviewer
- Links to resources
- Instructions for next steps
- Sponsors receive an email from GEMS/MARS with Procurement Review related details including:
- Reviews are typically conducted virtually, but may include an on-site review, when scheduling aligns with other reviews or area visits.
- Procurement Review Entrance Conference Call
- Vendor Selection and Documentation Upload
- Findings Report with review results will be sent to the Sponsor by email
- This may include technical assistance and/or findings of non-compliance and details on required corrective action.
- The MDE Procurement Team will review and approve the corrective action, as applicable, then close the review. A final closeout email will be sent to the Sponsor.
Required Documents
- Comprehensive Procurement Review Documentation Checklist
- Policies and Procedures
- Procurement Policies
- Procurement procedures
- Purchasing-related policies (Include all policies governing the procurement of supplies, materials and equipment)
- Sample procurement procedure document: Sample School District Procurement Procedures
- Code of Conduct or Conflict of Interest
- Sample code of conduct document Sponsor Written Code of Conduct
- Vendor Paid List/Summary of Total Expenditures by Vendor Report
- This is a report of all vendors paid from the Sponsor’s nonprofit food service account.
- The Procurement Team will select vendors for review from the Vendor Paid List for each type of procurement conducted including micro-purchase, small informal, formal/sealed bids, and food service contracts
- Food Service Contract Documentation
- 12 months of Invoices
- 12 months of Operating Statements (FSMC Cost Reimbursement Contracts only)
- Reconciliations supporting your school district Planned Assistance Level (PAL) Report
- Any correspondence or other documentation supporting the review of invoices and operating statements for accuracy and allowable costs
- Training Documentation
- Documentation of annual procurement training
- Supporting Documentation for Each Selected Vendor
- Solicitation documentation (copies of small purchase price/rate quotes and/or sealed bids/competitive proposals issued, and advertisements published as applicable)
- Responses (quotes for informal procurement procedures and bids/offers for formal procurement procedures)
- Evaluation and scoring results used to award contracts
- Final contract awarded and contract notification documentation
- Supporting documentation, such as purchase orders, paid invoices, and receipts for vendors who are selected for review (eCFR:: 2 CFR 200.318 -- General procurement standards.)
- Reference the Procurement Review Checklist for a detailed list of documentation required for the review