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School Nutrition Program Procurement Reviews


The procurement of goods and services is a significant responsibility of a School Nutrition Program Sponsor. Obtaining the most economical purchase should be considered in all purchases when using Federal funds. Federal, state, and local laws and regulations specify the procurement methods, terms, and conditions. Sponsors competitively precure goods and services, award contracts, and oversee contractor performance. State agency oversight is required to ensure Sponsors comply with the applicable provisions through audits, Procurement Reviews, technical assistance, training guidance materials, and by other means.

A Procurement Review will be conducted of each School nutrition program Sponsor within an Administrative Review cycle (once every five years). The Procurement Review may or may not occur in the same school year as a Resource Management or Administrative Review.

Summary Procurement Review

For each Sponsor scheduled for review, the Procurement Team reviews data available from multiple sources to determine each Sponsor's possible risk for non-compliance with Procurement regulations. Date may include but is not limited to, commodity and commercial food spending date from consortia's, year-end reporting data, Food Service Contract procurement information, and Planned Assistance Level (PAL) reports. Sponsors may receive notification via email if a Summary or a Comprehensive Review is required. If a Summary Review is required, no further action is required by Sponsors.

Comprehensive Procurement Review


If the Summary Review of data indicates a risk level associated with a Comprehensive Review, the MDE Procurement Team will then conduct an in-depth Comprehensive Review. Each of the following seeps 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
  • 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.

Required Documents

  • Sponsor Written Code of Conduct
  • Sponsor’s Documented Procurement Procedure
  • Vendor Paid List/Summary of Total Expenditures by Vendor Report
    • This is a report of all vendors paid from the Sponsor’s nonprofit foodservice 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 bid, and Food Service Contracts
    • Sample Vendor paid list - coming soon
  • Sponsor Procurement Table
    • This will be sent via email during notification and scheduling
    • Sample of completed Sponsor Procurement Table – coming soon
  • 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 (for competitive proposals – RFPs)
    • Final contract awarded and contract notification documentation
    • Supporting documentation, such as purchase orders and/or receipts/invoices for vendors selected for review (2 CFR 200.318(i)).