ISNA OPERATIONS RESEARCH COMMITTEE
Procurement & Buy American BY AMANDA STOUT, SNS DIRECTOR OF FOOD SERVICES GREENFIELD-CENTRAL COMMUNITY SCHOOL CORPORATION
Tis the season for procurement! As Indiana school nutrition programs wrap up the USDA Foods Annual Pre-order (Forecast) Survey, programs may now be turning attention toward procurement of other goods and services for the new school year. Because child nutrition programs receive large amounts of federal dollars annually, these programs are subject to federal procurement standards. Procurement is defined as the over-arching strategy to obtain goods and services. Obtaining the most economical purchase by looking at affordability, quality, market conditions, and ethics are all things to be considered as it promotes free and open competition. Government-wide procurement regulations are published in 2 CFR 200.318-326 and are available for program operators to access during any type of procurement conducted. School nutrition programs are required to have written procurement plans on file outlining purchasing thresholds, procurement methods and procedures for each level (formal or informal), as well as a written code of conduct. The procurement plan may also include committee information, and timelines for advertising. The school nutrition programs’ procurement plan will be reviewed by the State Agency during the Administrative and Procurement Review processes, which are done consecutively. Another key feature of the procurement plan includes writing in Buy American language.
The Buy American Act of 1933 requires the federal government to buy American–made iron, steel, and manufactured goods wherever possible. A product is defined as American– made under “Buy American” if over 51% of the final processed product (by weight or volume) consists of agricultural commodities grown domestically. The Buy American provision requirements were added as part of the Child Nutrition Reauthorization Act of 1998. Its goal is to support American agriculture and serve children nutritious meals. Within school nutrition programs, the Buy American provision applies to food only. There are limited exceptions to the Buy American provision. This allows for the purchase of foods not meeting the “domestic” standards in instances where the use of a domestic food is not practical. Two examples of this include 1. not enough quantities are produced in the USA of a specific food item, and 2. procurement efforts reveal a higher cost of the USA-produced food item than that of an item produced by foreign countries. During the on- site portion of an Administrative Review, the State Agency will perform a walk-through inspection and check product labels in dry, cooler, and frozen storage spaces to confirm Buy American compliance. You may also be asked to supply documentation from vendors and company representatives.
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