Arkansas Department of Education State Agency (SA) Prior Approval Process for School Food Authority (SFA) Equipment Purchases

Memo Information

Memo Number
CNU-16-004
Memo Date
8/13/2015
Memo Type
Regulatory
Section
Child Nutrition
Regulatory Authority
2 CFR 200.439(2); SP 31-2014
Response Required
NO
Attention
Federal Programs; Superintendents; Principals; Technology Coordinator; Test Coordinator; General Business Manager;

Contact Information

Memo Text

2 CFR 200, UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, Part 439 (Equipment and other capital expenditures) requires that a School Food Authority (SFA) obtain prior written approval from the State Agency (SA - Arkansas Department of Education, Child Nutrition Unit (ADE/CNU)) before incurring the cost of a capital expenditure, including equipment.  2 CFR 200.439 define “equipment” as any item of non-expendable personal property with a useful life of a year or longer and an acquisition cost which equals or exceeds the Federal per-unit capitalization threshold of $5,000 (or a lower threshold set by State or local level regulations).

 

Any equipment included on the attached ADE/CNU approved equipment list will receive automatic state agency approval. Therefore, the SFA may purchase those equipment items, following proper Federal, State, or local procurement policies, as applicable, without submitting a prior written request to ADE/CNU for approval.

 

Any equipment under $5,000 must follow proper Federal, State, or local procurement policies, as applicable, without submitting a request to ADE/CNU for approval.

 

This memo does not apply to the Fresh Fruit and Vegetable Program (FFVP) equipment purchases.  Schools participating in the FFVP should contact Stephanie Alsbrook, ADE/CNU FFVP at 501-324-9502.

 

If an SFA wants to purchase equipment that is NOT on the pre-approved list and that cost $5000 or more, the district MUST submit a written request for approval to the ADE/CNU prior to purchasing the item.

 

If the SFA chooses to use sole source purchasing for ANY equipment purchase (including those on the pre-approved list or those under $5000), the district must submit a written request for approval to the ADE/CNU prior to purchasing the item.  Sole source purchasing, in the Child Nutrition Program, occurs when the goods or services are available from only one manufacturer through only one distributor or supplier. When faced with an actual sole source situation, the SFA must first obtain ADE/CNU approval, and then go directly to the sole one source provider to negotiate terms, conditions, and prices. See attached Equipment Purchasing Flow Chart and Prior Approval Equipment Request Form for more information.

 

During local administrative reviews and audits, ADE/CNU must ensure appropriate equipment purchases were made based on the approved equipment list or the ADE/CNU prior approval process.  Any equipment purchases $5000 or more that are identified as not being listed on the pre-approved list or not having received prior written approval will be considered an unallowable expense for the Child Nutrition Program and must be paid with some other funds than the non-profit food service account. 

                    

Questions regarding this memo should be directed to the district’s area specialist.

 

 

 

Attachments:

Arkansas Approved Equipment List

Arkansas Equipment Purchasing Flow Chart

Prior Approval Equipment Request Form

SP31-2014