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

Memo Information

Memo Number
CNU-20-001
Memo Date
8/7/2019
Memo Type
Regulatory
Unit
Child Nutrition
Regulatory Authority
SP 39-2016
Response Required
NO
Attention
Superintendents; Principals; General Business Managers; Child Nutrition Directors/Managers

Primary Contact Information

Memo Reference

No references available.

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 - Child Nutrition Unit (CNU), Division of Elementary and Secondary Education, Arkansas Department of Education) before incurring the cost of a capital expenditure, including equipment.  According to 2 CFR 200.33, equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000.

 

Any equipment included on the Arkansas Approved Equipment List will receive automatic SA 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 CNU for approval.

 

Any equipment under $5,000 must follow proper Federal, State, or local procurement policies, as applicable, without submitting a request to 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 Myia McBride, at 501-324-9502.

 

If an SFA wants to purchase equipment that is NOT on the pre-approved list or that costs $5,000 or more, the district must submit a written request for approval to Suzanne Davidson (Suzanne.Davidson@arkansas.gov), CNU Director, prior to purchasing the item.  Please use the attached Prior Approval Equipment Request Form.

 

If the SFA chooses to use sole source purchasing for ANY equipment purchase (including those on the pre-approved list or those under $5,000), the district must submit a written request for approval to the CNU Director 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 approval, and then go directly to the sole source provider to negotiate terms, conditions, and prices. See attached Arkansas Equipment Purchasing Flow Chart and Prior Approval Equipment Request Form for more information.

 

During local administrative reviews and audits, CNU must ensure appropriate equipment purchases were made based on the approved equipment list or the prior approval process.  Any equipment purchases of $5,000 or more that are identified as not being listed on the Arkansas Approved Equipment 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. 

 

If you have any questions, please contact your Area Specialist at 501-324-9502.


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