If you are not not feeling 100% certain what your State’s expectations are for procurement review, you are not alone. Each state is different, but most have indicated that they don’t intend to be punitive, but instructive when conducting the procurement review. Still, it can be nerve-racking; especially when procurement reviews are fairly new.
It’s no small feat to understand all the requirements in 2 CFR, Part 200.318-326. When preparing to set up and organize your procurement program, be sure to seek out your State’s resources. Your first step will be to download your state's Procurement Tool.
It’s helpful to understand what the flow of the procurement review is so you can start to feel more comfortable with the process. With this convenient Flow Chart from SNA, you can see at a glance the steps that occur before, during, and after the Procurement Review.
6 Step Flow Chart of the Procurement Review
Now that we know what the State will require of you, let’s break down these steps into manageable pieces and get you on the road to procurement success. These steps will give you a road map for preparing for your review.
What Are The 6 Steps?
1. First, you will be notified by your state that your procurement review has been scheduled. The state will be looking at the previous school year's procurement activities. Your state will probably provide a link where you download the template and receive instructions. Some states will schedule a phone call with you to review what you need to turn in. Keep in mind, you may request a phone call to go over the requirements.
2. Just like in other Administrative Reviews, the state will ask you to turn in certain documents before your review date. For procurement review, you will usually turn in the procurement table and the vendor paid list. Check with your state well ahead of the review date to find out what you will need to turn in. You will want to download the school foodservice authority (SFA) procurement table and the vendor paid list template which is a summary of your expenditures and start filing it out way in advance of your review date.
3. Next, the state reviews the initial documents that you turned in to them. Most likely the additional documents you will be turning in are any cooperative purchasing agreements you have in place, your Code of Conduct, your Purchasing Procedures, and selected procurements. The state chooses which procurements to review.
4. Then, your state will request some additional documents from you and the offsite review continues.
5. The state will review the additional documents.
6. The final step is your state will go over the results of your review and any corrective actions. If there are corrective actions needed, they will provide technical assistance.
Each state can be slightly different, but let’s do a quick review of the type of documents the state will require you to turn in:
The Procurement Table is a template that you download and then you fill in your purchases.
The Vendor Paid list is a list of your purchases.
The Code of Conduct is a document that explains what your district will do to eliminate any conflicts of interest. It governs the performance of employees who are engaged in the product selection, award of the bid, and administration of contracts.
The Procurement Procedures document is a 10-20 page chronicle that is tailored to your district. It is a compilation of purchasing policies and procedures that assure full and open competition and transparency in your purchases.
Award records that show your formal bids have a method of award and you have awarded to the responsive and responsible vendor with the lowest price.
Award records for your Micropurchases and Small Purchases.
Another great resource to be sure your procurement program is complete and meeting the regulations is the Procurement Puzzle white paper provided by the School Nutrition Association (SNA).
If at anytime you have a question and would like to speak with a procurement coach, we are here for you!
My K12 Resource, LLC