What is a Procurement Plan? Just like it sounds, it is a written document that describes in full detail how you plan to procure the food and supplies for your district. Procurement Law 7 CFR 210.21 is the regulation that requires you to have a Procurement Plan in place and it must be customized to your district. Customization involves adhering to your State's bid thresholds and your local thresholds. Note that local district policies will supersede State and Federal laws.
It’s a Promise - By following your Procurement Plan you are promising to follow the law in your procurement practices.
It has a Purpose - The purpose of a Procurement Plan is to ensure free and open competition. Its other purpose is to state “how” you are going to do that.
It’s a Matter of Policy - Your Procurement Plan provides transparency that you are taking the correct steps to be in compliance with the law.
Let’s Get Started!
Follow these steps to put together your procurement procedures, or if you are short on time, you can hire a company to write the plan for you. These are the steps that My K12 Resource would pace you through if we were to write your Procurement Plan. Our procurement coach would help you through each task. With your coach by your side, you will be ready in time for your Administrative Review (AR)!
Being Proactive is Key
Be proactive! Ideally, it is preferable to be “review ready” PRIOR to your off-site procure
ment review. Some states will notify your department in the late Summer months of your scheduled review, while others provide a much shorter notification period. If your state agency has not provided a notification, try reaching out to them to see if they can provide an estimated time frame.
The GOAL is to have your Procurement Plan written and implemented prior to your review.
#1 Choose the methods of procurement you are going to use
The first major step in writing your Procurement Plan is stating in detail how you are going to buy. Which methods of procurement will you use - micropurchase, small or formal? How will you award, and what is your award criteria? The answers to these questions will be in your plan. This is where you will describe the methods you will use and signify who is the responsible party for the documentation.
The Federal, State, and local purchase thresholds are important to know for each method of procurement. The new Federal bid thresholds went into effect on August 1, 2018. OMB Policy Memo M-18-18 establishes these levels. Remember the State and local thresholds will take precedence if they are lower, as local will always trump State and Federal policies. The statement of the thresholds your department will adhere to is stated in your Procurement Plan, and the strictest of the thresholds are the ones you must follow.
#2 Create a method for tracking and recording your procurement activities
Doing everything right does not get you off the hook from documentation. Keeping good procurement records along the way will keep you from stressing out the week before your review. Some states provide suggestions for how to organize your records, but you still have work to do. As an option, your procurement coach can put together a Procurement Records Notebook for you and deliver it to you in the mail. Now all you have to do is follow the tabs and fill it up!
#3 Clearly define your purchase conditions
This section of the Procurement Plan a typically several pages long and it will tell your potential vendors the rules of the game. If they want to do business with your district, they will have to be prepared to meet your conditions. The conditions you set are designed to help you, as the buyer, to get the needs of your district met. An example of a condition would be the Buy American Act. It is the law (7CFR part 210.21) that every procurement includes this clause as a condition of doing business with the district. Most Procurement Plans will state 30 or more conditions in the document.
#4 Specifications, award criteria and weighted evaluations are required
In order to get what you want, you’ll need to create clear and concise specifications. A well-written specification can make the difference between getting the product you want and having to accept a cheaper substitute that does not help drive participation. Said another way, poorly-written specifications will ultimately cost you money. An award criteria must be set for all formal procurements, i.e. Invitation For Bid (IFB) and Request for Proposals (RFPs). In addition, competitive negotiations (RFPs) must have a weighted award criteria for proper evaluation of the responses. And, as you might have guessed, all of this must be documented in your Procurement Records notebook.
What else is included in your Procurement Plan?
There are other pieces of information that need to be included in your written plan; My K12 Resource can walk you through your plan line item by line item. For starters, potential suppliers must be given a point of contact, a way to ask questions, and a clear criteria to successfully submit a bid. You will also want to include your district’s Code of Conduct within your Procurement Plan.
Now that we have shed some light on the importance of the Procurement Plan in your Administrative Review preparation, let us help you out. If you’d like some help accessing your needs, reach out firstname.lastname@example.org to us! We’re here for you.
Talk to a procurement coach today to get help with your plan!