ADE Director's Communication Memo Form

Memo Number : FIN-09-069

Date Created : 04/17/2009


Co-op Directors
other: Principals
Purchasing Agents
Child Nutrition Directors

Type of Memo: Regulatory
Response Required: Optional
Section:   Fiscal and Administrative Services - William J. Goff, Assistant Commissioner
Purchasing Cooperatives and Applicable Procurement Regulations for Federal Child Nutrition

Regulatory Authority:
7 CFR 210, 220, 215, 3015, 3016, 3019, OMB Circulars A-87, A-122, USDA FNS Memo SP-15-2008 SP-10-2009, A.C.A. § 6-21-304

Contact Person:
Wanda Shockey

Phone Number:


The memo is intended to provide guidance to School Food Authorities/Local Education Agencies (LEA) regarding purchasing cooperatives and other resources available to assist with procurement in federal child nutrition programs.

Arkansas school nutrition directors and superintendents are seeking ways to cope with the lack of revenue and increased food costs. A number of district child nutrition directors and superintendents have recently had questions regarding issues of establishing purchasing cooperatives. Although the Arkansas Department of Education (ADE) Child Nutrition Unit (CNU) has not received clarification on specific issues from the United States Department of Agriculture (USDA), Food and Nutrition Services Division (FNS), concerning applicability of the new USDA federal procurement regulations to some aspects of Purchasing Cooperative Agreements with third parties, this memo is to address what is known at this time.

There are many advantages to forming informal purchasing groups (school nutrition directors meeting together to construct a proto-type bid in which no additional staff or funds are involved) and/or formal purchasing cooperatives (containing a number of districts with education cooperative employee responsible for the procurement process) in order to increase volume of products to get the best quality for the best price advantage. The National Food Service Management Institute (NFSMI) FREE resource, “First Choice: A Purchasing Systems Manual for School Food Service, 2nd Edition, USDA with NFSMI, Revised 2002” reiterates the advantages of forming purchasing groups or purchasing cooperatives as a means to provide cost savings and service improvements by reaching economies of scale by using common purchasing practices.

As a starting point for forming a formal purchasing cooperative or using a purchasing consultant’s services, a major NFSMI recommendation is to seek legal counsel with purchasing experience to do the necessary research and ensure compliance with state and federal laws. Please be reminded that legal counsel for a consultant or company is considered an employee of that consultant or company. Therefore, the application of legal opinions may reflect the views of the consultant or company and not those of the district legal counsel.

This memo will address some of the applicable state regulations, federal regulations, and other considerations regarding the use of an individual consultant, consulting services company, food service management companies (FSMC), administrative agents, and/or the creation of a purchasing group and/or purchasing cooperative administered by an education cooperative for school district nutrition programs or purchasing group. For clarification, the list of entities in the previous sentence includes: sole proprietorships, partnerships, or corporations, all of which must be licensed to do business in Arkansas and pay Arkansas taxes providing service to local education agencies.

It is a local district option to determine the direction of the school nutrition program and to make decisions to meet the district needs. All decisions to procure products that obligate or expend nonprofit food service account funds must be in compliance with applicable state and federal regulations.


With regard to legislation and regulatory language, school districts that operate federally reimbursed school nutrition programs are known as School Food Authorities (SFA)/Local Education Agencies (LEA). Any SFA/LEA approved by the Arkansas Department of Education (ADE) Child Nutrition Unit (CNU) to operate and receive federal funds MUST COMPLY WITH all State and Federal COST and PROCUREMENT standards and applicable state/federal regulations, policy memos, and instructions.

The USDA Policy Memos and Instructions are regulatory interpretations and implementation mechanisms that provide additional information necessary for making determinations as to the applicability of regulations to a procurement process. The documents are numbered and remain in place until new regulations are promulgated.

Many times after new regulations are finalized, USDA will continue to issue clarifications regarding the new final regulations through Policy Memos. ADE, CNU provides local school district school nutrition directors these clarifications to regulatory information through:
• The ADE Commissioner’s Memo process,
• Incorporation of new regulatory changes into the:
...o Director Certification Training Program,
...o Annual Directors’ Conference presentation, and
...o Distance Education (three hour monthly workshops) held on a monthly basis during the school year
• Technical assistance visits to local school districts,
• Procurement workshops.


The following are general requirements and excerpts from long-term state and federal regulations and/or new procurement regulations that are applicable to single SFA/LEA procurements and/or districts that wish to participate in a formal purchasing group or purchasing cooperative with other SFA/LEAs.


Any service or services provided by an individual, governmental entity, a sole proprietorship, partnership, or corporation to a single SFA/LEA or group of SFA/LEAs that result in procurement of products or procurement activities that are to be paid for by the nonprofit food service account funds SHALL be in compliance with federal requirements.

Examples of the above service or services that a district may consider for cooperative purchasing, and/or consulting services for the district school nutrition program may include, but are not limited to ADVICE and RECOMMENDATIONS:
(1) for procurement of food and other supplies, or
(2) menu planning or use of planned menus that drive procurement (even in the case of a food service management company, the district retains responsibility for approval and control of menus), or
(3) financial analysis, or
(4) data analysis, computer services for the SFA/LEA.
Management of any of the above aspects or any other aspect of a school nutrition program requires the SFA/LEA to follow ADE CNU (state agency) pre-issuance and approval processes of procurement transactions and federal requirements designated for procurement and renewal of Food Service Management Company contracts. See ADE Commissioner’s Memo FIN-09-063.

All procurements and/or procurement activities will be based on:

• OPEN AND FREE COMPETITION. The formal bid process IS REQUIRED if purchased services are $ 10,000 or more. Ark. Code Ann. 6-21-304 requires that all Food Service Contracts (including consulting services) in excess of $10,000 must be formally bid or procured (this issue is discussed in greater detail in Arkansas Attorney General's Opinion Number 95-294). A procurement made for food services such as a consulting contract using school district funds is not eligible for a school board exemption from the formal procurement process.

Open and free competition cannot be circumvented with donated services by a consultant or vendor. To allow the use of donated services, the procuring entity/SFA would in effect be providing a potential vendor/contractor with a distinct competitive advantage over other bidders that could provide this same service and/or other services. This situation could be considered an impairment to open and free competition. Requiring vendors to pay a fee to participate in the procurement process is an impairment to open and free competition.

• CLEAR/TRANSPARENT TRANSACTIONS validated by standards of ethical conduct established all parties involved in any procurement to include no conflicts of interest based on relationships with bidders, brokers, food manufacturers and use of anti-kickback language ( 7CFR 3016.36 and Copeland 'Anti-Kickback' Act (18 U.S.C. 874) and affidavits signed by all parties.

• ALLOWABLE COSTS payable from NONPROFIT SCHOOL FOOD SERVICE ACCOUNT. Non-allowable cost examples would be procurement fees or legal fees to form a purchasing cooperative. Allowable costs are direct expenses incurred for operation such as a fee for service (bid preparation), postage, etc. Requiring participating SFA/LEAs to pay membership fees collected by a third party (sole proprietorship, partnership, or corporation) to circumvent payment of procurement fees and the bidding process to secure consultant services is not allowed.

• ALL allowable costs shall be NET ALL DISCOUNTS, REBATES, and APPLICABLE CREDITS - See 7 CFR 210.21 below:
(i) “Allowable costs will be paid from the nonprofit school food service account to the contractor net of all discounts, rebates, and other applicable credits accruing to or received by the contractor or any assignee under the contract, to the extent those credits are allocable to the allowable portion of the costs billed to the school food authority';

• TRACKING system of all discounts, rebates and applicable credits to meet USDA audit standards. See 7 CFR 210.21 below:
(ii)(A) “The contractor must SEPARATELY IDENTIFY FOR EACH COST SUBMITTED FOR PAYMENT to the school food authority the amount of that cost that is ALLOWABLE (can be paid from the nonprofit school food service account) and the amount that is UNALLOWABLE (cannot be paid from the nonprofit school food service account); OR
(B) The contractor must exclude all unallowable costs from its billing documents and CERTIFY that only allowable costs are submitted for payment and RECORDS have been established that MAINTAIN THE VISIBILITY OF UNALLOWABLE COSTS, including directly associated costs in a manner suitable for contract cost determination and verification;
(iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental (USDA) and Program regulations and (United States) Office of Management and Budget cost circulars;
(iv) The contractor MUST IDENTIFY THE AMOUNT OF EACH DISCOUNT, REBATE, and OTHER APPLICABLE CREDIT ON BILLS AND INVOICES presented to the school food authority for payment and individually identify the amount as a discount, rebate, or in the case of other applicable credits, the nature of the credit. If approved by the State agency, the school food authority may permit the contractor to report this information on a less frequent basis than monthly, but no less frequently than annually;
(v) The contractor must identify the method by which it will report discounts, rebates and other applicable credits allocable to the contract that are not reported prior to conclusion of the contract; and
(vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department,”



With consulting services there is a contract/agreement upon the services to be provided. The price or value of those consulting services should be determined by a formal bid or request for proposal in an open and free competition by the SFA/LEA.

Consulting services generally provide guidance and/or recommendations to SFA/LEA, development of business tools or training materials, provision of training to personnel of the SFA/LEA, but do not include the final management decisions which determine SFA/LEA relationships with vendors or determine final obligations of nonprofit food service account funds, etc. The district or education cooperative will employ a person or persons to make the final decisions and perform the associated management functions.

To ensure that no conflict of interest exists, the consultant or consultant company should declare to the SFA/LEA or Purchasing Group or Purchasing Cooperatives all past and current contractual relationships with mutual business parties/entities to be involved in a project. To ensure that all actions are transparent and at arms length by all parties involved, SFA/LEA, Education Cooperative and consultant contractor, there must be an open and free competitive process for selection of the final contracted consultant contract services.


7 CFR 210.2 states “Food service management company means a commercial enterprise or a nonprofit organization which is or may be contracted with by the school food authority to manage any aspect of the school food service.”

If a school district, cooperative purchasing entity, or group has a third party manage (make final financial decisions that obligates federal funds, and/or represents the district or group in negotiations and commitments with vendors, food manufacturers, brokers, etc.) for one or more aspects of the district food service program then that third party entity is considered a Food Service Management Company under the above regulation. See ADE Commissioner’s Memos FIN-09-062 and FIN-09-063 for applicable regulations and procedures when contracting with a FSMC.

Failure to interpret the correct status of the contract as either a consulting services or a food service management company contract can lead to improper procurement. There are very specific timelines and procedures for FSMC RFP/Contracts that must be followed with state agency, ADE CNU. Based on 7 CFR 210.16 (a) (9) PRIOR WRITTEN APPROVAL BY ADE, CNU is required for the pre-issuance document and CONTRACT BEFORE EXECUTION. The non-profit school food service account funds cannot pay for the contract service or services if proper procurement is not completed.

Any substantial changes in the FSMC RFP/Contract after state agency approval has been received will require that the contract be rebid. One example of a substantial change in the contract would be if the menu planning option were changed.


Procurement of food or other services performed by a FSMC, Consultant Service, Purchasing Cooperative Entity or Purchasing Group SHALL NOT INCLUDE DELEGATION of any SFA/LEA responsibilities that are part of the Agreement and Policy Statement to operate the federal child nutrition programs in the school district. The fiscal responsibilities and accountability for operation of the federal child nutrition program CANNOT be delegated by the district to any other party or entity.

For example, if a school district over claim (repayment of federal funds) for reimbursement is assessed by ADE, CNU for meals served to students that do not meet the meal component requirements due to failure of a vendor to deliver the appropriate product or simply no product delivery at all, the district will be responsible for either
(1) Repayment of all federal funds to the USDA or
(2) Disallowance of reimbursement for meals that do not meet requirements.
The SFA/LEA must seek restitution or secure repayment of funds from the vendor contractor. The purchasing cooperative shall intervene with the vendor on behalf of the school, depending upon the responsibilities as delineated in the Purchasing Cooperative Agreement/Contract.


Caution: In all procurement processes related to federal child nutrition programs, FEDERAL regulations 7 CFR 3015, 3016.36 (b) (3) (iv), and 3019 SUPERSEDE Arkansas Department of Education, Arkansas Ethics Rules: 15.0 Registration, Travel, Conventions, and Seminars, 15.1 and 15.2 in these regulations in the matter of procurement ethics. All board members, administrators, education cooperative directors, child nutrition directors, district employees or third party service providers involved in the SFA/LEA procurement process shall abide by the following:

No current or POTENTIAL vendor, consultant, manufacturer or distributor shall pay for or provide ANYTHING OF MONETARY VALUE such as registration fees, hotel rooms, transportation, trip expenses, etc. to visit food shows, factories or any gifts for educational or any other purposes because these parties have a responsibility in the SFA/LEA procurement process. SFA/LEA/Education Cooperative employees will neither solicit, nor accept gratuities, favors, or anything of monetary value from current or potential contractors, consultants, vendors, manufacturers or distributors, etc.


For clarification, the 7 CFR 220.2 (O) (3) “Nonprofit School Food Service Account means the restricted account in which all of the revenue from all food service operations conducted by the SFA principally for the benefit of school children is retained and used only for the operation or improvement of the nonprofit school food service.”

The final rule, Procurement Requirements for the National School Lunch, School Breakfast and Special Milk Programs, published October 31, 2007, EXPLICITLY LIMITS the USE of nonprofit school food service account funds to costs resulting from PROPER PROCUREMENTS of AGREEMENTS, and CONTRACTS.

“7 CFR 210.21(c) (3) PROHIBITED EXPENDITURES. No expenditure may be made from the nonprofit school food service account for any cost resulting from a procurement failing to meet the requirements of this part.”

School administrators should be aware that other school district funds must be used to pay district food service procurement obligations if procurements are found improper in annual state required audits, ADE, CNU monitoring reviews, or USDA reviews.


USDA Memo SP-15-2008 states “any fee (including a procurement fee) that is directly tied to the amount of discounts, rebates, and applicable credits to be returned to the SFA is an UNALLOWABLE nonprofit school food service account cost … A fee structured in this way is clearly intended to return some or all of the discounts, rebates, and applicable credits to the company with whom the SFA has contracted for services rather than to ensure that the fee accrue to the nonprofit school food service account. This is true whether the fee is set forth in the solicitation/contract or not.” In 7 CFR 220.2 (a) (1) the term “Applicable Credits” “shall have the meaning established in the Office of Management and Budget Circulars: A-87 C (4) and A-122 A, A (5), respectively.

Efforts to circumvent the unallowable procurement fee by charging membership fees to SFAs participating in a purchasing cooperative and charging vendors to do business with an SFA does not provide clear and transparent accountability to the public and impedes open and free competition in the procurement process.


USDA Policy Memo SP-08-2009 date January 9, 2009, provides the following response with regard to SFA/LEA participation in purchasing groups:

“13) Question: Can an SFA purchase directly from a Buying Organization or Group?

USDA Answer: SFA’s are not prohibited from purchasing from a buying organization or group, as long as they comply with the government-wide procurement rules at 7 CFR 3016 and 7 CFR 3019. However, an SFA CANNOT PURCHASE DIRECTLY from a buying organization WITHOUT considering other sources. Depending on whether the procurement is informal or formal, the APPROPRIATE COMPETITION MUST TAKE PLACE to ensure that the SFA is obtaining the lowest responsive bid or offer. Joining or procuring directly from a buying service WITHOUT OPENING UP COMPETITION TO OTHER LIKE SOURCES DOES NOT ensure that the lowest responsive bid or offer has been obtained. The prices of a buying group or organization could be factored in and assessed against other bidders or offerors.”


7 CFR 3016.36 (i) (2) “Termination for cause and for convenience by the grantee or subgrantee” (SFA/LEA) “including the manner by which it will be effected and the basis for settlement. (All contracts in excess of $10,000)”

Vendor, broker, manufacturer, contractor, distributor, etc. of a product cannot have input into the development of product specifications or procurement specifications and/or advance review of the completed procurement documents, Requests for Proposal (RFP)/Contracts. Such activities would compromise open and free competition [7 CFR 3016.60(b)].

See Attachment A for the USDA Policy Memo SP-10-2009 dated January 23, 2009 that indicates the responsibility of the SFA to monitor contracts with economic adjustment for de-escalation prices. Another important point of this memo is that the SFA determines whether to include economic price adjustment in a bid, request for proposal or contract and inclusion of this provision IS NOT THE VENDOR’S DECISION. The SFA must have documentation to support contract monitoring when an economic adjustment is allowed.

7 CFR 220.2 (d) (1) Contractor means a commercial enterprise, public or nonprofit private organization or individual that enters into a contract with a school food authority.

The “Proto-type Purchasing Cooperative Agreement” in Attachment B is required by ADE CNU as part of any Arkansas SFA/LEA and Education Cooperative Purchasing Cooperative Agreement to ensure compliance with applicable federal procurement regulations.

This Proto-type is to be part of any final document that effectively establishes a purchasing cooperative with multiple school districts or uses a consultant or consultant services for any procurement that obligates federal nonprofit school food service account funds.

With the assistance of legal counsel SFA/LEA participants in a Purchasing Cooperative Agreement may want language drafted to cover clarifications of responsibilities, liabilities, and risk management efforts related to several issues that may arise in food procurement, delivery and utilization of purchased foods. Please see Attachment C “Purchasing Cooperative Agreement Additional Content” for a list of issues that may add additional content to the PURCHASING COOPERATIVE AGREEMENT/CONTRACT. This list is not intended to be all inclusive.

Please remember that any change in menu planning options made by the SFA/LEA requires a PRE-APPROVED amendment to the current Child Nutrition Agreement and Policy Statement between ADE, CNU and the SFA/LEA. Failure to notify ADE, CNU of the change in selection of the menu planning option for each school with age and grade groupings identified as part of the menu planning process will jeopardize the meal reimbursement in the school district.

This is a federal compliance issue due to compliance with USDA Schools Meals Initiative (SMI) Protocol Requirements that cannot be ignored. The menu planner for each school in the district must be identified and a new revised SFA/LEA CN Program Schedule A submitted for approval. Designated menu planners on the CN Program Schedule A must be an Arkansas Certified Director or Certified Manager in the local school district. The responsibility of approving and changing school menus CANNOT BE DELEGATED or CONTRACTED to a second or third party (7 CFR 210.16)


Before school districts purchase consulting services or form a Purchasing Cooperative for school nutrition programs, a review of current free resources should be made in order to make the most cost effective use of limited SFA funds. The following sections identify FREE RESOURCES that may prove to be more immediate solutions to reducing food and labor costs.



The Arkansas Office of State Procurement (OSP) has primary responsibility and oversight for the statewide procurement of commodities, technical and professional services for all State agencies, Boards and Commissions and Colleges and Universities. The OSP can be a valuable FREE resource. SFA/LEAs as “Local Public Procurement Units” can request to buy from or be included in OSP Mandatory Contracts for specific food product categories or use the online bid tabulation sheets for price comparisons. These “Mandatory Contracts” are only mandatory for specific state agency programs, but generate significant volume for price reductions and have delivery in even remote areas of the state.

For questions related to the use of the Food/Grocery Bid Process by local districts, please contact Ms. Amy Stoddard, CPPB the OSP Buyer. For training for local education cooperative districts on state purchasing laws or regulations contact Mr. Rick Smith, CPPB, CPP, PCS/Training/Grocery Division Manager.

The general link for OSP is
To view the food bid documents and bid tabulations, simply go to the drop down link for STATE CONTRACTS and click on “Mandatory Contracts” where the following food bids are listed:
• Bread
• Milk (Note frequency of bid requests)
• Cereal
• Cheese
• Dairy Foods
• Frozen Foods
• Groceries
• Meat
• Poultry
Please note that the School for the Blind and School for the Deaf operate federal child nutrition programs and use these state food bids. There are specific references to federal child nutrition requirements and requirements for provision of child nutrition labels in some of the bids. School districts may want to carefully review the Terms and Conditions and Specific Requirements of each Food Category of the state bids. These bids can be models for formal bids for use in the SFA/LEA food purchases.

These Mandatory Bids are required for state agencies. Thus individual institutions served by this procurement process may request Specific Requirements. Review by district legal counsel should be considered to identify any applicable local SFA/LEA purchasing policy requirements that may differ from the state purchasing laws and regulations. Districts can immediately request to use the pricing and food distributors awarded these state foods contracts and thus comply with the competitive open and free formal procurement process.



The Arkansas Department of Education (ADE), Child Nutrition Unit (CNU) in an effort to assist Arkansas school districts to meet the School Meals Initiative Nutrition Standards, secured USDA grant funding to pay for the development of the “Three Steps to Healthy School Meals Menu Management System:” The purposes of this project were:
• To assist schools in meeting the USDA School Meals Initiative (SMI) Nutrition Standards and Traditional USDA Meal Pattern Requirements,
• To reduce paper work at the district and school levels, and
• To reduce administrative labor costs for local school districts.

Currently 723 schools out of 1095 schools, 197 school districts in 73 counties use this FREE Menu Management System in part or entirely as a resource to plan menus that will benchmark programs to the USDA Nutrition Standards. The approximate savings to Arkansas school districts has been in excess of 15 million dollars over 10 years.

The Three Steps System has been updated and expanded each year. This FREE resource is a COMPUTERIZED system on CD Rom complete and up to date with:
1. RECIPES complete with
...o Targeted nutrients in the USDA, School Meals Initiative (SMI) Protocol and portion sizes related to the Traditional Meal Pattern,
...o FOOD DESCRIPTIONS for FOOD BIDS to be used for the development of food specifications and to ensure compliance with nutrient analysis data
...o Hazard Analysis Critical Control Points (HACCP) required by federal sanitation regulations.
2. MENU CARDS that are colored coded based on nutrient analysis and fat content so that when put in correct combinations the Menu Cards create a Menu Cycle. The Menu Cycles, planned by the local school district based on the Menu Card selections, are benchmarked to the USDA Meal Pattern Nutrient based on USDA approved database and in compliance with the USDA Nutrition Standards for the School Meals Initiative for reimbursable meals.
3. FOOD PRODUCTION RECORDS are available for each Menu Card List with Recipes and Ingredients of Recipes. The Microsoft Excel FOOD PRODUCTION RECORDS require the school manager or director to insert the number of meals planned and the spreadsheet will automatically calculate the quantity of the item to be prepared using the USDA Food Buying Guide data, etc.

The National School Food Service Management Institute was created by Congress to provide training and free resource support and to conduct on-going training in procurement, quantity food production, and financial management. NFSMI will provide several “FIRST CHOICE” PROCUREMENT WORKSHOPS in Arkansas in 2009 starting with one in May and two workshops next fall. More information will follow regarding these workshops.

For an alphabetical list of these FREE resources click on: or the Resource Center at

PURCHASING - Page numbers relate to the location of the FREE Downloadable Resources from the 2008 NFSMI Resource Catalog:
• Choice Plus: A Reference Guide for Foods and Ingredients (p. 6)
• Choice Plus Food Safety Supplement (p. 7)
• Cooperative Purchasing for Child Nutrition Programs (p. 7)
• First Choice Purchasing System Workshop Evaluation (p. 1)
• First Choice: A Purchasing Systems Manual for School Food Service, 2nd Edition (p. 8)
• Food Buying Guide for Child Nutrition Programs Instructor Manual and Participant Workbook (p. 9)
• Food Purchasing for Child Care Centers (p. 9)
• NFSMI Insight – Purchasing Decisions for Cost
• Effective Implementation of the Dietary Guidelines for Americans (p. 21)
• Procurement Education and Training (p. 12)
• Procurement Practices Influencing Programs Operating Within the Guidelines of the Child and Adult Care
• Food Program: A Review of Literature (p. 18)
• Responding to a Food Recall (p. 12)
• Check It In Mini-Poster (p. 6)
• Choice Plus Food Safety Supplement (p. 7)
• Inventory Management (p. 11)
• Serving It Safe, 2nd Edition (p. 13)
• Serving It Safe Instructor Guide, 2nd Edition (p. 13)
• Serving It Safe Interactive CD-ROM (p. 13)

Other federal information that may be necessary to review can be found under “Agriculture” at These items should include the following:

•7 CFR 3015 Uniform Federal Assistance Regulations
•7 CFR 3016 Procurement Regulations
•7 CFR 3017 Debarment and Suspension Regulations
•7 CFR 3018 Lobbying Regulations
•7 CFR 3019 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and other Non-Profit Organizations
•7 CFR 210 National School Lunch Program Regulations
•7 CFR 215 Special Milk Program
•7 CFR 220 School Breakfast Program Regulations
•7 CFR 225 Summer Food Service Program Regulations,if applicable
•7 CFR 245 Eligibility Regulations
•7 CFR 250 Commodity Regulations

The Office of Management and Budget (OMB) Circulars A-87, Cost Principles for State, Local and Indian Tribal Governments, and A-122, Cost Principals for Non-Profit Organizations are applicable to SFA/LEA and Non-profit Charter Schools respectively.

If a district or education cooperative has questions, please contact the ADE, CNU Area Specialist assigned to the county, Suzanne Davidson, or Wanda Shockey at 501-324-9502.

Attachment A: USDA Policy Memo SP-10-2009
Attachment B: Proto-type Purchasing Cooperative Agreement/Contract
Attachment C: Purchasing Cooperative Agreement Additional Content


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