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Procurement Reviews

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The USDA procurement review is a critical component of ensuring the responsible and efficient use of federal funds in Child Nutrition Programs while also promoting fair and transparent procurement practices. Procurement reviews are conducted on a three-year schedule. These reviews aim to verify that sponsors are using full and open competition in purchasing goods and services and that nonprofit food service account funds are used properly. Procurement reviews are a key part of ensuring the overall integrity and effectiveness of Child Nutrition Programs. The VDOE-SCNP conducts these reviews in-house.

Use the VDOE-SCNP Procurement Review Documentation Checklist to help ensure you have the documentation that will be asked for during procurement reviews.

Procurement Review Process 

  1. SCNP notifies sponsors and requests submission of initial documentation 
  2. SCNP reviews the initial documentation 
  3. SCNP requests any additional documentation 
  4. SCNP reviews additional documentation 
  5. SCNP provide a summary of findings, request corrective action plan(s), and close the procurement review 

Throughout the review process, VDOE-SCNP provide technical assistance to support sponsors. The SCNP reviewer schedules calls to discuss documentation requirements and to understand the sponsor’s procurement processes and procedures. 

Initial Documentation Requirements

Procurement Plan
A written procurement plan is a required document that explains how to buy goods and services using federal funds while following all rules and ensuring fair and competitive practices. Go to the Procurement Plan, Profile, & Code of Conduct section for our template.
Procurement Code of Conduct

Under 2 CFR 200.318(c)(1), sponsors must have written rules that explain how staff should avoid conflicts of interest when choosing, awarding, and managing contracts.

Go to the Procurement Plan, Profile, & Code of Conduct section for our template.
Vendor Paid List

This list includes all vendors whose goods, supplies, or services were purchased using nonprofit school food service funds, including the dates, amounts, and descriptions of items purchased.

Procurement Review Table
The Procurement Review Table Tool is an optional tool that sponsors may use during a procurement review. Please type the vendor’s name and information under the type of procurement procedure the sponsor followed (for example, micro-purchase, small, or formal purchase procedures). 

Corrective Action 

Sponsors may receive a finding during procurement reviews that requires a corrective action plan (CAP). CAPs are a tool to support sponsors in creating a plan to be compliant with procurement regulations. CAPs must include the following information: 

  • Why the identified issue was occurring 
  • How the issue can be corrected 
  • When the correction will be implemented 
  • Who is responsible for ensuring compliance 

Common Procurement Review Findings

  • General procurement procedures: 
    • Documented procurement procedures are not compliant with federal, state, or local procurement standards 
  • Small purchases: 
    • Insufficient records to detail the history of procurement 
    • Specifications are not used or not clearly defined 
    • Insufficient number of quotes (less than two) 
  • Formal purchases: 
    • Incomplete cost/price analysis 
    • Incorrectly advertised solicitations (limited number of platforms) 
    • Solicitations are missing at least one contract provision 
    • Price not being the primary evaluation factor

Review the full list of common findings and best practices to avoid them.