You need a procurement plan. That’s not me talking, that’s Uncle Sam, the giver of our federal dollars.
The purpose of a procurement plan is to have a set of processes in place before you make purchases. This helps to ensure you abide by the many rules you have to follow.
The federal regulations don’t specify exactly what needs to be in the plan, just that it needs to be in compliance with federal, state, and local procurement standards.
Because there’s not a lot of guidance, state agencies each developed their own template you can use to get started. Therefore, I suggest you check with your state agency for their version.
These templates can vary drastically from state-to-state, but the concept is the same. They want you to write down what your district does to remain compliant with procurement. They give you a template, which they intend for you to modify, add to, and make your own.
The problem is that school nutrition directors normally fill in the blanks once, hit save, and never look at it again. We roll our eyes at Big Government for giving us busy work and never stop to think, “is there a better way to do this?”.
I vote yes, there is a better way to do this.
In this article, I’ll share 5 tips for updating your state’s template so that it is actually useful to you.
Tip #1: Customize, customize, customize.
You’re much more likely to use the plan if it’s a reflection of what you actually do. Most states never intended for you to stick only to the language in their template. They encourage you to make it your own!
One way to do that is by filling it out with a different mindset. When you’re starting from a state template, instead of going into it thinking “where do I need to fill in blanks?”, go into it thinking “what do I do differently from or in addition to what’s written?” These are prime places to customize the plan.
For example, a lot of state templates mention advertising your IFB or RFP, but several don’t really define how you’ll distribute the solicitation document. If you are advertising on an IPS website that also posts the documents as attachments, you might not need another step in your plan. But if you are also emailing the documents directly to vendors, you might say, “hey, we do things in addition to what the template has.” You could then add a statement such as:
The district will maintain a list of potential vendors by bid category and will send solicitation documents electronically to all known vendors within a bid category.
Another example where you would customize the plan would be if you have more restrictive local requirements than the state. For example, the state’s template might say:
Quotes will be obtained from an adequate number of sources (at least two).
However, if your district requires you to obtain three quotes, when you read that sentence you should say, “hey, we are doing something differently from what the template says.” You would need to update it to say:
Quotes will be obtained from an adequate number of sources (at least three).
Essentially, if your plan is customized to your own district’s practices, you and your staff will find it much more useful than if it were just full of generic language.
Tip #2: Treat it like a contingency plan.
Even if you’re the most knowledgeable procurement expert out there, you need to plan for what happens if you get hit by a bus win the lottery and are never seen again. The procurement plan is a great way to ensure that if you ever needed time off, you have an instruction manual or road map someone could use to figure out what to do in your absence.
This often requires you to go in a little more detail than what’s in the template, but it’s worth it if it helps in the long run. An example is instead of stating…
Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms will be maximized by following the procedures outlined in 2 CFR 200.321.
…actually list out the steps you take:
Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms will be maximized by following the procedures outlined in 2 CFR 200.321, including:
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- Prior to sending out solicitation documents, the School Nutrition Director will conduct a search of the state’s directory found at https://tn.diversitysoftware.com/FrontEnd/SearchCertifiedDirectory.asp?XID=5672&TN=tn
(Guys, that’s my state’s directory, so don’t copy that link unless you’re in Tennessee. But you knew that, because you’re paying attention to my whole “customize, customize, customize” plea.)
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- Businesses found in the directory that could potentially respond to the solicitation will be added to the District’s solicitation list.
Etc.
See how providing more detail makes it much easier for an outsider to know exactly what to do if you were gone? By providing those extra instructions, you make the document much more usable.
Tip #3 Use your procurement plan as a training document.
As you’re reading through the document, identify the areas that any of your staff play a role in maintaining compliance and think through how you could use the plan in training.
If your code of conduct is included in your procurement plan, all your staff would need to be trained on that part, since they can’t accept gifts from vendors.
Otherwise, it might be an office assistant that does micro purchases, a bookkeeper that maintains documentation, or a dietitian that writes food specs.
As you identify these areas that they are involved in, be sure to write the plan in language that is relevant to them and their job. Then, use the procurement plan to do training later when you’re searching for relevant professional standards topics! (I’d use code 2430 by the way).
For example, instead of just stating…
Micro-purchases should be distributed equitably among qualified suppliers.
…you could update it with some examples to clarify what that means:
Micro-purchases should be distributed equitably among qualified suppliers. For example, office supply purchases will be rotated between both local office supply stores and different repair services will be used for equipment repairs.
Another example, instead of stating:
Each solicitation document will include specifications and estimated quantities of products and services prepared by the District and provided to potential contractors desiring to submit bids/proposals for the products or services requested.
You could make it more relevant to a dietitian who writes specs by stating:
Each solicitation document will include specifications and estimated quantities of products and services prepared by the District and provided to potential contractors desiring to submit bids/proposals for the products or services requested. Specifications will:
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- Describe the minimum quality standards of a product or service
- Not be written to restrict competition
- Include “or equal” or “or pre-approved equal” anytime a brand name is used
Etc.
Including more details or examples will make it a stronger training document when other people read it.
Tip #4: Share the document with your purchasing office.
I don’t know about you, but our purchasing office doesn’t know the ins and outs of school nutrition procurement.
By all means, I don’t blame them. We are under federal regulations that they don’t have to abide by.
This can make it difficult when they want you to do something you aren’t able to. However, if you have a plan in place and share it with them upfront and regularly, it’s easier to refer back to it when needed.
For example, imagine your procurement director tells you they want you to start using their bid template instead of what you’ve been using. You can politely share your plan with them again pointing to the part that has all the required federal clauses.
This can be a good tool to help your purchasing office understand why you can’t do everything they do. Additionally, writing it with them in mind as a reader will help you craft a more relevant plan.
Hot tip: if it seems like someone is always asking you to do something procurement related you know you can’t do, but it’s not currently in your plan, add it!
For example, other district programs might have contracts that are cost plus percentage of cost, which are prohibited for us federally funded folks.
If someone keeps bugging you about using a contract you know is cost plus percentage, add a statement about how cost plus percentage contracts are prohibited for school nutrition into your procurement plan with the reference of the federal reg. In this case, it would be 2 CFR 200.324(d). Then, anytime they bug you about it, refer them back to your plan. They might still not care, but at least they can see you’re not making this stuff up.
Tip #5: Double-check your plan before completing a procurement.
Using your plan to double-check your procedures will help ensure you do the procurement correctly, but it can also help you craft it so it is more useful. If you are always using it, you’ll be motivated to make it useful. For example, let’s say you have to run a newspaper ad for 2 weeks before bid opening. Your procurement plan might currently say:
An advertisement of an IFB or RFP will be placed in the ABC Times to publicize the intent of the SFA to purchase needed items. The advertisement will be run for 2 weeks.
But let’s say you always forget that the newspaper people require a 5-business day lead time before publishing. This has pushed your timeline back before. You could add the info into your procurement plan so you have a place to reference it later! For example:
An advertisement of an IFB or RFP will be placed in the ABC Times to publicize the intent of the SFA to purchase needed items. The advertisement will be run for 2 weeks. The School Nutrition Director will contact the newspaper at least 5 days in advance.
Now the next time you go to do a bid and you are looking over your plan, you’ll be reminded that you need to contact the newspaper at least 5 days in advance.
Summary
If you’re just looking to check an item off your to-do list, then go ahead and let your cookie-cutter procurement plan sit collecting metaphorical dust in your computer files.
However, if you’re wanting to use the procurement plan as a tool to make procurement a little easier down the line, then these tips will help do that. Does the state require you have all this very specific information in your plan? No. But it’s YOUR plan, so make it useful to YOU.
