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USDA Flexibility to Address Supply Chain Disruptions:

Child nutrition program operators are facing challenges in purchasing and receiving food through their normal channels. Specifically, some SFAs have experienced unanticipated cancellation of food and supply contracts, lack of availability of certain foods, the unexpected substitution of food products, and increased food and supply prices. As a result, schools have concerns about their ability to obtain the types, amounts, and variety of foods needed to serve reimbursable meals consistent with prior planning.


The methods of procurement authority under 2 CFR 200 provide SFAs with the flexibility to conduct emergency noncompetitive procurement(s) when an urgent need or emergency arises, such as replacing missing foods or paper goods with alternative sources or products quickly. Emergency noncompetitive procurement methods are a standing flexibility and do not require a waiver.

If an SFA experiences canceled or reduced orders, consider purchasing smaller quantities of the product(s) through one or more local producers or small businesses instead of purchasing products in a single, large transaction through a broad-line distributor. Leveraging local foods may help form new connections with small, local businesses and producers entering the school nutrition market, which can help create a more resilient food system.

Additional resources to address these challenges are available through the School Nutrition Association, the Institute of Child Nutrition, and No Kid Hungry

The Child Nutrition and Food Distribution Office (CNFD) is available to assist schools in completing waiver requests, identifying sources for food purchasing, and finding solutions to their unique struggles.  CNFD staff can be contacted at or call (888) 338-3663.


When procuring goods and services for the Child Nutrition Programs, a school food authority must determine whether they must use an informal or formal procurement method. It is important to understand and then identify which method best meets the needs of your individual school food service operation. Informal procurement occurs when a school food authority’s purchases fall at or below the Federal, State, or local small purchase threshold (whichever is more restrictive). The Informal Procurement method is commonly referred to as procurement under the small purchase threshold or simplified acquisitions. Although this method is permitted when the amount of a purchase falls at or below the most restrictive small purchase threshold, a school food authority could choose to use the formal procurement method (see below for more information) rather than the informal procurement method.

The following steps are typically involved in Informal Procurement:

  1. Develop specifications in writing;
  2. Identify sources eligible, able, and willing to provide products;
  3. Contact at least three sources;
  4. Evaluate bidders’ responses to your written specifications; and
  5. Determine the most responsive and responsible bidder at the lowest price.

Formal procurement occurs when a school food authority’s purchases exceed the Federal, State, or local small purchase threshold (whichever is more restrictive). Within Formal Procurement, there are two methods available: Competitive Sealed Bidding (commonly referred to as sealed bidding and uses an invitation for bid or IFB) and Competitive Negotiation (which uses a request for proposal or RFP).

The following steps are typically involved in Formal Procurement:

  1. Develop solicitation specifications;
    • Geographic preference points may be incorporated into scoring criteria for unprocessed local grown or raised agricultural products;
  2. Publicly announce the solicitation;
  3. Evaluate bidders using established scoring criteria in the solicitation;
  4. Providers of locally grown or raised unprocessed agricultural products receive extra points in scoring; and
  5. Determine the most responsive and responsible bidder at the lowest price

These procurement methods are designed to provide free and open competition and ensure that Federal funds—when used to purchase products or services—result in the best and most responsive product at the lowest possible price.

Farm 2 Child Nutrition:

Farm 2 School is a program to encourage K-12 schools to source the foodstuffs needed to feed their students from as local as possible.  Local foods usually are higher in nutrients because nutritional loss due to shipping is lessened. For the same reason, they may be of higher quality as well. Purchasing from local sources usually keeps the money circulating in the local economy.  Schools have also brought in local producers for nutrition education opportunities with the students to make a stronger connection between the food they eat and the land it was grown on.

School kitchens must use proper procurement practices for all food, but they can give extra points when awarding contracts for local food items. Please see the information above for information on ways to properly procure local foods.