Get Full Government Meeting Transcripts, Videos, & Alerts Forever!
Get email alerts on the Usda Foods topic
No spam. Unsubscribe anytime.
State outlines USDA Foods options: rebates allowed, net‑off‑invoice pending; procurement guidance for districts
Summary
Tennessee procurement staff described allowable vendor pass‑through rebates for commodity processors as an alternative to net‑off‑invoice, explained procurement language and reporting expectations, and recommended coordination with the Department of Agriculture for allocation and tracking.
Elizabeth Frankel Hewson, procurement specialist at the Tennessee Department of Education, told the April update call that USDA guidance allows rebates as an allowable vendor pass‑through method in Tennessee and that rebates can be used as a practical workaround while the state pursues net‑off‑invoice (NOI) options.
Frankel Hewson said rebates allow an SFA to allocate entitlement pounds to processors, include specific line items in a commercial distributor solicitation, purchase the end products through a commercial distributor and then submit a rebate to the processor. She warned that the rebate method requires precise solicitation language identifying line items, processors and quantities and that processed beef products cannot use the rebate method because of additional testing and processor requirements.
The procurement specialist recommended that districts include monthly velocity reports from awarded distributors to track processed commodity usage. She said districts may use small purchases or formal contracts for USDA Foods procurements but must include USDA Foods clauses and recall procedures, and that small purchases carry more risk if they lack full solicitation language. “If it's something that's eligible to be stored in state contracted warehouse that's fine,” she said in response to a question about storage.
Frankel Hewson advised SFAs to coordinate allocations with Grant Puls and Jean Trimble at the Tennessee Department of Agriculture and to submit commodity processing worksheets by published due dates. She said the drawdown of entitlement pounds occurs after a rebate is submitted and received from the processor and that tracking can be done with WBSCM, K‑12 Food Service or ProcessorLink.
She also said NOAA (net‑off‑invoice) would be another possible future option but would not remove the availability of fee‑for‑service or rebates; districts would be able to choose the method that fits their capacity. Frankel Hewson recommended districts consider forecasting and storage capacity when choosing between NOI and fee‑for‑service.
The department said it will provide additional written guidance and will support SFAs that need help drafting solicitation language and tracking commodity rebates.
