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  • Question

    I can't find a FAR site that says the duration of a purchase order other than, "it can be driven by funding". Thank you for your help!


    Answer

    Why not have a BPA or even a BOA that allows for payment through the GPC?  Each visit to the firing range should not be more than $3,000 if agents are just using a local firing range for practice and certification tests.  The overall price may be significant, but not each individual visit.  FAR regulations allow the BPA to be used.  And, even though it is not a consistent task, a BPA can be a simple one that just has the simple terms and conditions that are in every past purchase order.  The inconsistencies - more or less agents using the firing range and for less or more time - can be priced in individual increments (e.g. 1 agent/hour practicing = $120/hour; 1/2 day certification exams of all agents = $500 per period.)  Even if the costs are more than $3,000, a GPC can still be used, just not the firing agents GPC, in those cases only a CO's GPC can be used but in all other's, the CO can stay out of it unless the BPA needs renegotiated. 
     
    GPCs can be used both as purchasing vehicles but also as payment vehicles. If the agents have GPC's, even they can be approved to swipe their card each time payment is necessary.  This is not considered splitting requirements. 
     
    FAR 13.003(e) encourages maximized use of GPC, however, if this is used, a BPA must be written to so that the GPC is not used as a procurement method and only used as a payment method. FAR 13.301  states "(a) The Governmentwide commercial purchase card is authorized for use in making and/or paying for purchases of supplies, services, or construction. The Governmentwide commercial purchase card may be used by contracting officers and other individuals designated in accordance with 1.603-3. The card may be used only for purchases that are otherwise authorized by law or regulation.
     
    (b) Agencies using the Governmentwide commercial purchase card shall establish procedures for use and control of the card that comply with the Treasury Financial Manual for Guidance of Departments and Agencies (TFM 4-4500) and that are consistent with the terms and conditions of the current GSA credit card contract. Agency procedures should not limit the use of the Governmentwide commercial purchase card to micro-purchases. Agency procedures should encourage use of the card in greater dollar amounts by contracting officers to place orders and to pay for purchases against contracts established under Part 8 procedures, when authorized; and to place orders and/or make payment under other contractual instruments, when agreed to by the contractor. See 32.1110(d) for instructions for use of the
    appropriate clause when payment under a written contract will be made through use of the card.
    (c) The Governmentwide commercial purchase card may be used to-
    (1) Make micro-purchases;
    (2) Place a task or delivery order (if authorized in the basic contract, basic ordering agreement, or blanket purchase agreement); or
    (3) Make payments, when the contractor agrees to accept payment by the card."
     
    In short, there may be inconsistencies which make funding difficult to place onto a typical contracting instrument.  So, they should just do a very simplistic (1 to 5 pager) BPA and pay using GPC's. 

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