1. Is this a financial commitment without prior authorization, since the training was scheduled and initiated prior to any funding documents being processed?
2. Does an approved SF-182 authorize, the training, or the purchase of training, or both?
- - My understanding of the GPC/Maximo process is:
- - - - Requestor initiates request (per qoute, email, or approved SF-182)
- - - - PR is generated, then signed by the requestor.
- - - - PR is routed to the AO for their "approval" to make the purchase with a PO. Without this approval, there cannot be an "authorized" purchase. The SF-182 approver is not an AO for the GPC.
- - - - Once PR is approved, the PO is generated/approved by the buyer.
- - - - The buyer contacts the training vendor to confirm that the training is authorized, and comfirms the attendees, and the dates. Payment can be made either prior to, or after, the training is conducted.
- - - - Once completed, the PO for training is received in Maximo.
I feel like the procurement of training services is the same as any other purchase. If I were to bring a contractor out for repair services, without an approved PO, I would be guilty of not having prior authorization. I can't remember if it was the FAR, or NAVSUPINST, it was in, but I read that an approved SF-182 only authorizes the buyer to exceed the micro-purchase limit of $3000, and allows for training purchases up to $25000.
Thank you for your time.
As stated on the SF 182 itself, its primary purpose is “to document the nomination of trainees and the completion of training.” It is a requisition document rather than an order for services. I am surprised that the training vendor started the training without either a purchase card transaction or a purchase order. Being that the Government did not make a valid order to purchase from the vendor, an unauthorized commitment may have been created.
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You need to consult with your organization’s legal counsel in such cases.