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  • Question

    Can a $25,000 GPC card be issued for small supply and service requests and if so where can I find the neccessary requirements, training and risks associated with issuing this type of card? Does the $25,000 card have to have a designated ordering officer?


    Answer

    It sounds as if you are dealing firsthand with the challenge of doing more with less! According to the regulations, FAR and DFARS, the GPCC is to be used to the maximum extent practicable and the GPCC is the preferred method to purchase and pay for micro-purchases. According to FAR 2.101, the micro-purchase threshold is currently $3,000 under normal conditions, but does increase to $15,000 (inside the U.S.) and $30,000 (outside the U.S.) in support of contingency operations or to facilitate defense against or recovery from nuclear, biological, chemical or radiological attack.  In addition, DFARS allows “an individual appointed in accordance with 201.603-3(a) to use the Government wide commercial purchase card to make a purchase that exceeds the micro-purchase threshold but does not exceed $25,000,” if certain VERY specific conditions are met. See DFARS 213.301(2) for the information about those conditions. Unfortunately, with the likelihood that most, if not all, of the purchases you are referring to are routine and are not in support of any contingency operation, do not to facilitate defense against an attack, and do not fulfill the conditions described at DFARS 213.301(2), it means you will not be authorized to simply use the GPCC for normal higher dollar purchases.  

    However, please also note that
    FAR 13.301 tells us that “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.” This section of the regulations sends you to FAR 32.1110 and FAR 32.1108. Upon consulting FAR part 32, we learn that “when it is contemplated that the Governmentwide commercial purchase card will be used as the method of payment, and the contract or order is above the micro-purchase threshold, contracting officers are required to verify (by looking in the System for Award Management (SAM)) whether the contractor has any delinquent debt subject to collection under the Treasury Offset Program (TOP) at contract award and order placement.”

    DAU Continuous Learning Module CLG 001, DOD Government Purchase Card is a good resource for any additional questions you might have.



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