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    Questions: Is competition required when using the $25K Commercial off-the shelf training card for purchase above the $2,500 service micro-threshold. If only one source, what documents are required? Does this school only offered for SES meet the definition for commercial off the shelf for the use of the GPC $25K card?


    Answer

    The office of Personnel Management’s opinion on the SF-182 is expressed in their answer to a Frequently Asked Question (FAQ) here: https://www.opm.gov/faq/training/What-is-the-spending-limit-for-the-SF-182.ashx.  OPM answers as follows: “The intent of the SF-182 is to approve and record completion of employee training—not for use as a procurement document.   However, agencies that choose to use the SF-182 to procure training should consult with the agency contracting office for agency specific policies on the use of SF182 as a training procurement option.”


    The possibility of the SF-182 being the “other contractual instrument” referred to in
    FAR 13.301(b) would allow for the proper use of the Governmentwide commercial purchase card (GCPC) supported by regulation as follows:
    The current micro-purchase threshold, normally $3,500, is found at FAR 2.101. The procedures at FAR part 13 are to be used for purchases up to the simplified acquisition threshold, normally $150,000 (FAR 2.101). FAR 13.104 requires contracting officers to promote competition to the maximum extent practicable to obtain supplies and services from the source whose offer is the most advantageous to the Government, considering the administrative cost of the purchase. FAR 13.105 provides sets out the solicitation and publicizing requirements in accordance with FAR part 5 – Publicizing Contracting Actions.  FAR 5.101(a)(1) requires synopsis of all purchases over $25,000. 

    FAR 13.301(b) encourages use of the (GCPC) in dollar amounts greater than the micro-purchase threshold 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. Given an existing contract and a contractor who does not object to payment by the GCPC, there is no prohibition against using the GCPC. 

    As seen by the citations above, it is critical that some “other contractual instrument,” be in place because a “GPC $25K card” is not supported by regulation.  A common point of confusion stems from
    DFARS 213.301(2) which allows authorized users to use the card for purchases above the micro-purchase threshold but less than $25,000 under very specific circumstances.  The first specific circumstance is at DFARS 213.301(2)(i)(A), for purchases outside the United States for use outside the United States.  FAR 12.102(e)(4) highlights the procedures and policies of FAR part 12 shall not apply to the acquisition of commercial items using the GCPC as a method of purchase rather than only as a method of payment. 


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