Our fiscal accounting department has a problem with utilizing the Bulk funding Concept in relation to a BPA. (13.101 (b)(4) BULK FUNDING) They state a PR MUST be obligated first before BPA orders can be placed by individuals authorized to purchase under the BPA.
Please state whether or not he following BPA office Standard Operating Procedure for ICE is acceptable under the umbrella of Fiscal Law.
1. A PR for $2,000.00 is received at the beginning of(each) the month for a ICE BPA. PR at this stage is not obligated.
2. Individual authorized to purchase under the BPA places numerous orders throughout the month up to the $2,000.00 PR monthly limit. (PR has not been obligated throughout the month however the funds are committed (form of a PR)
3. At the end of the (each) month, the Individual authorized to purchase under the BPA submits all documents to the contracting officer reflecting the numerous orders placed throughout the month. (example SF 1034).
4. Contracting officer at this point (end of the month) confirms all receipts / orders / etc and at that point obligates the committed funds PR by writing the call in PD2.
In short, all monthly orders are being placed on funds that have NOT been obligated, only committed in the form of a PR. Obligation occurs after all orders for the month have been "ordered" and completed and turned over to contracting officer.
Funds are committed once certified to be available with an approved purchase request document. The individual authorized by the contracting officer to place calls against the BPA properly obligates the government when placing the call. So, there is a proper commitment of funds followed by a proper obligation of funds. Transforming the electronic purchase request into an "electronic call" is an invention of PD2. The process of proper funds commitment and obligation does not change based on the administrative expediency of PD2.
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