Can the GPC be used to purchase cases of bottled water to support Hurricane/Tropical Storm Harvey relief operations?
This response is based on the information provided. Your question is open-ended and are subject to different interpretations. I’m assuming the purpose of purchasing bottled water via Government Purchase Card (GPC) is for the use/consumption of National Guard units assigned to support the declared domestic contingency efforts in response to the National Guard Bureau (NGB) Principal Assistance Responsible for Contracting (PARC) Policy Alert #17-015. I’m also assuming that NGB’s contracting authority derives from the Army (through DASA/P), meaning that NGB PARC utilizes the FAR, DFARS, AFAR, and its own local supplement (NGB Acquisition Manual) as its contracting policy and guidance.
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Generally speaking, you don’t normally use GPC to procure bottled water for personal consumption due to fiscal law issues associated with appropriated funding. Referring you to DPAP GPC website under FAQ link and GAO Principles of Federal Appropriations Law, Third Edition, Volume I (January 2004), most appropriated funds are not available to pay for subsistence (in this case Class I supplies like bottled water) to government employees for personal use at their official duty stations or vicinity as a general rule. There are exceptions, notably GAO Decision B-247871 (10 April 1992), when there is evidence that potable (drinkable) water in the facility occupied by federal employees is not for human consumption.
We also suggest you review the AFARS Appendix EE (Government Purchase Card Operating Procedures). There are specific rules when dealing with GPC authorization and its use within theater in support of contingency operation, to include specific guidance towards Reserve and National Guard units (see Appendix A: Best Practice). AFARS Appendix EE also provided guidance regarding prohibited purchases and restriction on GPC use (see Appendix C: Prohibited Purchases). Food or refreshment are indeed part of the list of prohibited transactions using GPC…note that there are certain exceptions to this rule as well.
We also suggest to review your local supplement (NGB Acquisition Manual) when dealing with GPC procedures concerning procurement of food and beverage. At the end of the day, if you are an authorized GPC cardholder, I highly recommend contacting your local authorities (contracting officer, legal, finance, requirements manager, A/OPC, and your chain-of-command) prior to purchasing any items using GPC.