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  • Question

    Can the blood centers use their cards for this type of purchase (is it legal) and is using the card the right procurement tool (GPC or 1449)? Assuming yearly purchases are less then micro-purchase limit. What if purchase are random, only order when supplies are low, purchases to do not exceed micro-purchase limit, but annually may exceed micro-purchase limit?


    Answer

    I’m seeing two issues here after looking at the DoD Government Charge Card Book Effective date 1 Oct 2017.  The first issue is buying refreshments.  The guide book states, “Written coordination with local legal counsel and the Financial/Resource Manager is required prior to purchase of any such refreshments.” Assuming you have already done this the next issue could fall under what the guide book refers to as split purchases. “Split Purchases. Making split purchases with the GPC to circumvent purchase limits is prohibited by FAR Subpart 13.003(c)(2). A split purchase occurs when a CH splits a known requirement at the time of the purchase into several transactions in order to circumvent their authorized dollar thresholds in order to use the GPC; or to avoid sending the requirement to contracting for appropriate contract award. When a known requirement exceeds the micro-purchase threshold, it must be procured on a government contract. The following are examples of split purchases:

    A CH holding known requirements exceeding the micro-purchase threshold to purchase the items from the same or multiple merchants over a period of time when the total requirement was known at time of the first purchase and the value exceeds the CH’s single purchase limit.”

    I would say it is for this reason you are being told you need a contract.

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