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  • Question

    1. For OCONUS GPC cardholders for OCONUS missions with OCONUS vendors, are services permitted, either recurring or a one-time service, above the Micro-Purchase Threshold up to $25,000? Is this limited to "per annum"? 2. For GPC specifically, is the Service Contract Approval form required for services OCONUS if it is permitted to use the OCONUS GPC above the MPT? If so, what other requirements may apply?


    Answer

    This response is based on the information provided.  We suggest you discuss with your contracting team, program manager and/or legal department as appropriate. 

     

    While FAR 13.301 discusses the Governmentwide Commercial Purchase Card (GCPC) in general, and the FAR and DFARS discuss dollar thresholds; GCPC program requirements and policies are established at the Agency level per FAR 13.301(b) (See DPAP website for Agency specific GCPC policies, guides, and handbooks).  Subsequently, your Agency's rules and policies may change the answers provided here and therefore would be the best source for a definitive answer to your particular situation.

     

    The answer to question 1:  See DFARS 213.301; "An individual appointed in accordance with DFARS 201.603-3(a) also may use the [card] to make a purchase that exceeds the micro-purchase threshold but does not exceed $25,000, if [the purchase meets the conditions that follow under DFARS 213.301(2)(i), and the individual meets the conditions found under DFARS 213.301(2)(ii)]."  Additionally, contracting officers supporting contingency operations (or other unique situations listed under DFARS 213.301(3)) may even exceed the $25,000 threshold.  The 'per-annum' aspect would be covered in Agency GCPC policy/procedures.

     

    The answer to question 2:  By "Service Contract Approval form", we are assuming you are referring to an RSCA (Request for Service Contract Approval) as mentioned in the Army FAR Supplement at AFARS 5107.503.  Neither the FAR nor DFARS go into specifics on the purpose and process of same, but rather leave it to the Agencies to comply with the general requirement found at FAR 7.503(e) with regard to requiring activities' certification on inherently governmental functions.  Please confer with your Agency's GCPC POCs for the answer to this question with regards to GCPC procedures.

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