My issue or question is, is there a difference between a payment method and a procurement method with the GPC. In my mind if the GPC is used with a FSS it should only be used as a method of payment not a method of procurement. If I understand correctly there needs to be an order placed against an existing vehicle and a record through FPDS-NG also needs to be done. That can not happen if the GPC is used as a method of procurement.
Another issue is a possible double obligation from using one over the other with GFEBS.
Is our office getting ourselves into trouble by allowing the GPC as a method of procurement instead of a method of payment.
This is a GREAT question, thank you. We suspect there are other organizations who may be confused by this and the CAR (contract action report) requirements under your scenario.
I'll start by saying YES, there is definitely a difference between using the GPC as the purchase method and when you are using the GPC as the payment method; but there is a nuance. That nuance is that the GPC can be used to place an order against an existing contract or agreement (reference provided below).
The only time in DoD when someone is authorized to use the GPC as a "purchase method" above the micro-purchase threshold (MPT) is when the conditions at [DFARS 213.270 - specifically see the criteria listed at 213.270(c) and 213.301(2)]. So in your scenario you are only using the GPC as the order placement and payment method see FAR 13.301(c)(2) and (3). When placing orders using the GPC, the theory is that all provisions and clauses in the basic contract or agreement apply to the individual order/call order, etc. If that is not the case, an SF 1449 or DD 1155 should be used to place the order (unless another written format is in place). Note: the FAR and DFARS are silent on how placing orders are to be documented; that is up to individual agencies and procurement organizations. There is some guidance in the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs.
You are also correct in assuming that a CAR is most definitely required for these actions; see FAR 4.606(a)(1). But you may be able to utilize the "express reporting" procedures found at DFARS PGI 204.606(1)(iii)(A)(3) in order to decrease the administrative burden..