One organization would like to use GPC to pay for multiple SF182s (multiple students) but the total amount would exceed to $100K. As AOPC, I advised them that it requires a contract due to the total amount. However, according to the customer, it does not violate the policy of splitting the purchase because one SF182 is for one student, which is under $25K. Meaning, one SF-182 per transaction. I consulted level 3 AOPCs but they agreed that one SF182 is considered one transaction, so it will not be considered split.
Please I need a clarification in this situation. Would this be split or not?
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Page 39,para. (k) of DODI 1400.25 tells us that the price of the training event (not for each individual person being trained) is the relevant threshold for determining the acquisition method. So according to that instruction, using the threshold "per student" would be splitting the requirement. The SF 182 is an administrative form to document training. It is not a purchase request in the usual sense.