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  • Question

    Does this requirement needs to go to the contracting office since the aggregated total exceeds to $2.5? Or they should be good because the contingency limit is 20K?


    Answer

    The short answer is this: you need to coordinate with your local contracting office to determine the local/regional/command policy for the purchase of internet services.  It's true the micro-purchase threshold is $20K for the acquisition of supplies or services that are in the support of a declared contingency if the contract is awarded and performed or purchase is to be made inside the United States.  FAR 13.301 permits the use of Governmentwide commercial purchase card to make micro-purchases.  I think the key in determining whether or not a contract must be awarded for the purchase of internet services even though it's below the micro-purchase threshold is determining whether or not the Services Contract labors Standards (SCLS) is applicable for the services in question.  If the SCLS is applicable, then associated SCLS clauses (which are intended to ensure employees are being paid a fair wage and fringe benefits in performance of the services (e.g. such as a janitorial service) under the contract) would need to be included in a contract   In accordance with FAR 22.1003-3 (d), the Service Contract Labor Standards statute does not apply to any contract for furnishing services by radio, telephone, or cable companies subject to the Communications Act of 1934.  What I found in my research is that internet services providers have been regulated by the Communication Act of 1934.  Therefore, a contract would not be required for purposes of implementing the requirements of the SCLS statute.  However, it really boils down to working with your cognizant contracting office because they should know the policy that must be followed for the purchase of internet services.

     

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