If a cardholder visits the BSC prior to awarding a PO because they are not certain of all the items they will be purchasing, and makes a purchase but fails to create a PR and award a PO on the same day as the purchase, is this considered an unauthorized commitment (e.g., the purchase is made on 6/28/2021 and the PO is awarded on 6/29/2021)? The date on the invoice would be 6/28/2021 and the award date on the PO would be 6/29/2021. If this is considered an unauthorized commitment, what is the applicable FAR reference? If this is NOT considered an unauthorized commitment, what is the applicable FAR reference? (Our financial system of record is ERP.
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Per FAR 1.602-3 Ratification of unauthorized commitments.
Unauthorized commitment, as used in this subsection, means an agreement that is not binding solely because the Government representative who made it lacked the authority to enter into that agreement on behalf of the Government.
Based on the definition, this scenarion would not create an unauthorized commitment because the cardholder should have the authority to purchase and make the payment. This would be true as long as they are not exceeding any authority on what items from the BCS they are allowed to purchase (if any restrictions) or dollar limitations they may have.
Contact with the question submitter revealed the purchase card program coordinator will develop a verification process to be used within their ERP payment system.