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    1. Can the GPC be used to pay for repair of equipment that includes travel cost? 2. If repair is to be provided by the manufacturer/seller of the equipment i.e. x-ray machine for cargo, does this fall under exception to the Service Contract Labor Standards; cost of Labor exceeds $2.5, travel at $3K. Total amount $5K+


    Answer

    Applicable references for question 1: See the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (referred to as the Guidebook from here-on-out) (https://www.acq.osd.mil/dpap/pdi/pc/policy_documents.html),  Appendix I Definitions and Abbreviations:

    Micro-Purchase Threshold means $10,000 (10 U.S.C. 2338), except it means—

    (1) For acquisitions of construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction), $2,000;

    (2) For acquisitions of services subject to 41 U.S.C. chapter 67, Service

    Contract Labor Standards, $2,500; and

    Applicable references for question 2: Your situation appears to fit the Secretary of Labor exemption at FAR 22.1003-4 (d)(1)(iv) which states, "Maintenance, calibration, repair, and/or installation (where the installation is not subject to the Construction Wage Rate Requirements statute, as provided in 29 CFR 4.116(c)(2)) services for all types of equipment where the services are obtained from the manufacturer or supplier of the equipment under a contract awarded on a sole source basis."  Also, you should review FAR 22.1003-4(d)(2) to ensure your requirement meets the conditions listed there.

    Bottom line: Based on your background information, I think the $10,000 MPT probably applies to your repair service; that's assuming it meets the exemption at FAR 22.1003-4 (d)(1)(iv), which would mean your purchase would not be subject to 41 U.S.C. chapter 67.  I didn't find guidance that specifically spells out whether paying for travel associated with the repair is allowable and how to handle such travel.  However, travel (that's incidental to performing a service) was not listed in Section A.1.2.4 PROHIBITED PURCHASES of the Guidebook.  Take caution though because it's not an all-inclusive list, and I strongly recommend paying heed to the guidance provided in Section A.1.2.4 of the Guidebook which reads: "CHs should contact local authorities (e.g., the A/OPC, local Judge Advocate General, and Financial/Resource Manager) prior to purchasing any items that seem questionable or may have the appearance of being inappropriate. All exceptions must be on a per-transaction basis after consultation with legal counsel, the HCA, and the Financial Manager."  So, please talk to these folks before making the purchase.  I do not know where, how long or any other details about the travel, but the cost sounds a little high so check to make ensure the travel amount is fair and reasonable.  If you find out after contacting your local authorities, you are not permitted to make the purchase on GPC, I would seek guidance from your local contracting office on other possible alternatives.  

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