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    Can the GPC be used if total exceeds $2.5K threshold subject to SCA? What is the reference for exemption as FAR 22.1003-4 (d)(1) applies only to contracts.


    1) Please ask your Agency Program Coordinator if your organization's Internal Operating Procedures (IOP) allows you to treat the labor element ONLY as Service Contract Labor Standards (SCLS) covered; while the supplies required for repair are not SCA covered. Only a portion of your requirement appears covered by the SCLS. It is common to encounter GCPC buys with separate line item for parts and labor. The Navy GCPC instruction NAVSUPINST 4200.99C is silent to how to handle a purchase including both supplies and services.

    2) Reference: FAR 22.1003-7 Questions concerning applicability of the Service Contract Labor Standards statute. If the contracting officer questions the applicability of the Service Contract Labor Standards statute to an acquisition, the contracting officer shall request the advice of the agency labor advisor. Unresolved questions shall be submitted in a timely manner to the Administrator, Wage and Hour Division, for determination.

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