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    The question I have, since the micropurchase threshold is listed as $2000 for construction and $2500 for services, can contracts be written without higher approval between the threshold and $3000 or are any contracts below $3000 not allowed at all and must use the GPC for payment? So for example, if you have a construction project at $2800, can you use the GPC (without competing) or does it need to be competed (davis bacon act) and put on a contract?


    Answer

    The following answer is based solely on the background information provided as we do not have all the facts pertaining to your contract.  As we do not have access to the contract folder or program particulars that apply to this situation, we highly recommend you consult the Contracting Officer as well as the Legal Office.
     
    Since there are several questions compiled into one large question, I will respond to each one separately.
    Can contracts be written without higher approval between the threshold and $3000 or are any contracts below $3000 not allowed at all and must use the GPC for payment? 
     
    FAR 13.201 states that the governmentwide commercial purchase card shall be the preferred method to purchase and pay for micro-purchases.  FAR 13.301 further states that the governmentwide commercial purchase card is authorized for use in making and/or paying for purchases of supplies, services, or construction. It also states that agency procedures should not limit the use of the Governmentwide commercial purchase card to micro-purchases. Agency procedures should encourage use of the card in greater dollar amounts by contracting officers to place orders and to pay for purchases against contracts established under part 8 procedures, when authorized.
     
    So for example, if you have a construction project at $2800, can you use the GPC (without competing) or does it need to be competed (davis bacon act) and put on a contract?
     
    Since your particular project is $2,800, it would be subject to FAR 22.403-1 which clearly states that contracts in excess of $2,000 for construction must comply with the statutory requirements of the Davis-Bacon Act, and the contract shall contain a clause (FAR 52.222-6) that no laborer or mechanic employed directly upon the site of the work shall receive less than the prevailing wage rates.  This infers that that the GPC cannot be used as a contract vehicle to purchase your project. The project falls in the category for use of the  simplified acquisition procedures (> the micro-purchase threshold and ≤ simplified acquisition threshold) found in FAR Part 13, which allows the incorporation of the clause.  Although micro-purchases may be awarded without competition, your project per FAR 13.304 would require the promoting of competition to the maximum extent practicable.

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