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Everything posted by GovtAcctGeek

  1. @Vern Edwards Time will tell, I suppose; circular logic/definitions aren't very useful, but specific exemptions and examples elsewhere in the FAR and USC Chapters referenced above helped a little! I'd appreciate your thoughts on how you would more specifically / usefully define a service employee besides the circular default of an employee on a service contract is a service employee / a service contract is one that uses service employees [to perform tasks, not deliver an item]. I'd also appreciate your thoughts on practicable ways to work through the time-consuming issue of
  2. The problem with the FAR's definitions are that they are circular. What's a service contract? One that uses service employees. What's a service employee? One that's in a service contract! That sort of circular logic is neither clear nor helpful. The most specific, the clearest, and most helpful definition is the negative one found in 37.101, which basically says "not a supply contract", and verbatim reads: a contract that directly engages the time and effort of a contractor whose primary purpose is to perform an identifiable task rather than to furnish an end item of supply.
  3. So it seems like my Bureau's current interpretation is probably accurate, and the suggestions to make a basic wood cutting contract $10k and put it on a card were incorrect. This is based on y'all's feedback here, the USC and DOL citations above, and also the definitions at FAR 22.1003-1 and FAR 37.101. Basically, any "blue collar" services is still subject to the $2,500 MPT, except for those services explicitly exempted in: 22.1003 22.1003-4 22.1003-4(b)-(d) 37.101 (1)-(9) (DISREGARD) (relevant Dept/Agency-specifics regs, if applicable)
  4. First, THANK YOU Neil, Joel, and Culham for the responses so far, this is useful. I definitely won't hold my breath on regulatory changes that are both intelligent and quick to occur. Second, sorry to seem dense, but I guess I am still wondering where the "blue collar" rule question has been answered? I agree that this is one possible solution, and I've floated it to my management with little response or proactivity on their part. Additional question: Would cardholders be able to place a BPA Call, paid with their Purchase card, without having to submit a PR or in
  5. Neil, I'm not sure I understand what you're asking with how the FAR became applicable to our state? 41 USC Ch 67 is referenced in FAR 2.101 in saying what Services are subject to the lower MPT. The FAR is what governs us in my Bureau's Acquisitions; we also have Dept-wide regs but they are quite sparse and don't mention MPT. So far as I know, 41 USC Ch 67 and the FAR are both government-wide regs that apply to almost all agencies/bureaus in almost all states (unless there is some exemption).
  6. Sorry, that doesn't really answer the first question - and it raises another one! Down the regulatory rabbit hole we go. Is my Bureau wrong about the "blue collar" rule, in which non-professional / non-creative services all still have just a $2,500 MPT? The second question raised: What would be the benefit of just making payment with Purchase card if most of the other time consuming stuff still is required? IE, if a $3k non-professional Service exceeds the MPT, I can't delegate that purchasing to a cardholder, it has to be handled by one of us in the Acquisitions shop. S
  7. I work at a small civilian Bureau, have to run the Purchase card program for our state, and I am aware the Micro-Purchase Threshold (MPT) was recently increased for some categories of requirements up to $10,000. However, on another forum post last year regarding an $11,000 tree removal requirement and using vendors not in SAM, another forum user suggested I negotiate down to the newer/higher $10,000 MPT, so it could be put on a Purchase card. At the time (FY-end madness) I thought that was odd, but didn't follow back up then. My Bureau's leadership insists that only some services h
  8. I have a question about synopsizing and competing regulations. I work at a civilian Bureau and everything here is about Services that are commercial items using SAP and under the SAT. I already reviewed the helpful forum topic Making Sense of FAR 5.202(a)(11), but that is about Construction, and the other two posts I found were more about large scale acquisitions and IDIQs / Orders. Last year we awarded a $150k contract with 4 line items, 1 base and 3 options, all exercised at time of award, to effectively do a lot of data management and digitization over the course of a year. Lin
  9. I have a standard level-of-frustration Warranted CO job, grade 9, at a civilian agency. I have an offer to go up to grade 11, but at a high level-of-frustration Contracting Specialist job at FEMA (not signing myself, just prepping under a Warranted CO). The work at FEMA sounds immensely more important and meaningful than where I currently am, but also much more stressful, and the commute would be substantially longer. My question for other beginners or more experienced CO's: how do you decide if a pay/grade increase is worth the added stress?? What are the major
  10. I am a recently Warranted CO at a civilian Bureau only working in the states (not overseas) that deals with a lot of very low dollar requirements between the Micro Purchase Threshold (MPT) and $15k. I also have to run the purchase card program, but that's an entirely different headache. I currently have an ~$11,000 tree removal project that does not count as unusual and compelling urgency. The only capable vendor, according to the requiring office, is not in SAM. My question is: for things under the $15k threshold, with no synopsizing or publicizing required, and with only o
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