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  1. I'm a contracting officer currently working overseas in support of a declared contingency for the Department of Defense. We're having a spirited discussion in our office on synopsizing requirements. The most hotly debated topic is the requirement to synopsize through the GPE for requirements >$30k (micro-purchase threshold) when soliciting competition in the United States. FAR 13.106-1( c ) states that oral solicitations can be used when notice is not required under FAR 5.101 and the acquisition does not exceed the SAT ($1M for overseas declared contingency). But FAR 13.106-1( c ) also cautions that oral solicitations may not be practicable unless an exception under FAR 5.202 applies. An exception under FAR 5.202 does apply, but it's FAR 5.202( f ), which states synopsizing is not required when the proposed contract action is by the DoD, and only local sources will be solicited. This is the only exception that applies, and a U.S. based company cannot reasonably be considered a local source. FAR 5.101( a )( 1 ) states that synopsizing is required for actions expected to exceed $25k. FAR 5.101( a )( 2 ) outlines public display requirements for actions between $15k and $25k, but excepts display requirements for actions solicited using oral solicitations (FAR 5.101( a )( 2 )( ii )). The premise of the argument I'm hearing is that FAR 5.101( a )( 2 )( ii ) allows us to solicit companies in the U.S., provided the action is under the SAT, without the need to synopsize. I wholly disagree with this argument due to the fact that our synopsizing requirement falls under FAR 5.101( a )( 1 ) and not FAR 5.101( a )( 2 ). Therefore, any requirement greater than our micro-purchase threshold of $30k where non-local sources are being solicited must be synopsized to the GPE. On a similar note, we also had a spirited discussion on the applicable micro-purchase threshold in our environment. At one point, an argument was being made that the applicable micro-purchase depended on whether or not the acquisition was being awarded to a company inside or outside the U.S. ($20k inside the U.S. and $30k outside the U.S.). However, we all now generally agree that the applicable threshold is $30k, regardless of where the company is located because the purchase is "being made outside of the United States". Thoughts on the synopsizing requirements and feedback on the applicable micro-purchase threshold?
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