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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 oral quotations, and with an attempt to innovate, keep documentation minimal, and be maximally efficient (IAW FAR 13), is there any way to use a non-SAM-registered vendor? I am trying to figure out if there is a way to use purchase card, too, because logically, we are given these tools (Warrants, training, purchase cards, FAR 13, etc) for exactly this reason: to not spend hours and hours on low risk, low dollar, low priority awards. Could one simply have a vendor manually fill out 52.212-3 to get their representations in writing? 52.204-7 System for Award Management, as prescribed at 4.1105(a)(1), must go in "all solicitations" - and it looks like the only real exception an exception under 4.1102(a)(5): Somewhat tangential: these MPT - $15k projects can be very frustrating and time consuming, particularly because the administrative costs are so high relative to other work we have to do, and requiring offices insisting we use "their" "local" vendor who they often talk with for weeks before we get a PR. Being able to streamline and simplify the 100+ requirements like this that we deal with each year would save us hundreds of hours of work.
I am a new member posting for hte first tiime; I hope i have filed this under the correct forum. I am a CO. In my agency the purchase card program is managed by financial operations and not the acquisition office. The brief email i posted below was from our purchase card manager, who infomed a staff member that the following scenario violated the micropurchase threshold rules for purchase card. One person in an offsite office has an ez pass account to pay the toll charges for the staff in that office. Each individual toll is for a few dollars, but the office annual aggregate cost was over $3k. Therfore the purchase card manager stated the purchase card can not be used for this type of transaction. I am not sure i agree. Any comments and advice would be greatly appreciated. Thank you in advance. Jim S ______________ Dear (name redacted): During a review of purchase card transactions, we noticed a large amount of toll charges on your card in FY-12. Total there was $7,340.00 in toll charges for FY-12. During this review, we took a look at FY-13 transactions to see where we stood on toll charges and noticed that thus far you have $3,840.00 in toll charges for FY-13 (see detailed information below). Merchant Category Code Merchant Category Code Description Merchant Name Transaction Date Transaction Amount 4784 TOLLS AND BRIDGE FEES EZPASS PREPAID TOLL 2012/10/07 $960.00 4784 TOLLS AND BRIDGE FEES EZPASS PREPAID TOLL 2012/11/04 $960.00 4784 TOLLS AND BRIDGE FEES EZPASS PREPAID TOLL 2012/12/05 $960.00 4784 TOLLS AND BRIDGE FEES EZPASS PREPAID TOLL 2013/01/06 $960.00 Total $3,840.00 As we all know the micro-purchase threshold is $3,000 for a single transaction or requirement. For toll charges, we need to make sure that the limit does not exceed $3,000 in one fiscal year, which you have already done. In order to remedy this situation and prevent it from being a larger issue, please contact EZ-PASS and have you card number removed from the account as an authorized payment method so that they cannot charge again in the beginning of February.