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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 have an MPT of $10,000, if they are exempted from a $2,500 threshold per 41 USC Chapter 67. The only services that we currently exempt are those that we determine to be professional or creative, per 29 CFR 541.301. When I first started, I inherited our entire state's Purchase card program, which was right after the MPT was increased, during high staff turnover, and a switch to a new card vendor; cue mass confusion. I met with other CO's and a Dept of Labor wage specialist, and the determination (and guidance from above us in the Bureau) was that all "blue-collar", or non-professional and non-creative services, are subject to SCLS / SCA / FLSA and have only a $2,500 MPT. In short, right now at my Bureau, every blue collar requirement over $2,500 cannot go on a Purchase card and must be a contract (or order off an existing vehicle). The $2,500 amount is first mentioned in FAR 2.101, where it's spelled out as: [The MPT] means $10,000, except it means- (1) For acquisitions of construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction), $2,000; (2) For acquisitions of services subject to 41 U.S.C. chapter 67, Service Contract Labor Standards, $2,500; (3) For acquisitions of supplies or services that, as determined by the head of the agency, are to be used to support a contingency operation....[yada yada] The only other time the $2,500 amount is explicitly referenced again is in FAR 22, with a general emphasis being that Service contracts over $2,500 have to have certain Clauses, Previsions, Wage Determinations, and other relevant attachments. Otherwise, just "micro-purchase threshold" is used throughout FAR 5, 6, 12, 13, etc. My question: is my Bureau wrong about the "blue collar" rule, in which non-professional / non-creative services all still have just a $2,500 MPT? I looked at 41 USC Chapter 67, which has these exemptions under para. (b): (b) Exemptions.—This chapter does not apply to— (1) a contract of the Federal Government or the District of Columbia for the construction, alteration, or repair, including painting and decorating, of public buildings or public works; (2) any work required to be done in accordance with chapter 65 of this title; (3) a contract for the carriage of freight or personnel by vessel, airplane, bus, truck, express, railway line or oil or gas pipeline where published tariff rates are in effect; (4) a contract for the furnishing of services by radio, telephone, telegraph, or cable companies, subject to the Communications Act of 1934 (47 U.S.C. 151 et seq.); (5) a contract for public utility services, including electric light and power, water, steam, and gas; (6) an employment contract providing for direct services to a Federal agency by an individual; and (7) a contract with the United States Postal Service, the principal purpose of which is the operation of postal contract stations. The Chapter 65 exemption referenced therein refers to Supplies requirements. Administering the Purchase card program is honestly the bane of my professional existence...whether it is cardholders splitting purchases, cardholders begging to exempt things from the $2,500 MPT, Ratifications in the $9k-$11k range, and PR's in the $2,500 - $10k range - this eats up SUBSTANTIAL hours of my and other CO's time. If the Services MPT was just uniformly $10k, life would be remarkably easier, and I could spend much less time on these abundant low dollar value requirements. It would also make a lot of sense....so I assume that's not how the regs work, and my Bureau's current policy is right. However, I assume that the comments on my other post were just made in error, and my determinations so far, and my Bureau's leadership's determinations, are in fact correct and many services still have only a $2,500 MPT.
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.