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First time post and would greatly appreciate any feedback/insight. Could be as simple as a yes and no, or feel free to elaborate. I started at a new organization this summer and I am confused with the current organizations process compared to my last organization. Does your organizations GPC/policy team review every single micro purchase made by cardholders? They had me fill in for a teammate that went on leave and my task was to watch an email org box and assign these requests to reviewers on our team and put these request into an excel file. (There are packages submitted for pens/pencils, staples, stamps etc...many purchases under $100.00). They are pretty pessimistic about the card holders that's why they want to review everything, but to me it seems to defeat the purpose of the program. They take the training required and are authorized to make these purchases. From my experience its the same anywhere, its inevitable that there will be negligent card holders but that shouldn't mean holding up the entire program. My previous organization did not do this as there are hundreds of card holders and thousands of transactions made each year making reviewing every purchase unrealistic. There were audits and random reviews of the files to ensure compliance, IOD for split purchases etc... I am trying help the program and save a handful of contracting bodies that do this all day. Anything I could provide to show that there is a better way to do this?
I have recently transitioned to a new agency and have been surprised by a local policy that states "As a general rule, the contract specialist originating a document signs it as the CO (Contracting Officer) after all required reviews." In practice, this language is cited supporting the fact that a specialist (non-warrant holder) would actually sign contract actions, or a contracting officer may sign actions over their delegated warrant authority. Now, one of the levels of review required would be from a Contracting Officer that holds the required warrant authority and they would be required to sign the review forms necessary. Though, again, the ultimate government signatory may not actually have a warrant that covers the value of the action. In speaking with our local policy official, it was explained that the rationale behind this approach is that the contract specialist whom is involved with the acquisition has a far greater knowledge base about the acquisition than a Contracting Officer whose only contribution is their warrant authority. While I understand that point of view, it was always my belief that the Specialist/Officer dichotomy centered around the Contracting Officer keeping familiar at least in a general sense with their contract. The specialist is responsible for keeping the Contracting Officer aware of issues and potential complications. Ultimately, I THINK I would be protected from personal liability if this practice was ever challenged in litigation as long as I am operating within established contracting office policy - but am not really sure. The legal council for the office has apparently signed off on this practice, so that does alleviate some of my concern. I consider myself a moderately seasoned contracting professional, and have always understood that you just do not sign actions that you do not have warrant authority to sign. However, I certainly do not have a robust knowledge of the various agencies policies when it comes to warrant delegation. I am curious if: (a) Anyone else operates under this type of structure? (b) If so, has it ever been challenged? (c) General thoughts about this structure, such as does this approach fall within the purview of FAR 1.602-1(a) "Contracting officers may bind the Government only to the extent of the authority delegated to them. Contracting officers shall receive from the appointing authority (see 1.603-1) clear instructions in writing regarding the limits of their authority." Also, am I at risk for Unauthorized Commitments with every action I would be signing? I am consciously being vague about the agency/office just to avoid seeming accusatory, but suffice to say that agency FAR supplement does not address this - only the local policy does. Sorry for the long post, but I thank you all in advance for any input.