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There is a training requirement of $50K that will be attended by 10 Government employees from various offices. My argument is that the requirement is each individual person attending this class, with a separate SF182. The micro-purchase threshold for training is $25K. If the class is being split into multiple purchases because the class is the requirement I would say that is a split, but my assertion is that the requirement is each individual SF-182 and that 10 credit card swipes of $2,500 is not splitting the purchase and should be acceptable. Please give me your thoughts.
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A Training Officer with authorization to use a SF182 to obligate funds and contract for training did not complete the routing process (BFM and comptroller signature was not acquired) of the SF182 before the training took place. Since the funding was available and the Government representative had the authority, is this action still an Unauthorized Commitment?