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We have an "item" on our GSA IT-70 schedule for a government-site training class. It has a part number, description (syllabus), and duration (1 week). It also specifies that travel is not included. The cost for the class is about $12k. Additionally, there will be travel expenses (hotel, airfare...) separate from the GSA item. Here is the challenge: 1. Fed customers want to pay with GPC; however, some do not want to see the GSA item and travel costs itemized but want a single total with the training class descriptor.This would show our GSA product billed at a higher amount (not acceptable). The travel is not incurred by a government employee (thus requiring the Gov travel card) but is an actual cost reimbursement for contractor travel to facilitate the training (ancillary). Although the gov can't pay for federal employee travel on GPC, can they pay contractor travel costs itemized on an invoice along with the GSA line item for training? 2. A general question on this: can the government purchase the training before it takes place and pay for the travel after the fact. I've seen where, under the tuition exception to advanced payments, that this could be deemed acceptable but I'm not sure. I would appreciate any insights!
In the FAR the term Contracting Officer is defined as "a person with the authority to enter into, administer, and/or terminate contracts and make related determinations and findings. The term includes certain authorized representatives of the contracting officer acting within the limits of their authority as delegated by the contracting officer. “Administrative contracting officer (ACO)’’ refers to a contracting officer who is administering contracts. “Termination contracting officer (TCO)” refers to a contracting officer who is settling terminated contracts." The second sentence of the definition stumps me. Could the 'certain authorized representative' be a Government Purchase Card holder acting within their authority (assuming their appointment letter is on the SF1402)? In instances of limiting competition, typically the FAR makes mention of the Contracting Officer documenting the reasons for the limited competition. In the case of a GPC purchase, if competition is going to be limited for legitimate reasons, who is the Contracting Officer that would give approval? Thank you.
Background: Our agency procures reports that contain taxpayer information. The cost of procuring these reports are less than the micro purchase threshold. Mandatory clauses are necessary due to disclosure and privacy issues. Question: In order to reduce the time to procure these reports we are considering using the GPC card for requirements less than $2,500.00 in lieu of issuing PO's which has been past practice. The vendor must accept the mandated clauses in writing before beginning performance. Can we send a separate sheet containing the required clauses to the vendor and get acceptance in writing. Then after acceptance, order the reports using a GPC?