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PO vs GPC


SgtP

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We have a requirement to lease equipment for 12 months total a little over $1600. AFI 64-117 prohibits the use of GPC for lease over 90 days and SAF/AQC letter signed by Mr Roger Correll (deputy assistant sec for contracting) says we can't use GPC as a method or payment on PO's due to weaknesses on internal control of the GPC. DFARS 213.270 allows us to issue PO at or below the micro purchase with the approval of a general or flag officer or a member of the Senior Executive Service (SES) or a local senior commander as long as it has been established that the source doesn't accept GPC and that the CO is looking for another source that accepts the purchase card. Well, the only reason we're using the PO is because of the AFI and SAF/AQC; do these trump DFARS? If we just reference the policy letter from SAF/AQC then we wouldn't need the signature from the senior local commander (WG/CC).

Does this make sense? I guess my question is do I need a WG/CC signature if the reason doesn't follow DFARS entirely.

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I would think that your particular situation may require additional terms and conditions (i.e. clauses) that require a written order be issued. Presumably you have insurance, maintenance, or other requirements that should be written; or you may need to lay out terms and conditions similar to the vehicle clauses in FAR Part 8. The DFAS Memo that came out many years ago also exempted micro-purchase PO's from the Flag/SES signature, if the contract needed to include terms and conditions that had to be in writing.

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