Reporting Manual Action - Standalone CAR's

[ROD]

Guys & Gals

This is a question I have based on my current contracting center procedures on reporting Manual Action - Standalone CAR's  for BPA calls under $10K. Keeping in mind that we are located overseas, FAR 7.107 Service Contract Labor Standards does not apply for services contract therefore our micropurchase threshold for services is bumped to $10K. 

So, why do we report Manual Action Report - Standalone CAR's  for BPA calls under $10K?

When:

*** PGI 204.606 Reporting data.

• (A) An individual CAR is required to be reported for each of the following types of awards regardless of the estimated value of the awards

  • (5) Task and delivery orders and calls issued under any agreement or indefinite-delivery contract (including Federal Supply Schedules, Governmentwide acquisition contracts, or multi-agency contracts).

*** 4.601 Definitions.

As used in this subpart-

“Contract action” means any oral or written action that results in the purchase, rent, or lease of supplies or equipment, services, or construction using appropriated dollars over the micro-purchase threshold, or modifications to these actions regardless of dollar value. Contract action does not include grants, cooperative agreements, other transactions, real property leases, requisitions from Federal stock, training authorizations, or other non-FAR based transactions.

“Contract action report (CAR)” means contract action data required to be entered into the Federal Procurement Data System (FPDS).

*** FPDS-NG: What’s reported to FPDS-NG?

Contracts whose estimated value is $10,000 or more. Every modification to that contract, regardless of dollar value must be reported to FPDS-NG.

 

Any other interpretations, thoughts, suggestions? 

Thanks 

ROD