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I am a recently Warranted CO at a civilian Bureau only working in the states (not overseas) that deals with a lot of very low dollar requirements between the Micro Purchase Threshold (MPT) and $15k.  I also have to run the purchase card program, but that's an entirely different headache. 

I currently have an ~$11,000 tree removal project that does not count as unusual and compelling urgency. 

The only capable vendor, according to the requiring office, is not in SAM. 

My question is: for things under the $15k threshold, with no synopsizing or publicizing required, and with only oral quotations, and with an attempt to innovate, keep documentation minimal, and be maximally efficient (IAW FAR 13), is there any way to use a non-SAM-registered vendor? 

I am trying to figure out if there is a way to use purchase card, too, because logically,  we are given these tools (Warrants, training, purchase cards, FAR 13, etc) for exactly this reason: to not spend hours and hours on low risk, low dollar, low priority awards. 

Could one simply have a vendor manually fill out 52.212-3 to get their representations in writing? 

52.204-7  System for Award Management, as prescribed at 4.1105(a)(1), must go in "all solicitations" - and it looks like the only real exception an exception under 4.1102(a)(5): 


 (5) Contracts awarded without providing for full and open competition due to unusual or compelling urgency (see 6.302-2)

Somewhat tangential: these MPT - $15k projects can be very frustrating and time consuming, particularly because the administrative costs are so high relative to other work we have to do, and requiring offices insisting we use "their" "local" vendor who they often talk with for weeks before we get a PR.  Being able to streamline and simplify the 100+ requirements like this that we deal with each year would save us hundreds of hours of work. 

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comment deleted -- I mis-read the original posting

but, it would be great if agencies would start to meaningfully use the $10,000 micropurchase threshold -- this means Government Purchase Card limits should be raised to $10,000

Geek, can you negotiate the price from ~$11,000 to $9,999.99?  Then, FAR 4.1102(a)(1) would cover you.

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You do realize that the MPT is now $10k, correct? The FAR hasn't been updated yet, but 30+ agencies have issued class deviations to implement the new threshold. 

In any case, assuming you don't have the authority to raise Government purchase card limits, you could also consider a BPA as described at FAR 13.303.

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I will vouch for the facts that tree removal companies are not the types that would go to the trouble of filling out government “paperwork” unless you spoon feed them.

They usually have plenty of business to keep them busy.

Probably will take as long to do the “paperwork” as to remove the trees. 

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13 hours ago, GovtAcctGeek said:

52.204-7  System for Award Management, as prescribed at 4.1105(a)(1), must go in "all solicitations" - and it looks like the only real exception an exception under 4.1102(a)(5): 

You’re likely going to get tied up with more than SAM —

4.1804 Solicitation provisions and contract clause.

       (a) Insert the provision at 52.204-16, Commercial and Government Entity Code Reporting, in all solicitations that include–

            (1)  52.204-6, Unique Entity Identifier; or

            (2)  52.204-7, System for Award Management.



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@GovtAcctGeek. As has been provided no way to avoid SAM if there is no exception that would apply.

Do consider being proactive and refer the contractor to the most local Procurement Technical Assistance Center for assistance in registering in SAM.  THE PTAC assistance is free.  Find your local one here ....https://www.aptac-us.org/

On another point I realize you mention "urgent and compelling" based on the exception to SAM.  I just wanted to give you the heads up if you did not already know that FAR Part 6 does not apply to the world of procurement you are dealing with - MP to $15K.  FAR 13.106 is the reference should you be in the world of needing a single source.  This is a general rule.  In some cases agencies get twisted and apply FAR 6 stands to stuff below the SAP.

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I agree with Joel.  These type of businesses likely have more work than they can handle.  This kind of situation happens often in rural environments and very small businesses.  The company (could be one person) doesn’t want to bother registering with SAM, doesn’t want to be in a government data base, and it’s just too much work.

You could negotiate the price under $10K and use the P Card as already suggested.  You could call around and try to find another source of two.  You could also scale back the size of the work and do the most critical now if there’s a logical and supportive rational for breaking things up.  Ji20874 also has a great idea and that’s put together a BPA for all this type of work.  Award a manageable number and just use calls against them when these type needs come up.

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