Expanded Use of GPC

[Freyr]

I recall when I was working for the Air Force they had begun to implement their expanded use of GPC initiative, allowing non-warranted cardholders to procure under FAR 13.301 for up $25,000 provided they had the additional training and were provided a delegation stating this threshold. Of course, re-reading it sounds as if those cardholders were in fact warranted up to $25k (is that correct?). Seemed like a great idea and it really took a lot of the workload off the base contracting folks and instead each cardholder would submit their proof of compliance (typically a sole source J&A or 3 quotes they received) for anything above the MPC but under the $25k threshold. I suppose my question is why haven't I seen other agencies pursuing this (unless I'm missing it) and would it require any sort of deviation to the FAR to allow for this to happen?  

[Constricting Officer]

2 hours ago, Freyr said:

I suppose my question is why haven't I seen other agencies pursuing this (unless I'm missing it) and would it require any sort of deviation to the FAR to allow for this to happen?  

1. My agency has not implemented anything as such, although I do believe there has been discussion. I think the ability to provide good oversight for the larger agencies is the reason.

2.  FAR 13.301 (a) - ". . . the Governmentwide commercial purchase card is authorized for use in making and/or paying for purchases of supplies, services, or construction. The Governmentwide commercial purchase card may be used by contracting officers and other individuals designated in accordance with 1.603-3. . ."

FAR 1.603-3 (b) - "Agency heads are encouraged to delegate micro-purchase authority to individuals who are employees of an executive agency or members of the Armed Forces of the United States who will be using the supplies or services being purchased. Individuals delegated this authority are not required to be appointed on an SF 1402, but shall be appointed in writing in accordance with agency procedures."

Have to change the FAR for the un-warranted individual to go above the MPT. 

[ji20874]

Un-warranted employees can also order from existing contracts (think indefinite-delivery contracts) and BPAs above the MPT as ordering officials if their agencies will let them.

[jtolli]

To add to what others have said, the DFARS provides the authority for purchases up to $25,000 with the GPC @ 213-301(2)(II) which says:

"(2) An individual appointed in accordance with 201.603-3 (a) also may use the Governmentwide commercial purchase card to make a purchase that exceeds the micro-purchase threshold but does not exceed $25,000, if—

 

(ii) The individual making the purchase—

(A) Is authorized and trained in accordance with agency procedures;

(B) Complies with the requirements of FAR 8.002 in making the purchase; and

(C) Seeks maximum practicable competition for the purchase in accordance with FAR 13.104(b)."

In the Army, individuals with authority to make such purchases at called "Ordering Officers".  They are issued a Delegation of Procurement Authority as an Ordering Officer.  This is addressed in the AFARS. 

[formerfed]

My agency did this 20 years ago.  Selected program office personnel underwent simplified acquisition training.  Then they received limited warrants.  They documented actions including quotes or sole source justifications in the electronic system which were available for post contracting office review.  It worked extremely well.

[joel hoffman]

Regarding DoD : see this from the WIFCON home page:  https://www.acq.osd.mil/dpap/policy/policyvault/USA002016-20-DPC.pdf

[formerfed]

When my agency did this 20 years ago the one thing OFPP mentioned was the lack of required clauses.  We covered that through posting clauses on our web site and telling suppliers when accepting orders to check the website for applicable ones