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Micropurchase Threshold and 2012 NDAA


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#1 civ_1102

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Posted 28 February 2012 - 11:48 AM

Section 822 of the FY12 NDAA contained the following language regarding the micropurchase threshold:

This section would allow the Secretary of Defense to apply a simplified
acquisition threshold of $1.0 million and micro-purchase threshold of $25,000 for
contracting activities supporting contingency operations in the Republic of Iraq or
the Islamic Republic of Afghanistan, regardless of the location of the contracting
activity.

FAR 13.201(g)(1)(i) establishes a MP threshold, for contingency operations, of $15,000 in the case of any contract to be awarded and performed, or purchase to be made, inside the United States and 13.201(g)(1)(ii) establishes a MP threshold of $30,000 in the case of any contract to be awarded and performed, or purchase to be made, outside the United States.

I work in a DoD contracting office located in Afghanistan. The organization has interpreted the NDAA to mean that the MP threshold for any purchase related to contingency operations in Iraq or Afghanistan to now be $25,000, even when the contract is awarded OCONUS. However, to me the intent seems to be to authorize a higher threshold for contracting offices located CONUS that are issuing contracts in support of the operations in Iraq/Afghanistan.

Does anyone have any insight into the background of this or which interpretation is correct?

#2 ji20874

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Posted 28 February 2012 - 12:26 PM

civ_1102,
You write, "This section would allow the Secretary of Defense to apply a simplified acquisition threshold..." If so, should you wait for the Secretary of Defense to take his action before you adopt the higher threshold? Such action might come in the form of a DPAP letter or DFARS change.

#3 jason_a

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Posted 28 February 2012 - 12:39 PM

Civ, the purpose of the change was to allow Reachback cells located in the CONUS to make purchases for OEF and OND at the higher threshold. This is shown by both the House and Senate reports. Below is from the House side, the Senate version is almost the same. I agree with ji though, I would wait for the policy or inquire about it.

SEC. 843. REACH-BACK CONTRACTING AUTHORITY FOR OPERATION ENDURING FREEDOM AND OPERATION NEW DAWN.


(a) Authority To Designate Lead Contracting Activity- The Under Secretary of Defense for Acquisition, Technology, and Logistics may designate a single contracting activity inside the United States to act as the lead contracting activity with authority for use of domestic capabilities in support of overseas contracting for Operation Enduring Freedom and Operation New Dawn. The contracting activity so designated shall be known as the `lead reach-back contracting authority' for such operations.

(B) Limited Authority for Use of Outside-the-United-States-thresholds- The head of the contracting authority designated pursuant to subsection (a) may, when awarding a contract inside the United States for performance in the theater of operations for Operation Enduring Freedom or Operation New Dawn, use the overseas increased micro-purchase threshold and the overseas increased simplified acquisition threshold in the same manner and to the same extent as if the contract were to be awarded and performed outside the United States.




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