I'm all for rightsizing and streamlining, but these changes seem like kind of stuff my five-year-old would dream up if he were a contract specialist.

This makes me cringe: "This proposal would increase the Simplified Acquisition Threshold for commercial products and services in phases from $250,000 to $10 million over 5 years..." Source

FAR doesn't increase the SAT, it allows the use of SAP for commercial products and services up to a certain dollar threshold. Seemingly minor distinction, but a meaningful one. I'd expect the people involved in this process to know the difference.

I'd love to hear others' thoughts.

Excerpts
"One of the central proposals by GSA focuses on enhancing Simplified Acquisition Procedures for small-dollar contracts. Under this initiative, the threshold for simplified purchases will gradually increase as follows:

(A) $2,000,000 through Sept. 30, 2027;

(B) $5,000,000 from Oct. 1, 2027 through Sept. 30, 2030; and

(C) $10,000,000 after Sept. 30, 2030."

and
"Also included is a substantial overhaul of the Micro-Purchase Threshold, which will increase from $10,000 to $100,000 over five years. Despite the flexibility this would bring, the Buy American Act will still apply to all micro-purchases above $10,000, preserving domestic preference. GSA anticipates the move could streamline over half a million transactions annually, significantly reducing the workload on contracting officials."

GSA completes the statutory foundation for expanded, consolidated procurement authority

Legislative Proposals | GSA

On 8/2/2025 at 1:45 PM, Coconut said:

I'd love to hear others' thoughts

First, I wonder why the proposal does not mess with 41 USC 1908?

To the substance of adjusting the SAT I say about time as the sematics around SAT and SAP in truth have little meaning today. After all with SAP available to $7.5 million ($15 m in contingency ops) whats the difference. Maybe it will force folks to utilize SAP finally. But a serious culture change is necessary to make it work beyond just changing the threshold as from my view folks donot get it with regard to SAP and have bastardized its use to look more like FAR Part 15 procedures. I might add the culture change i extends to the whole of the acquistion "team" which includes the courts as again from my simple view the ideal of "termination for cause'" with regard to SAP and FAR Part 12 got morphed in to looking just like termination for default from the courts view.

Micropurchase, about time as well but it will have little impact if the constraints of the Service Contract Act and Davis Bacon (yep I am old school and still use old terms) are not changed as well.

3 hours ago, C Culham said:

Micropurchase, about time as well but it will have little impact

For HHS , under these new definitions,

• ~ 60% of all awards in HHS could be classified as micropurchases. (up from 6%)

• ~ 97% of all awards could use FAR 13 (commercial and under $50M) (up from 76%)

That might have an impact or might not. HHS rarely uses FAR 15 anyways, and so there isn't much that under these new thresholds could switch to FAR 13. Like everyone else, HHS already makes extensive use of FAR 8.4 and 16.505 (about half of everything is a TO/DO in HHS) and these changes don't have much or any impact here.

Micropurchases have a bunch of restrictions on them that aren't going away, and they don't exempt much of the work that is done b/w $10K and $100K. In IT world, which I know best, cybersecurity is always a major consideration, takes a while, and price doesn't matter. So I am skeptical of the impact. WIll it help? Yes. A lot? Probably not.

On 8/2/2025 at 4:45 PM, Coconut said:

streamline over half a million transactions

Maybe. I am skeptical of FAR procedures being a major source of inefficiency, and thus skeptical of the potential benefit of moving around the boundaries of FAR procedures. I note that my agency, like most if not all agencies, now has five additional approvals for nearly everything. For us, its SES x 3, Agency Head x 1 and Department x 1. For many things, this happens twice, so ten approvals. This process is why DHS didn't send search and rescue after the Texas floods. It is the opposite of streamlining - it has introduced big new inefficiencies in the system. So let's stop digging first, before we start figuring out how to get out of the hole.

I am really struggling with the idea that GSA wants to charge fees to register with Sam.gov. It's pay-to-play at its worst. The ability to bid for and win Federal contracts should not be predicated on your ability to pay registration fees. It will wall off Federal procurement even further from the people it is supposed to serve.

Regarding micropurchases: At both my most recent Federal jobs, using the purchase card became almost as hard as issuing a purchase order. Multiple supervisors had to approve its use, then approve the transaction itself. It has very much lost its ability to provide the flexibility, ease of use, and speed that the idea of micropurchase is based on. (Cynically, it does employ a lot of entry level financial statement auditors and IG/GAO folks. They love digging into the micropurchases to find 3K worth of questionable spend.)

3 minutes ago, KeithB18 said:

It will wall off Federal procurement even further from the people it is supposed to serve.

I don't understand that.

Who are the people Federal procurement is supposed to serve? How will SAM registration fees wall those people off?

1 hour ago, Vern Edwards said:

I don't understand that.

Who are the people Federal procurement is supposed to serve? How will SAM registration fees wall those people off?

In the end, Federal procurement serves the public. It's pretty straightforward that if you make people pay to participate, fewer people will participate. It's especially odd to me because the regulatory regime surrounding Federal contracting is already a high bar for participation. We used to get measured on how many new small businesses got government contracts. Now we're trying to increase the "non-traditionals" to participate. Paying to participate acts against those goals, whatever you think of those goals in the first place. (I don't even like TSA PreCheck, even though I have it, because it creates a situation where financially capable citizens can pay for better service from the government that is supposed to serve them.)

I'd also note that SAM registration applies to financial assistance recipients too, many of which do important work in our communities without a lot of overhead.

2 hours ago, KeithB18 said:

I am really struggling with the idea that GSA wants to charge fees to register with Sam.gov. It's pay-to-play at its worst. The ability to bid for and win Federal contracts should not be predicated on your ability to pay registration fees. It will wall off Federal procurement even further from the people it is supposed to serve.

The flip side is why should taxpayers pay for something that only a small share use? GSA is faced with a big cost increase now. It needs funded with more money. “Pay-to-play” isn’t new to citizens. Passports, patent applications, drug approvals, airline passenger arrivals, entering national parks, marine vessel registration, and so on.

2 hours ago, KeithB18 said:

I'd also note that SAM registration applies to financial assistance recipients too, many of which do important work in our communities without a lot of overhead.

2 hours ago, formerfed said:

The flip side

The double flip side....my rancher/farmer friends that I have helped with the day to day stuff as well as helping them register in SAM.gov as they have to as a participants in USDA programs.

And why wouldn't I as taxpayer be happy that it is free registration as from memory in part the intent of SAM was to have a clearinghouse (my term) of those that do business with the Federal government so those that owe taxes etc. could be identified easily so that said monies could be collected. Just as a tool for the acquisition side is too narrow minded on the part of GSA in my view and would suggest that maybe just maybe the operating deficit of the system is due to inefficiencies of management and operation of the system and/or a not well thought out cost benefit analysis.

I think the burden of proof on fees for sam registration lands with GSA. Its currently free, why does that need to change now?

Its also not "free." Every agency pays into the "integrated award environment" pot, so this just extracts funding from another source. Which, if you read Cory Doctorow, is right out of the Enshittification playbook. Its why all our social media and online experiences are worse now than they've ever been.

IMO putting SAM behind a paywall isn’t going to do anything. Those costs are just going to be covered in B&P which will be charged right back to the Govt which it’s already paying for. Maybe you’ll weed out those folks that register once and then never do anything again, but their registrations go inactive anyways so that data is archived and eventually deleted.

As far as the changes to the thresholds, the one that really worries me as an 1102 is the proposed increase in the GPC threshold under the FORGED Act. $25M purchases on a Pcard, that will eliminate 80-90% of the contracting folks outside of systems contracting.

Not to beat a dead horse but Vern says it all the time, until better training is given to acquisition folks, the processes that we award contracts will largely remain the same, regardless of the thresholds because there’s still the policy and processes on how to do things at each command and now with DRP and VERA so many folks have walked out the door that knew why the processes where there and what was done and when a process applied or not. Once the hiring freeze is lifted all the new folks will have no clue what to do, other than follow the local process which just recreates the wheel that Congress is trying to destroy by raising thresholds to make things faster.

21 hours ago, KeithB18 said:

It's pretty straightforward that if you make people pay to participate, fewer people will participate.

"Participate" how? By submitting quotes, bids, or proposals? "

... fewer people..." How many fewer?

1. Do we know how much GSA would charge to register? Would, say, $150.00/year deter serious prospective quoters or offerors? It wouldn't deter me, and I'm a very small business.

2. Would such a registration fee reduce competition? If so, what amount of fee would reduce what amount of competition?

I realize, of course, that few if any of us could answer (as opposed to speculate about) those questions. I cannot. But maybe we should seek more info and then think the thing through.

"Its currently free, why does that need to change now?"

Because SAM costs money to maintain. Before the CBDnet went online in 1996, prospective bidders had to pay to subscribe to the Commerce Business Daily.

4 hours ago, Vern Edwards said:

1. Do we know how much GSA would charge to register? Would, say, $150.00/year deter serious prospective quoters or offerors? It wouldn't deter me, and I'm a very small business.

This is from a LinkedIn post by the American Small Business Coalitition

“The Office of Management and Budget proposes charging businesses $75-$125 registration fees plus $25-$50 annual fees to access SAM.gov - a federally funded system that currently advertises "100% Free" registration.

The Bottom Line: Section 7 of OMB's Revolutionary FAR Overhaul to the 119th Congress would shift (or augment) SAM.gov from federal funding to user fees, targeting $40 million from 780,000+ registered entities. This contradicts SAM.gov's own FAQ stating registration is free "because SAM.gov is a federally mandated and funded program."

The Problem: GSA's Acquisition Services Fund has absorbed $690 million in shortfalls since 2015, creating unsustainable federal funding gaps.“

What costs so much?

The alphabet soup mix and remix since 2003 of Central Contractor Registry (CCR), Federal Agency Registration (Fedreg), Online Representations and Certifications Application (ORCA), the Excluded Parties List System (EPLS), FEDBIZOPS and DUNS to CAGE code has created a monolith (SAM.gov) that was suppose to be more efficent. Really, more efficient at more cost?

In truth the complications of SAM.gov that have resulted in side businesses popping up where folks pay to have help in managing their SAM.gov account is the testament that SAM.gov doesn't work and having me as a taxpayer throw more money at it as a "fee" is a joke. The "fee" is a disguised tax where the "fix" is to just throw more money at it rather than dissecting the monster to see why it supposedly costs too much money dating back to 2015 which is a mere 3 years after SAM.gov went live.

The fee does not "fix" the problem!

3 hours ago, C Culham said:

In truth the complications of SAM.gov that have resulted in side businesses popping up where folks pay to have help in managing their SAM.gov account is the testament that SAM.gov doesn't work and having me as a taxpayer throw more money at it as a "fee" is a joke. The "fee" is a disguised tax where the "fix" is to just throw more money at it rather than dissecting the monster to see why it supposedly costs too much money dating back to 2015 which is a mere 3 years after SAM.gov went live.

Well said!!!

But they won't fix it. Everybody loves IT and info gathering too much.

3 hours ago, C Culham said:

What costs so much?

The alphabet soup mix and remix since 2003 of Central Contractor Registry (CCR), Federal Agency Registration (Fedreg), Online Representations and Certifications Application (ORCA), the Excluded Parties List System (EPLS), FEDBIZOPS and DUNS to CAGE code has created a monolith (SAM.gov) that was suppose to be more efficent. Really, more efficient at more cost!

Sam.gov also now maintains the database for DOL wage determinations and FASCSA orders. CPARS looks to be moving to Sam.gov. Sam.gov is ever growing.

The issues I have with a fee for using Sam.gov is the gov’t uses SAM for its own internal purposes as much as for the public.

@Mattt Or even more than the public!

8 hours ago, Mattt said:

The issues I have with a fee for using Sam.gov is the gov’t uses SAM for its own internal purposes as much as for the public.

On the other hand...

• Free registration may have prompted entities that are not serious about pursuing government contracts to clutter up the system, uselessly, from the government's point of view.

• Free registration may have created a market and a database for "consultants" and scam artists who want to take advantage of the clueless.

In my opinion, any company that would complain about $125/year is not serious about pursuing government contracts. I pay that much to register my pickup and trailer with the DMV for the state's own internal purposes.

All I get is little stickers to put on my license plates.

Thanks for the discussion everyone. I let this simmer for awhile and I think this is the type of thing that gets proposed every so often but never goes anywhere.

Or I could be entirely wrong and it's implemented in the next five years!

Thanks again.

On 8/4/2025 at 3:41 PM, General.Zhukov said:

For HHS , under these new definitions,

• ~ 60% of all awards in HHS could be classified as micropurchases. (up from 6%)

• ~ 97% of all awards could use FAR 13 (commercial and under $50M) (up from 76%)

That might have an impact or might not. HHS rarely uses FAR 15 anyways, and so there isn't much that under these new thresholds could switch to FAR 13. Like everyone else, HHS already makes extensive use of FAR 8.4 and 16.505 (about half of everything is a TO/DO in HHS) and these changes don't have much or any impact here.

Micropurchases have a bunch of restrictions on them that aren't going away, and they don't exempt much of the work that is done b/w $10K and $100K. In IT world, which I know best, cybersecurity is always a major consideration, takes a while, and price doesn't matter. So I am skeptical of the impact. WIll it help? Yes. A lot? Probably not.

Maybe. I am skeptical of FAR procedures being a major source of inefficiency, and thus skeptical of the potential benefit of moving around the boundaries of FAR procedures. I note that my agency, like most if not all agencies, now has five additional approvals for nearly everything. For us, its SES x 3, Agency Head x 1 and Department x 1. For many things, this happens twice, so ten approvals. This process is why DHS didn't send search and rescue after the Texas floods. It is the opposite of streamlining - it has introduced big new inefficiencies in the system. So let's stop digging first, before we start figuring out how to get out of the hole.

My agency has numerous procurement locations worldwide - usually staffed up by locally employed staff (with a US CO).The micro-purchase threshold increase is, frankly, welcome news. If the proper controls are put in place, I don't see how this is a bad thing at all. But, with all these increases and streamlinings, it certainly appears that the procurement workforce is really going to morph into a sort of "buyer" role altogether. Maybe a new series should be created altogether? Perhaps a revamped 1105 series should be introduced that matches what is happening on the ground and in the regs? If the micro is upped, it sounds like the program offices are going to be able to make a lot more of the purchases, which may shrink the current acquisition workforce even more. Then again, just because the threshold is $100k doesn't mean the card itself will have a limit anywhere near that. Many p-cards at my agency were capped at $3k and they have stayed at that amount even when the threshold was raised.

Regarding approvals - yea, that is a problem, especially now we have to run anything over $1 million (save for mods) up the chain and across the river. This extra step of process can take many weeks , which is a problem at the end if the FY. The acquisition planning phase now has to factor in the time for these additional approvals (HCA, SPE, HQ and so forth).

2 hours ago, Motorcity said:

My agency has numerous procurement locations worldwide - usually staffed up by locally employed staff (with a US CO).The micro-purchase threshold increase is, frankly, welcome news. If the proper controls are put in place, I don't see how this is a bad thing at all. But, with all these increases and streamlinings, it certainly appears that the procurement workforce is really going to morph into a sort of "buyer" role altogether. Maybe a new series should be created altogether? Perhaps a revamped 1105 series should be introduced that matches what is happening on the ground and in the regs? If the micro is upped, it sounds like the program offices are going to be able to make a lot more of the purchases, which may shrink the current acquisition workforce even more.

I see problems with justifying fair and reasonable pricing. There’s no competition required at the micro-purchase level, and that is one of the easiest and most common means. Various other ways of performing price/cost analysis exist, but some take training and experience to properly use. Considering the increased dollar value ceilings and the complexity of some buys especially for specialized professional services, analyzing and documenting fair and reasonable isn’t easy. This seems beyond what 1105s typically did. So anyone handling micro-purchases at a higher increased threshold either needs to be an 1102 or adequately trained in a 1105 type series.

On 8/2/2025 at 4:45 PM, Coconut said:

and
"Also included is a substantial overhaul of the Micro-Purchase Threshold, which will increase from $10,000 to $100,000 over five years. Despite the flexibility this would bring, the Buy American Act will still apply to all micro-purchases above $10,000, preserving domestic preference. GSA anticipates the move could streamline over half a million transactions annually, significantly reducing the workload on contracting officials."

I wonder what the increase will be for each phase? An extra $18K a year for five years? $10k - $28k - $46k - $64K - $82k - $100k

7 hours ago, formerfed said:

So anyone handling micro-purchases at a higher increased threshold either needs to be an 1102 or adequately trained in a 1105 type series.

7 hours ago, formerfed said:

the complexity of some buys especially for specialized professional services, analyzing and documenting fair and reasonable isn’t easy.

Indeed, here are some slightly heighted 1102 comments I have read recently about professional services requirements <$100K which, I think, suggest these probably shouldn't be treated as micropurchases handed off to an 1105.

1) These contractors will have access not only to facilities, but to [an IT system] and so the contract and contractor personnel need [a whole lot of cybersecurity-related stuff].

2) Meetings are not deliverables. This "SOW" has no actual deliverables. What are we paying them to do, and how do we know they have done the thing for which we pay them?

3) You cannot realistically award this contract and have these [very specialized] contractors start the next week. Thats not how it works. Since this lead-time wasn't on your plan, and you have a hard start-work date, we will have to make up the time elsewhere in the acquisition process.

3) Your IGCE is literally just the sentence "2 x Specialist III at $150/HR, 2,000 hours/year is $600,000."

4) I understand that you do not like either of the two offers received, nor can you afford them, but that doesn't mean I can take you up on your suggestion to "just sole source it" to that vendor you like.

20 hours ago, formerfed said:

So anyone handling micro-purchases at a higher increased threshold either needs to be an 1102 or adequately trained in a 1105 type series.

Let me modify that to say: “So anyone handling micro-purchases at a higher increased threshold either needs to be an adequately trained 1102 with business sense or adequately trained in a 1105 type series.”

Would these increases have an effect on the number of folks in the procurement workforce? I'd be specially interested in seeing how the numbers stack up overseas at various posts abroad where the vast majority or purchases fall well under the $100k mark. You won't need as many employees to do the work if it is streamlined to such levels - or would you?

2 hours ago, joel hoffman said:

Let me modify that to say: “So anyone handling micro-purchases at a higher increased threshold either needs to be an adequately trained 1102 with business sense or adequately trained in a 1105 type series.”

Good revision