1901 is titled Simplified Acquisition Procedures; and 3305 is titled Simplified Procedures. With minor exceptions both texts are roughly equivalent. Both are also referenced under the RFO Far Part 12 rewrite, under Applicability.

Google seems to think 3305 is applicable only to micro purchases but when reading the text they both reference SAT.

1901 is codified under a Division title called OFPP; while 3305 is codified under a Division title called Procurement.

Thoroughly confused on this.

The initial question was that the RFO FAR 12 rewrite still excepts CICA from SAP explicitly stating FAR 13 is excepted; however under the RFO, FAR 13 is now Non-commercial SAP. RFO Far Part 6 makes no exception to FAR 12 procedures.

One last point -- under the FAR 12 rewrite, SAP is no longer a thing. What has been messaged down in the DOW so far is that commercial SAP has been rolled into Part 12 and yet, there is no mention of SAP in Part 12. It only references "Simplified Procedures" now.

Hence, back to the difference between 1901 and 3305 which seem to differentiate between the two phrases.

Can anyone explain the difference?

4 hours ago, cdhames said:

Thoroughly confused on this.

That's because you're reading the statutes. Don't do that.

Read the applicable regulation --- FAR or RFO FAR class deviation. Whichever applies in your case.

19 hours ago, cdhames said:

Can anyone explain the difference?

I simply asked AI. No doubt the response changes based on the form of the question but this seemed to make sense to me. Noting that the RFO seems to make the same differentiation.

"The primary difference between 41 U.S.C. § 1901 and 41 U.S.C. § 3305 lies in their scope of application regarding contract value and the types of products being acquired:

• 41 U.S.C. § 1901 (Simplified Acquisition Procedures): This section authorizes the use of simplified procedures specifically for the acquisition of commercial products and commercial services. It provides a higher dollar threshold—historically up to $7 million (or $13 million for certain acquisitions)—allowing agencies to use streamlined methods for high-value commercial items that would otherwise require more complex formal procedures.

• 41 U.S.C. § 3305 (Simplified Procedures for Small Purchases): This section serves as the general authority for simplified procedures for all types of purchases (not just commercial) but is strictly limited to amounts not greater than the Simplified Acquisition Threshold (SAT)."

Great find Carl. So the answer is pretty sample.

@cdhames Have you read RFO 12.102(b)?