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First time post and would greatly appreciate any feedback/insight. Could be as simple as a yes and no, or feel free to elaborate. I started at a new organization this summer and I am confused with the current organizations process compared to my last organization. Does your organizations GPC/policy team review every single micro purchase made by cardholders? They had me fill in for a teammate that went on leave and my task was to watch an email org box and assign these requests to reviewers on our team and put these request into an excel file. (There are packages submitted for pens/pencils, staples, stamps etc...many purchases under $100.00). They are pretty pessimistic about the card holders that's why they want to review everything, but to me it seems to defeat the purpose of the program. They take the training required and are authorized to make these purchases. From my experience its the same anywhere, its inevitable that there will be negligent card holders but that shouldn't mean holding up the entire program. My previous organization did not do this as there are hundreds of card holders and thousands of transactions made each year making reviewing every purchase unrealistic. There were audits and random reviews of the files to ensure compliance, IOD for split purchases etc... I am trying help the program and save a handful of contracting bodies that do this all day. Anything I could provide to show that there is a better way to do this?
I work at a small civilian Bureau, have to run the Purchase card program for our state, and I am aware the Micro-Purchase Threshold (MPT) was recently increased for some categories of requirements up to $10,000. However, on another forum post last year regarding an $11,000 tree removal requirement and using vendors not in SAM, another forum user suggested I negotiate down to the newer/higher $10,000 MPT, so it could be put on a Purchase card. At the time (FY-end madness) I thought that was odd, but didn't follow back up then. My Bureau's leadership insists that only some services have an MPT of $10,000, if they are exempted from a $2,500 threshold per 41 USC Chapter 67. The only services that we currently exempt are those that we determine to be professional or creative, per 29 CFR 541.301. When I first started, I inherited our entire state's Purchase card program, which was right after the MPT was increased, during high staff turnover, and a switch to a new card vendor; cue mass confusion. I met with other CO's and a Dept of Labor wage specialist, and the determination (and guidance from above us in the Bureau) was that all "blue-collar", or non-professional and non-creative services, are subject to SCLS / SCA / FLSA and have only a $2,500 MPT. In short, right now at my Bureau, every blue collar requirement over $2,500 cannot go on a Purchase card and must be a contract (or order off an existing vehicle). The $2,500 amount is first mentioned in FAR 2.101, where it's spelled out as: [The MPT] means $10,000, except it means- (1) For acquisitions of construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction), $2,000; (2) For acquisitions of services subject to 41 U.S.C. chapter 67, Service Contract Labor Standards, $2,500; (3) For acquisitions of supplies or services that, as determined by the head of the agency, are to be used to support a contingency operation....[yada yada] The only other time the $2,500 amount is explicitly referenced again is in FAR 22, with a general emphasis being that Service contracts over $2,500 have to have certain Clauses, Previsions, Wage Determinations, and other relevant attachments. Otherwise, just "micro-purchase threshold" is used throughout FAR 5, 6, 12, 13, etc. My question: is my Bureau wrong about the "blue collar" rule, in which non-professional / non-creative services all still have just a $2,500 MPT? I looked at 41 USC Chapter 67, which has these exemptions under para. (b): (b) Exemptions.—This chapter does not apply to— (1) a contract of the Federal Government or the District of Columbia for the construction, alteration, or repair, including painting and decorating, of public buildings or public works; (2) any work required to be done in accordance with chapter 65 of this title; (3) a contract for the carriage of freight or personnel by vessel, airplane, bus, truck, express, railway line or oil or gas pipeline where published tariff rates are in effect; (4) a contract for the furnishing of services by radio, telephone, telegraph, or cable companies, subject to the Communications Act of 1934 (47 U.S.C. 151 et seq.); (5) a contract for public utility services, including electric light and power, water, steam, and gas; (6) an employment contract providing for direct services to a Federal agency by an individual; and (7) a contract with the United States Postal Service, the principal purpose of which is the operation of postal contract stations. The Chapter 65 exemption referenced therein refers to Supplies requirements. Administering the Purchase card program is honestly the bane of my professional existence...whether it is cardholders splitting purchases, cardholders begging to exempt things from the $2,500 MPT, Ratifications in the $9k-$11k range, and PR's in the $2,500 - $10k range - this eats up SUBSTANTIAL hours of my and other CO's time. If the Services MPT was just uniformly $10k, life would be remarkably easier, and I could spend much less time on these abundant low dollar value requirements. It would also make a lot of sense....so I assume that's not how the regs work, and my Bureau's current policy is right. However, I assume that the comments on my other post were just made in error, and my determinations so far, and my Bureau's leadership's determinations, are in fact correct and many services still have only a $2,500 MPT.
My experiences with an Ordering Officer is limited to sharing an office with the Admin Staff who was appointed as one 10 years ago and reading over the appointment letter as a curiosity. I'm trying to problem solve now for a unit spread over 20 states with 40 offices, 100 employees and a $10K annual office supply budget. In the past, office supply orders for the unit were placed after coming into Acquisition. This solution is taking up too much time for such a small effort (complaints, orders taking "too long", shipping to the wring address and receipts not coming back to the card holder). I reached back into my memory to pull up the Ordering Officer solution, but I can't think of why this would be preferred to simply giving an admin office a Purchase Card and having the unit be responsible for their own supplies. Finally, if there is a request to obligate the dollars up front (No Year Dollars = no Bona Fide needs rules) what is the flaw in writing a NTE contract from a GSA BPA and appointing an Ordering Officer?