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Do all GSA Advantage purchases necessarily use an FSS?


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The Navy recently came out with NAVSUPINST 4200.99D regarding use of the GPC. A delegation table in the instruction states that a CH needs a special designation to order from Federal Supply Schedules. 

Aside from open market items, are all purchases on GSA Advantage necessarily FSS orders? We use GSA Advantage quite a lot and now it seems that we must stop using it completely unless we obtain special designations for our Cardholders. (We have purchase authority up to MPT).

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There is a list of rules posted.  

Quote

16.  Abbreviations are to be kept to a minimum--preferably none at all--so that others can interpret a post and respond to it intelligently.

I searched for NAVSUPINST 4200.99D and could not find it using Google.

GPC?  Government Purchase Card?  

           Green Procurement Compilation?

CH??????

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5 hours ago, bob7947 said:

There is a list of rules posted.  

I searched for NAVSUPINST 4200.99D and could not find it using Google.

GPC?  Government Purchase Card?  

           Green Procurement Compilation?

CH??????

My oversight, apologies. The instruction was published very recently and isn't widely available (at least not yet) outside the DON or to people without DON CCPMD website access. NAVSUPINST 4200.99D, Department of the Navy Government Purchase Card Program Policy, 15 Feb 2024. Thank you.

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No, GSA Advantage includes items on Federal Supply Schedules (FSS), Federal Strategic Sourcing Initiative (FSSI) Blanket Purchase Agreements (BPAs), and GSA Global Supply.

In the FAR FSS and FSSI fall under 8.004(a)(1) as an "other source".  The Army calls these non-mandatory Government sources.

In the FAR GSA Global Supply falls under 8.002(a)(1)(v), "Wholesale supply sources, such as stock programs of the General Services Administration (GSA) (see 41 CFR 101-26.3)", and is a mandatory source.  GSA Global Supply is also considered an inter/intra governmental source.

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On 4/4/2024 at 6:43 PM, Goldenreef said:

a CH needs a special designation to order from Federal Supply Schedules

My impression is that someone discovered that FAR 1.603-3(b) says that "Agency heads are encouraged to delegate micro-purchase authority [and] Individuals delegated this authority are not required to be appointed on an SF 1402" and that per FAR 13.201 micro-purchases must be made using Part 13/Simplified Acquisition and so cannot be made using Part 8, or 16.5 for that matter. So basically the standard micro-purchase authority delegated to cardholders only enables them to make purchases using Part 13, and they would need separate authorization (either using something like that special designation you reference, or even requiring an SF 1402 depending on the card-issuing authority's interpretation) to order via GSA or any IDIQs. The only loophole I found (to my agency's interpretation, which was that an SF 1402 was required for a cardholder to place any order at any value via GSA or a GWAC/MAC/other IDIQ) was to establish non-GSA BPAs (or BOAs or BAs) for cardholders to order against under Part 13.

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