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Training requirement (individual or class), micropurchase for training and split purchases


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There is a training requirement of $50K that will be attended by 10 Government employees from various offices.  My argument is that the requirement is each individual person attending this class, with a separate SF182.  The micro-purchase threshold for training is $25K.  If the class is being split into multiple purchases because the class is the requirement I would say that is a split, but my assertion is that the requirement is each individual SF-182 and that 10 credit card swipes of $2,500 is not splitting the purchase and should be acceptable.

Please give me your thoughts.

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54 minutes ago, Scott1580 said:

Yes, this is a foreign concept to my district and myself.  I am not sure how to go about informing them of that.  Will look around unless you had a few links you could direct me to.

Go to https://www.opm.gov/faqs/topic/training/index.aspx and click on " What is the spending limit for the SF-182?"

The OPM Training Policy Handbook is in revision at present and is not available on the OPM website.

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Agencies have different policies.  Some use the approved SF-182 as the obligating document and have their FM office obligate funds and make payment from that obligation by EFT.  It does not go through contracting or a purchase cardholder. 

If it does go through a non-warranted cardholder, the question is whether or not the SF-182 is the obligating document.  If it is the obligating document, the cardholder is then only using their card as a payment method, not as a contracting method.  I would recommend checking your agency policy regarding who can process payment using a purchase card.  Some agencies limit this to contracting officers.  Whether it is process as one payment or multiple payments should not be an issue with regarding to breaking down requirements in violation of FAR 13.003(c)(2).  If the cardholder is making the purchase (obligation) and payment then breaking down the transaction would run afoul of FAR 13.003.

Also, I did some research on the whole issue of using SF-182's vs contracting processes and looked into the OPM guidance, which is no longer their latest guidance last time I checked.  Their latest guidance says to contact contracting and I don't think folks can rely on OPMs prior guidance in an archived handbook.  See the following thread where I discussed this issue in more detail. 


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Guest Vern Edwards

Here is the OPM guidance on the use of SF 182 to acquire commercial training. The emphasis is added.


Use of the Training Authorization Form

Agencies may use an authorized training form to procure and certify payment of training expenses through Government or non-Government facilities. The form is certified by training officials and supervisors instead of the contracting officer under a procedure negotiated by the two offices and addressed in the agency's administrative directives. Comp. Gen. B-210334 (July 14, 1983).

Under typical negotiated procedures, the Training Authorization Form (SF-182) or equivalent is authorized for use to obligate funds, contract for training, and certify payment of approved training expenses under the following conditions: 

  1. the training cost of a single training event, program, or instructional service does not exceed the simplified acquisition process dollar limit established by U.S. General Services Administration; 

  2. the cost is of a fixed nature, i.e., price per student or price per course, program, or service; and 

  3. the program, course, or instructional service is off-the-shelf and no modification or development resulting in increased cost to the Government is needed to meet the organization's needs. 

The Training Authorization Form is also used for requesting, approving, and certifying payment for attendance at meetings, conferences, seminars, and symposia where the primary purpose is to train an employee to meet a performance improvement related need. The form is not used to purchase general supplies, training equipment, or non-training services. 

When an agency training course or program requires new design and development, the authorized contracting officer contracts for the service on behalf of and as requested by the responsible training or management official.


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