Threshold | The Contracting Education Academy

November 19, 2018 By AMK

How contracting officers want to use the new micropurchase threshold

Steve Kelman’s recent talk with feds reinforced his view that a $10,000 micropurchase limit opens up vast new acquisition possibilities.

Recently I did a webinar at the request of the General Services Administration’s Acquisition Gateway for professional services, as part of their Spotlight training series, on the new micropurchase threshold. As I have blogged before, the threshold has been raised to $10,000 for civilian agencies and, through a strange anomaly that hopefully will be corrected soon, to $6,000 for the Department of Defense.

This change will allow agencies to make procurements of up to $10,000 without (if they choose) competitively soliciting or evaluating proposals, though some of the agencies that have started using the authority have chosen to develop one-page requirements statements and solicit one-page competitive proposal. Regulations implementing this change are unfortunately not out yet, but a number of agencies — including the Department of Veterans Affairs, the Department of Homeland Security and GSA itself — have received class deviations to introduce the change now. However, the GSA class deviation applies only to GSA’s own purchases, not more broadly for any purchases using GSA vehicles.

Keep reading this article at: https://fcw.com/blogs/lectern/2018/11/kelman-micropurchase-ideas.aspx

September 10, 2018 By AMK

DoD’s micropurchase threshold just increased to $10,000

The Department of Defense has issued a class deviation raising the micro-purchase threshold to $10,000, effective immediately.

The increase implements Section 821 of the 2019 National Defense Authorization Act, which was signed into law last month.

The memo explains that there are a few exceptions to the standard $10,000 threshold.

Keep reading this article at: http://smallgovcon.com/statutes-and-regulations/dod-increases-micro-purchase-threshold-to-10000-effective-immediately/

To see a handy table of current purchasing thresholds, click here: Purchasing Thresholds – September 2018

July 26, 2018 By AMK

The rise of the microconsultants

One of the first — and even more than two decades later, still one of the most important — changes during the procurement reform era of the 1990s was the introduction of a “micropurchase” authority in the Federal Acquisition Streamlining Act of 1995.

In the background was the desire to allow program customers the ability to use a government credit card to make very small purchases directly, without the significant extra time (think of the purchase order request landing at the bottom of the contracting person’s in-box) and administrative cost that come with working through the contracting office.

An interesting backstory to this statutory change was the role of a young contract specialist at the Department of Health and Human Services named Michelle Craddock in helping develop the administration’s legislative proposal on this. Even before the 1995 law, the government could make purchases under $2,500 without going through a competition. Having just arrived in Washington in 1993 to become administrator of the Office of Federal Procurement Policy, I was tasked with trying to find out if there were any statutory barriers to using a credit card for under-$2,500 purchases. On a learning tour of contracting offices to prepare me for my job as a Washington outsider awaiting Senate confirmation, Craddock was one of the contracting people I met in a visit set up by the HHS senior procurement executive.

Keep reading this article at: https://fcw.com/blogs/lectern/2018/07/kelman-microconsulting.aspx

May 11, 2018 By AMK

FAR rule implements higher dollar threshold for GAO’s protest jurisdiction over DoD, NASA, Coast Guard task orders

In a new rule announced May 1, the FAR Council implemented prior statutory changes to GAO’s bid protest jurisdiction.

For task orders issued by the Department of Defense, NASA, or the Coast Guard, the rule provides that GAO will have jurisdiction only over task orders “valued in excess of $25 million.”

For civilian agencies, GAO continues to have jurisdiction over protests of task orders “valued in excess of $10 million.” The rule also permanently repeals a pre-existing FAR clause that had set a September 30, 2016 expiration date on the ability to protest civilian agency task orders.

The new rule — codified as FAR 16.505(a)(10) — implements Section 835 of the National Defense Authorization Act for Fiscal Year 2017, which directed the FAR Council to establish the new DoD, NASA, and Coast Guard threshold. (The sunset date for protests of civilian agency task orders had previously been repealed by the GAO Civilian Task and Delivery Order Protest Authority Act of 2016.) According to the FAR Council, its new rule is designed to “follow[] the statute exactly.”

Keep reading this article at: https://www.insidegovernmentcontracts.com/2018/05/new-far-rule-implements-increased-minimum-dollar-threshold-for-gaos-protest-jurisdiction-over-dod-nasa-and-coast-guard-task-orders/

February 22, 2018 By AMK

Higher limits on micropurchase, simplified acquisition thresholds okayed by CAAC

The Civilian Agency Acquisition Council (CAAC) has authorized federal agencies to issue class deviations from the Federal Acquisition Regulation (FAR) to raise the dollar thresholds on micropurchases and simplified acquisitions.

The higher thresholds are $10,000 for micropurchases (up from $3,500) and $250,000 for simplified acquisitions (up from $150,000). Authority for these changes stems from the 2018 National Defense Authorization Act (NDAA).

The CAAC’s memorandum can be downloaded here: Class Deviation – Micropurchase and Simplified Acquisition Threshold – CAAC Letter 02.16.2018

The CAAC memorandum “is effective immediately, and remains in effect until the increased thresholds are incorporated into the FAR or is otherwise rescinded.” The FAR Council has opened FAR Case 2018-004 to address what the 2018 NDAA has to say about these thresholds, and the CAAC memo authorizes civilian agencies to adopt their own class deviations while the FAR Case is pending.

CAAC members are senior procurement professionals within 15 departments and agencies:

Department of Agriculture
Department of Commerce
Department of Energy
Department of Health and Human Services
Department of Homeland Security
Department of the Interior
Department of Labor
Department of State
Department of Transportation
Department of Treasury
Department of Veterans Affairs
Environmental Protection Agency
General Services Administration
Small Business Administration
Social Security Administration

The Council is responsible for: Assisting the General Services Administration in developing and maintaining the FAR System by developing or reviewing changes to the FAR; Soliciting the views of agencies, associations, and other interested parties on those proposed changes to the FAR; and Coordinating its activities with the Defense Acquisition Regulations Council (DARC).

GSA, itself, has already issued a class deviation raising the micropurchase and simplified acquisition thresholds on GSA contracts. It can be seen here: GSA Class Deviation 2018-01 MPT and SAT Increase

Steve Kelman’s recent talk with feds reinforced his view that a $10,000 micropurchase limit opens up vast new acquisition possibilities.

The Department of Defense has issued a class deviation raising the micro-purchase threshold to $10,000, effective immediately.

One of the first — and even more than two decades later, still one of the most important — changes during the procurement reform era of the 1990s was the introduction of a “micropurchase” authority in the Federal Acquisition Streamlining Act of 1995.

In a new rule announced May 1, the FAR Council implemented prior statutory changes to GAO’s bid protest jurisdiction.

The Civilian Agency Acquisition Council (CAAC) has authorized federal agencies to issue class deviations from the Federal Acquisition Regulation (FAR) to raise the dollar thresholds on micropurchases and simplified acquisitions.

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