Government Purchase Card (GPC)

The GPC is the Governmentwide commercial purchase card. Per FAR 13.201(b) it is the preferred method to purchase and to pay for micro-purchases. It is authorized for making and/or paying for purchases of supplies, services, or construction, and may be used by contracting officers and other designated individuals.

The current micro-purchase threshold is $15,000 (FAR 2.101). The commonly circulated figures of $3,500 and $10,000 are outdated. Reduced thresholds still apply: $2,000 for construction subject to Wage Rate Requirements (Davis-Bacon) and $2,500 for services subject to the Service Contract Labor Standards.

For construction subject to 40 U.S.C. chapter 31, subchapter IV (Wage Rate Requirements / Davis-Bacon Act), the micro-purchase threshold is $2,000. The GPC may be used for construction only up to $2,000, and such purchases must comply with the Wage Rate Requirements clause.

No. The GPC cannot be used to acquire services where the underlying contract is in excess of $2,500, because the Service Contract Labor Standards (McNamara-O’Hara Service Contract Act) apply to service contracts over $2,500.

A split purchase occurs when a cardholder divides a single known requirement into several transactions to stay under an authorized dollar threshold (for example, to keep using the GPC or to avoid sending the requirement to contracting). It is strictly prohibited by FAR 13.003(c)(2). When a known requirement exceeds the MPT, it must be procured on a government contract.

Strictly prohibited. Splitting a known requirement into multiple transactions to stay under the micro-purchase threshold circumvents the authorized dollar limit and is barred by FAR 13.003(c)(2).

Examples include: purchases for personal, family, or household purposes; cash withdrawals or advances; intentional failure to timely pay undisputed travel charges; failing to purchase from mandatory sources; and splitting requirements to avoid card thresholds.

10 U.S.C. 2784 and 2784a, as modified by Public Law 112-194 (the Government Charge Card Abuse Prevention Act of 2012). Employees and Service members who commit charge card violations may face administrative or disciplinary action, up to and including removal; a violation by a person subject to the UCMJ is punishable under Article 92.

Only when use of the GPC is not possible — for example, when a merchant does not accept the card. Convenience checks are a purchasing alternative of last resort, limited to the applicable convenience-check micro-purchase threshold, and they must not be written to vendors who accept the GPC.

Cardholders must satisfy requirements from mandatory sources of supply first — including Federal Prison Industries (UNICOR) for supplies and the AbilityOne Program (Committee for Purchase from People Who Are Blind or Severely Disabled) — before considering non-mandatory sources such as Federal Supply Schedule (GSA) contracts and the open market.

An unauthorized commitment is an agreement that is not binding solely because the Government representative who made it lacked the authority to enter into it on behalf of the Government. Only warranted contracting officers (and properly delegated cardholders acting within their limits) can obligate the Government.

The GPC shall be used only for mission-essential purchases. It shall not be used to split payments or to split purchases to avoid exceeding the authorized limit.

The card may be used by contracting officers and other individuals designated (appointed) in accordance with FAR 1.603-3. It is authorized for making and/or paying for purchases of supplies, services, or construction within the individual’s delegated authority.

The SF-182 (Authorization, Agreement, and Certification of Training) is used to request and document training, and the GPC may be used as the method of payment for commercial training requests using the SF-182 in lieu of an employee reimbursement.

No. Micro-purchases may be made without a small-business set-aside and without obtaining competitive quotations if the purchaser considers the price reasonable. Requirements above the micro-purchase threshold but at or below the simplified acquisition threshold, however, are reserved for small business.

True is the answer the course key expects, and the contingency check limit is still higher than the ordinary one. Note the current DoD figures: the general convenience check micro-purchase threshold is $5,000; for contingency and other emergency uses it is $10,000 inside the United States and $15,000 outside the United States. So $10,000 is now the inside-the-U.S. contingency figure, and an overseas contingency check may run to $15,000.

True. The purchase card is authorized both to make purchases and to pay for them, so when it is used as a method of payment against a contract or order the transaction is a contract action and the FAR and DFARS rules for that action apply - including the mandatory use of Wide Area Workflow's iRAPT module to create and accept the receiving report.

$3,500 is the answer the course key expects, because the course was written when the micro-purchase threshold was $3,500. Note: FAR 2.101 now sets the micro-purchase threshold at $15,000 for ordinary supplies and services, so under the current FAR the ceiling on this buy is $15,000 - subject to the cardholder's own delegated single-purchase limit, which is often lower. Watch the lag: the DoD Government Charge Card Guidebook dated 23 Aug 2024 has not caught up and still prints $10,000 in its Appendix I.

Construction subject to the Wage Rate Requirements statute (formerly the Davis-Bacon Act). FAR 2.101 keeps the micro-purchase threshold at $2,000 for construction subject to 40 U.S.C. chapter 31, subchapter IV, and FAR 22.403-1 requires the prevailing-wage clause in construction contracts in excess of $2,000. That $2,000 figure is unchanged and still current.

$25,000. Training bought on an SF 182 does not run to the micro-purchase threshold: the DoD Government Charge Card Guidebook authorizes GPC payment of training requests using the SF 182 valued at or below $25,000, and the total price of training authorized by a single SF 182 may not exceed $25,000 per DoD FMR Volume 10, Chapter 12, paragraph 120323. That $25,000 figure is current, not a stale course number.

Activity or installation inventories, then Federal Prison Industries (UNICOR), then the AbilityOne Procurement List, then wholesale supply sources - that is the answer the course key expects. Two corrections against the current FAR 8.002(a)(1): the full descending list is (i) inventories of the requiring agency, (ii) excess from other agencies, (iii) Federal Prison Industries, Inc., (iv) supplies on the Procurement List maintained by the Committee for Purchase From People Who Are Blind or Severely Disabled, and (v) wholesale supply sources - so excess from other agencies sits between agency inventories and UNICOR; and the source older courses call NIB/NISH is now the AbilityOne Program. For services, the only mandatory source listed in FAR 8.002 is the AbilityOne Procurement List.

Recovered material - that is, recycled content. Under the Resource Conservation and Recovery Act as implemented at FAR 23.107-1, EPA designates items that are or can be made with recovered materials and recommends recovered-material content levels, and agencies must buy conforming products to the maximum extent practicable. Note the FAR's term of art is recovered material rather than recycled material, and agency affirmative procurement programs must include guidance for purchases of EPA-designated items at or below the micro-purchase threshold.

Intent. Abuse is the intentional use of a Government-issued charge card in violation of applicable regulations; misuse is the unintentional use of the card in violation of applicable regulations, the result of ignorance or carelessness. Both are reportable violations. Internal fraud - a felonious act of corruption or an attempt to cheat the Government - is classified as malicious intent and is the most serious category.

Confirming that funding is available for each account and each purchase. The cardholder must also hold a valid delegation of purchase authority, complete mandatory initial and refresher training, screen and use the required sources under FAR 8.002, and ensure every purchase is proper, legal, economical, and satisfies a bona fide requirement.

The appropriate Financial/Resource Manager. The A/OPC establishes and manages the account profile - transaction limitations, line-of-accounting information, spending limits, and merchant category code limitations - and must ensure spending limits and funding have been coordinated with the Financial/Resource Manager. No GPC or convenience check account may be issued or maintained unless that manager has assigned a valid line of accounting.

False. Purchase cards shall not be issued to contractors at all, and using the GPC to make purchases from contractors or contractor agents who are military personnel or civilian employees of the Government is separately prohibited. Under certain conditions GSA can authorize contractors to establish cards directly with the issuing bank.

True, if warranted in the interests of national security. Commanders and supervisors must ensure a security clearance review is conducted when a cardholder comes under investigation for charge card violations. The clearance review is not itself a disciplinary action, but modification or revocation of a clearance can lead to reassignment or removal for failure to maintain a condition of employment.

Cardholder fraud - internal fraud in the DoD charge card disciplinary categories. Internal fraud is any felonious act of corruption or attempt to cheat the Government, or use of the card to transact business that is not sanctioned, not authorized, not in one's official Government capacity, and not for the purpose for which the card was issued. Splitting the requirement to stay under the limit is separately prohibited by FAR 13.003(c)(2).

Your Agency/Organization Program Coordinator (A/OPC) - the individual responsible for implementing, maintaining, monitoring, and overseeing the GPC and travel card programs under their cognizance. In the DoD hierarchy that is normally the Level 4 A/OPC supporting your activity (Level 5 for Navy and Marine Corps accounts).

Yes. All program officials in PCOLS-deployed organizations must use PCOLS to issue and maintain GPC accounts; where PCOLS has not been deployed the issuing bank's electronic access system is used instead. Use of PCOLS is mandatory unless a waiver has been requested and granted by the Director, Contracting eBusiness (CeB), Defense Pricing and Contracting, OUSD(A&S).

True. PCOLS is CAC-enabled. Note the reason the DoD guidebook gives is secure authentication and nonrepudiation, not the capture of personnel category information; CAC data are separately used by the EMMA application to define purchase card hierarchies and authority chains.

False. All delegates and appointees must countersign their letters to acknowledge they have reviewed, understand, and concur with their GPC program responsibilities. The letter must also state the duties, any dollar limit of the procurement authority, and any limitations on the scope of authority beyond those in law or regulation.

Yes. A GPC transaction that lacks a written item or service request is a self-generated (self-initiated) purchase. The cardholder should document availability of funds at the time of purchase and obtain prior approval before making self-generated purchases, and written independent receipt and acceptance by someone other than the cardholder is then mandatory.

No - you may not take the gift card, but the Government may take the discount. A gift card from a vendor doing business with your agency is a gift from a prohibited source, and the $20-or-less exception at 5 CFR 2635.204(a) expressly does not reach gifts of cash; DoD treats gift certificates and gift cards as cash advances. A price reduction, by contrast, runs to the Government rather than to the employee.

A Government employee other than the cardholder. That employee accepts the good or service to confirm the Government received what the invoice says, affixes a legible signature, printed name, and date to the invoice, packing slip, or other document listing what was ordered, billed, and received, and forwards the supporting documentation to the Approving/Billing Official.

All of the transactions posted to that cardholder's account during the billing cycle. During reconciliation the cardholder reallocates each transaction from the default to an alternate line of accounting where appropriate and approves or disputes each charge.

When the GPC is used as a method of payment against a contract. The contractor generates the receiving report in WAWF, the Government acceptor accepts it in WAWF, and the cardholder verifies acceptance before submitting the invoice for certification. For GPC micro-purchases that deliver accountable property, WAWF use is encouraged but not mandatory.

15 calendar days. If the cardholder does not reconcile and certify within 15 calendar days following the close of the billing cycle, the cardholder is locked out of the file and the Approving/Billing Official or Certifying Officer must step in and perform the reconciliation and certification.

They are a last resort, used only when use of the GPC is not possible; they shall not be written for more than the applicable convenience check micro-purchase threshold; they shall not be written to vendors who accept the GPC; they shall not be used to split payments or purchases; they shall not be used as a method of payment against a contract; and they shall not be used for employee reimbursements.

On a Government contract, by a warranted contracting officer. The SF 182 purchase card route is limited to a regularly scheduled commercial-off-the-shelf course, training conference, or instructional service that is available to the general public and priced the same for everyone in the same category.

The act of approving an unauthorized commitment by an official who has the authority to do so. The head of the contracting activity may ratify unless the agency designates a higher-level official, and the authority may never be delegated below the level of chief of the contracting office. A GPC cardholder may not buy or pay for supplies, services, or small construction in an attempt to cover up an unauthorized commitment.

False. Splitting is strictly prohibited and there is no urgency exception. FAR 13.003(c)(2) forbids breaking a requirement down to permit use of simplified acquisition procedures or to avoid a requirement that applies above the micro-purchase threshold, and the DoD guidebook states that when a known requirement exceeds the micro-purchase threshold it must be procured on a Government contract.

It does not require DoD to make merchants submit reports to identify potential fraudulent purchases. What Public Law 112-194 does require of DoD is: use of effective systems, techniques, and technologies to prevent or identify potential fraudulent purchases; invalidation of the card of any cardholder who leaves the Department, transfers, or separates from active duty; recovery of the cost of illegal, improper, or erroneous purchases, including through salary offsets; appropriate adverse personnel action including dismissal; and periodic DoD Inspector General audits of purchase card and convenience check programs.

Salary offsets.

True. Public Law 112-194 requires that penalties prescribed for employee misuse of purchase cards or convenience checks include dismissal of the employee, as appropriate. DoD policy states civilian personnel may face administrative or disciplinary action up to and including removal from Federal Service, and a violation by a person subject to the UCMJ is punishable as a violation of Article 92.

The PCOLS Data Mining (DM) application. DM programmatically reviews 100 percent of the DoD GPC transactions made by PCOLS-deployed organizations, using intelligent and learning software to identify correlations, patterns, and trends, and its Case Manager assigns the referred transactions to A/BOs and A/OPCs for review.

10 years from the date of final case closure, per DoD FMR Volume 15, Chapter 6. Ordinary GPC transaction-supporting documentation is retained for 6 years in accordance with FAR 4.805.

All of it - proof of delivery, a detailed invoice, and a detailed receipt. The guidebook's examples of GPC transaction-supporting documentation include requests for purchase from the requiring individual, special approvals, order confirmations, invoices, cash register receipts, purchase documents, records of return, waivers, receiving reports or other proof of delivery, and property book entries.

$25,000 inside the United States and $40,000 outside the United States. Older GPC study material lists $20,000/$30,000 or $20,000/$35,000; those figures are superseded. The purchase must have a clear and direct relationship to the contingency operation, the defense against or recovery from a cyber, nuclear, biological, chemical or radiological attack, international disaster assistance, or the emergency or major disaster, and construction subject to the Wage Rate Requirements statute is excluded from the raised threshold.

Yes, in two narrow DFARS cases. An individual appointed under DFARS 201.603-3(a) may use the GPC above the micro-purchase threshold but not above $25,000 when the purchase is made outside the United States for use outside the United States and is for a commercial product or commercial service, subject to a list of exclusions and to seeking maximum practicable competition. Separately, a contracting officer supporting a contingency, humanitarian, or peacekeeping operation may use the GPC above the micro-purchase threshold up to the simplified acquisition threshold when the supplies or services are immediately available and there will be one delivery and one payment.

Yes. FAR 13.201(e) states plainly that the requirements in part 8 apply to purchases at or below the micro-purchase threshold, and the DoD guidebook makes screening and use of required sources under FAR 8.002 a mandatory cardholder responsibility. Failing to follow policies requiring purchases from mandatory sources is a listed DoD charge card violation.

No. Gift certificates and gift cards are considered cash advances and shall not be purchased with the GPC, even to obtain items from merchants that do not accept the card. Cash advances, money orders, and travelers' checks are prohibited for the same reason - cash and near-cash is easily misappropriated - and awarding gift cards triggers IRS Form 1099-MISC reporting for payments to an individual totaling more than $600 in a tax year.

The DD Form 577, Appointment/Termination Record - Authorized Signature. The appointing authority keeps the signed original and provides copies to the offices that certify vouchers; Departmental Accountable Officials' DD Form 577s are retained by the A/OPC for 6 years rather than submitted to DFAS.

The Governmentwide commercial purchase card, for all types of contract actions authorized by the FAR, unless one of the listed exceptions applies - for example, a Deputy Secretary of Defense approved electronic commerce exception, a written determination by a general or flag officer or SES member that no available source accepts the card, performance entirely outside the United States and its outlying areas, an SF 44 purchase for aviation fuel or oil, an overseas contingency transaction, a payment made with an accommodation check or for a transportation bill, or a Federal Supply Schedule contract that does not permit purchase card use.

The guidebook's list, which is not all inclusive and applies to convenience checks too, includes: aircraft fuel and oil (use the AIR Card); appliances acquired for personal use in a work environment; bail and bond payments; betting, casino gaming chips, and off-track betting; cash advances including money orders and travelers' checks; construction services over $2,000; purchases from contractors or contractor agents who are Government military or civilian employees; court costs, alimony, and child support; foreign currency; gift certificates and gift cards; and Kaspersky Lab hardware, software, or services. If a valid requirement has already resulted in a Government contract, the GPC may still be used as a method of payment against that contract even for an otherwise prohibited item.