Question 1

What is the Government Purchase Card (GPC) and what is it the preferred method for?

Accepted Answer

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. [Source: FAR 13.201, General — micro-purchases (acquisition.gov) — "The Governmentwide commercial purchase card shall be the preferred method to purchase and to pay for micro-purchases." https://www.acquisition.gov/far/13.201]

Question 2

What is the current micro-purchase threshold (MPT) for the Government Purchase Card?

Accepted Answer

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 The commonly circulated figures of $3,500 and $10,000 are outdated.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. [Source: FAR 2.101, Definitions (acquisition.gov) — "Micro-purchase threshold means $15,000, 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" https://www.acquisition.gov/far/2.101]

Question 3

What is the micro-purchase threshold for construction subject to the Wage Rate Requirements (Davis-Bacon Act)?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "Construction Services over $2,000. FAR 22.403-1 addresses application of the Davis-Bacon Act... contracts in excess of $2,000 ... for construction, alteration, or repair ... of public buildings or public works within the United States, shal" https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 4

Can the GPC be used to buy services when the underlying contract exceeds $2,500?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "Services Acquisitions Greater than $2,500. The GPC cannot be used to acquire services where the underlying contract is in excess of $2,500." https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 5

What is a split purchase and why is it prohibited?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "Making split purchases with the GPC to circumvent purchase limits is prohibited by FAR Subpart 13.003(c)(2). A split purchase occurs when a CH splits a known requirement at the time of the purchase into several transactions in order to circ" https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 6

Splitting an $11,000 requirement into two GPC transactions each under the micro-purchase threshold is:

Accepted Answer

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). [Source: FAR 13.003, Policy (acquisition.gov) — "Do not break down requirements aggregating more than the simplified acquisition threshold ... into several purchases that are less than the applicable threshold merely to permit use of simplified acquisition procedures." https://www.acquisition.gov/far/13.003]

Question 7

What are some examples of DoD-issued charge card violations?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "Examples of DoD-issued charge card violations include, but are not limited to: (a) purchases for personal, family or household purposes, (b) cash withdrawals or advances, (c) intentional failure to pay undisputed travel charges in a timely " https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 8

What law governs corrective action for Governmentwide Commercial Purchase Card program violations?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "In accordance with 10 U.S.C. 2784 and 2784a (as modified by Public Law 112–194, Government Charge Card Abuse Prevention Act of 2012), Government employees and members of the armed services who commit charge card violations may be subject to" https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 9

When is it appropriate to use a convenience check instead of the GPC?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "Convenience checks provide a purchasing alternative to GPC transactions and formal contracting, and they are to be used only when the use of the GPC is not possible ... Convenience checks shall not be written to vendors who accept the GPC." https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 10

Before making an open-market purchase, what sources must a cardholder consider first?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "Then, in accordance with FAR 8.004, consider use of non-mandatory sources such as Federal Supply Schedule (FSS) contracts/BPAs (e.g., GSA Advantage); Governmentwide acquisition contracts." https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 11

What is an unauthorized commitment?

Accepted Answer

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. [Source: FAR 1.602-2, Responsibilities (acquisition.gov) — "Contracting officers may bind the Government only to the extent of the authority delegated to them." https://www.acquisition.gov/far/1.602-2]

Question 12

What is the primary purpose limitation on GPC use?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "The GPC shall be used only for mission-essential purchases. The GPC shall not be used to split payments or to split purchases to avoid exceeding the authorized limit." https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 13

Who may be authorized to use the Governmentwide commercial purchase card?

Accepted Answer

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. [Source: FAR 13.301, Governmentwide commercial purchase card (acquisition.gov) — "The Governmentwide commercial purchase card is authorized for use in making and/or paying for purchases of supplies, services, or construction. The card may be used by contracting officers and other individuals designated in accordance with" https://www.acquisition.gov/far/13.301]

Question 14

What is the correct form for purchasing training with the GPC?

Accepted Answer

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. [Source: DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (23 Aug 2024, OUSD(A&S)/DPC) — "Payments Using ... the SF-182 Training Request" https://www.acq.osd.mil/asda/dpc/ce/pc/docs/guides-docs/Posted_DoD_Govt_Charge_Card_Guide_8-23-24.pdf]

Question 15

Are purchases at or below the micro-purchase threshold required to be set aside for small business or competed?

Accepted Answer

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. [Source: FAR 13.003, Policy (acquisition.gov) — "Acquisitions of supplies or services that have an anticipated dollar value above the micro-purchase threshold, but at or below the simplified acquisition threshold, shall be set aside for small business concerns." https://www.acquisition.gov/far/13.003]

Government Purchase Card (GPC)

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