Overview
FAR Subpart 13.3 prescribes the policies and procedures for using simplified acquisition methods, which are designed to reduce administrative costs and streamline the procurement process. It covers the use of Governmentwide commercial purchase cards, purchase orders, Blanket Purchase Agreements (BPAs), imprest funds, and specialized forms like the SF 44.
Key Rules
- Governmentwide Commercial Purchase Card: Authorized for making and paying for supplies, services, or construction. While primarily for micro-purchases, agencies are encouraged to use them for higher dollar amounts when authorized under existing contracts.
- Unpriced Purchase Orders: May only be used when it is impractical to obtain pricing in advance (e.g., equipment repairs requiring disassembly) and must include a "realistic monetary limitation."
- Blanket Purchase Agreements (BPAs): These are "charge accounts" established for repetitive needs. They are not contracts and do not obligate the government until an individual purchase is made.
- Competition Requirements: The existence of a BPA does not justify sole-source purchasing. Contracting Officers must still seek maximum practicable competition and prioritize small business set-asides.
- Termination and Cancellation: A purchase order that has been accepted in writing requires a formal termination process; one that hasn't been accepted can be canceled via written notification.
- SF 44 (Purchase Order-Invoice-Voucher): Limited to on-the-spot, over-the-counter purchases where the item is immediately available and the transaction involves a single delivery and payment.
- Imprest Funds: Cash-based transactions are generally capped at $500, while third-party drafts are capped at $2,500 unless specifically authorized.
Responsibilities
- Contracting Officers (COs):
- Reviewing BPA files at least annually to ensure compliance.
- Ensuring unpriced purchase orders are priced in a timely manner.
- Establishing procedures for the use and control of purchase cards.
- Verifying that Electronic Funds Transfer (EFT) clauses are included in purchase orders.
- Designated Individuals (Cardholders/BPA Callers):
- Making purchases within authorized dollar limitations and legal requirements.
- Ensuring receipt and acceptance of supplies or services are properly documented.
- Agencies:
- Establishing internal procedures for purchase card use and control.
- Reviewing the continuing need for imprest funds and third-party draft accounts.
- Providing safeguards for the control of forms like the SF 44.
- Suppliers/Contractors:
- Providing delivery tickets or sales slips for all shipments under a BPA.
- Acknowledging written acceptance of purchase orders when required by the CO.
Practical Implications
- Reduced Administrative Burden: These methods allow the government to bypass the formal and time-consuming "Full and Open Competition" requirements of FAR Part 15, making it easier for small businesses to engage with the government on routine requirements.
- Agility in the Field: Tools like the SF 44 and the Governmentwide purchase card are essential for "away from the office" scenarios, such as emergency repairs or contingency operations, where standard procurement systems are inaccessible.
- Financial Risk Management: Because BPAs do not obligate funds until a "call" (order) is placed, agencies can establish multiple accounts with different vendors to ensure availability without committing their budget upfront.
- Vendor Relationships: For contractors, having a BPA is a competitive advantage but not a guarantee of work; they must remain price-competitive and maintain high past performance to receive individual orders.