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Focus in FY2025: Who are the Buyers for the Government?

shaunaweatherly

The word "buyer" gets thrown around a lot in the GovCon sector. But who are the buyers for the Government?


Answer? It depends.


There are a few key parameters that dictate if a Federal employee is a "buyer" or not:

▶️ The role of the individual "buyer" (again, an often misused term when talking about roles and who does what in the Federal acquisition process),

▶️ The total aggregate dollar value of the action, AND

▶️ The authority granted to that individual to obligate the government.


(Before reading more, and to learn more about the players / roles in the Federal acquisition process, check out this past FedSubK Feature, "Hate the Game, Not the Players - Know the Roles in Federal Contracting".)


Let's talk about each of those key parameters above.


First, "buyer" is a loose term not used in the Federal acquisition process because it's not specific enough to the roles that occur and the work performed. It's taken from private industry and used by GovCon's to oversimplify the process. "Buyers" in Government can be--


▶️ Any Government employee that has been issued a Governmentwide Purchase Card (GPC or "p-card). There are over 705,000 "GPC holders" (their official title for that role).


▶️ Procurement Assistants, administrative support staff of a contracting office.


▶️ Purchasing Agents, the lower graded employees in a contracting office that may also hold a GPC but have no other authority and support others on the simpliest buys. You don't see this role often anymore.


▶️ Contract Specialists -- journeymen who do most in the acquisition except they don't have authority to making Contracting Officer decisions or enter into / sign contracts.


▶️ Contracting Officers (COs in civilian agencies and KO in DoD), a Contract Specialist who has been granted specific decision-making and signature authority by means of a Contracting Officer Warrant.


▶️ Ordering Officers, a Contracting Officer or other trained individual granted written authority to place orders under existing contracts (like GWACs).


▶️ Administrative Contracting Officer (ACO), a Contracting Officer that can only perform administrative post award actions that do not impact the terms and conditions of the overall contract.


Notice that in the descriptions above not everyone makes buying decisions; that is reserved for the GPC holder at or below the micro-purchase threshold and the CO/KO, OO, or ACO for everything else; a select group with written authority. These are your "buyers".


BUT... decision making also extends to levels above the Contracting Officer, based on the dollar value of the action. The CO/KO is not always the final decision-maker and having "approval authority" is not the same thing as having "procurement authority" by means of a formal written instrument (a "warrant") which grants signature authority to sign contracts. Approvers are not "buyers" because they don't have that written authority to obligate the Government (aka, sign contracts). They are there strictly for oversight.


And let's talk a tad about "buyer's preferences" here for a moment. Buyers may seem to have "preferences" BUT...


What you are really seeing is an overall agency preference because every buy--YES, EVERY BUY--goes through a review process.


The basic review includes:

  • Acquisition Strategy -- Completed regardless of dollar value to ensure the purchase strategy is sound and the purchase is for an official use. Documentation is simplified and dependent on the complexity of the purchase.

  • Acquisition Plan (FAR 7.105) -- Formal process that addresses a review of the mission need (to include history of the need); acquisition milestones; conditions impacting the purchase; life-cycle, design-to-cost, and should-cost; delivery; risks; acquisition streamlining; sources; competition; selection of contract type; selection procedures; budgeting and funding; priorities, allocations, and allotments; contractor versus Government performance; inherently governmental functions; management information requirements; make or buy analyses; tests and evaluation; logistics considerations; government-furnished property; government-furnished information; environmental and energy conservation objectives; security considerations; contract administration; and other implications like foreign sales, special requirements, the Defense Production Act, the Occupational Safety and Health Act, industrial readiness, and more.


GPC holders and COs/KOs, OO, and ACOs have every action reviewed even when they are the decision-maker, which at a minimum is a peer review or supervisory review.


P-Card buys are reviewed by the supervisor and Approving Official (if not the supervisor) at a minimum to ensure the purchase is for official use and funds are available to make the purchase.


All actions over the Simplified Acquisition Threshold (SAT, presently $250,000 and proposed to increase to $350,000 by 10/1/2025) require this more formal written Acquisition Plan. Review and concurrence is required by the Requiring Activity, Contracting Officer, Contracting Chief / Director, Small Business Technical Advisor, Office of Small Business Utilization, Chief Financial Office / Budget Officer, Chief Information Officer (as required for IT purchases), and Office of the General Counsel, along with any other personnel up to, and including, the Head of the Contracting Activity (HCA), depending on the dollar value. Some agencies also have Capitol Investment Boards and/or additional business case requirements for major systems investments and/or the procurement of contracts for Governmentwide use (i.e., OMB's "Best in Class" or GWAC contracts).


As you can see, being a "buyer" is not mean a single person can make the decision to expend funds; there is review and accountability, even for Contracting Officers with unlimited signature authority, as I was during my career. Federal contracting is NEVER done in a vacuum and the "buyer" is not the ultimate decision-maker.


Now you know when you hear the word "buyer" who that is and that they alone rarely make the purchase decision.


(Copyright 2/3/2025, Federal Subcontract Solutions LLC)

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