The simple answer is "No". The Federal Acquisition Regulation (FAR) prohibits Contracting Officers (COs/KOs) from intentionally splitting a single requirement into two or more separate requirements to circumvent acquisition thresholds. It may be considered a violation of the Procurement Integrity Act, it is likely considered an ethics violation, and it may also be a violation of the laws upon which many thresholds are based, (i.e., Small Business Act, etc.). It is a HUGE "no-no" and contracting officers or agencies that habitually try to circumvent procurement thresholds may lose their procurement authority.
Here is a simple real life example:
A Project Manager is asked to buy a $26,000 trailer for their customer. It is the end of the FY and the Contracting shop isn't taking purchase orders for processing again until after September 30th. The PM held a purchase card with a $10,000 single transaction limit; the micro-purchases threshold (MPT) is $10,000. The PM decides to use her card and has the trailer vendor charge her card twice for $10,000 and once for $6,000. This purchase splits the requirement into three smaller purchases in order to circumvent her purchase card single transaction limit and micro-purchase threshold.
The Army Criminal Investigation Division agent showed up at my desk a couple months later (yes, I'm the one who turned this PM away at the end of the FY). He asked, "Do you know of an instance where a single flatbed trailer could be delivered in three parts?" He then clarified he was referring to three charges made to the PM's card to purchase the trailer. The PM said she felt pressured by the customer to spend their remaining one-year money at the end of the FY. Because I had turned down her request, she decided with the aid of the customer's budget office, to split the requirement and intentionally circumvent her card limit and the purchase threshold.
The PM was suspended without pay for a month and lost her purchase card privileges permanently.
So why do some agencies seem to split requirements? Well, there are ways around the "rule". We all know that everyone does things a little different -- which we all LOVE, right? (Not.) Here are a few examples of how an agency can seem to split a purchase and it is legit:
▶️ Classifying the same purchase funded with different funding streams as separate requirements by funding stream.
▶️ Classifying severable products and services (those that when purchased separately still have value without the other parts of a known requirement being purchased at the time time) as separate requirements.
▶️ Classifying the same purchase but at multiple locations as separate requirements by geographic location.
▶️ Classifying the same purchase but with multiple delivery points as separate requirements by delivery point.
If the agency has "cover" by either an inculcated agency buying process, a set of contractual vehicles with terms that allow this type of buying, or legal concurrence on this determination of what constitutes a requirement given the product or service being purchased, it is likely allowable and legal. Then the battle becomes agency culture, and that's one battle that is not easily won.
Bottom line is....please please please...as a small business, I know you are looking for avenues to find opportunities. But DO NOT suggest that agencies find ways to circumvent acquisition thresholds. Some "green" COs should know better but often don't. With those COs that do understand it can leave a lasting negative impression that can jeopardize your future opportunities with that agency, erode any trust in your company, and you could face other fall out -- particularly if you are a participant in an SBA Federal contracting assistance program like the 8(a) program.
(P.S. The purchase card example with the trailer actually happened twenty years ago when the micro-purchase threshold and card limits were at the lower $3,000 and the trailer cost $9,000. The current threshold and limit was used for this story so not to confuse folks on the current micro-purchase threshold and single purchase card limit.)
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