GPC Frequently Asked Questions

 

Government Purchase Card

The Government Purchase Card (GPC) mission is to streamline payment procedures and reduce the administrative burden associated with purchasing supplies and services. The GPC provides “on the spot” purchasing, receiving, and payment authority for individuals other than contracting or purchasing officers. DFAS eSolutions GPC Program helps to develop and maintain an interface for automated receipt and processing of GPC invoices.

 

Regulations and Procedures
Department of Defense

Department of Army

• GPC Program Army GPC Guidebook
• EDI Reject Procedures - Coming Soon
• Year-End Procedures (Annex N) – Coming Soon

Department of Navy (USN and USMC) GPC Program

• DON GPC Program
• DON procedures and polices
• USMC policies and procedures specific for the Government Commercial Purchase Card Program (GCPC)
• DON CitiBank online training
• Purchase Card Policy Notices

Department of Air Force GPC Program

• Policies

Defense Agencies and DFAS

• DFAS 4200.2-I
• DFAS Manual 7097.01

Other Related Links

Federal Acquisition Regulation (FAR) Information

Frequently Asked Questions

Question: What is a micro-purchase?

Answer:  A micro-purchase is an acquisition of supplies or services using simplified acquisition procedures, the aggregate (total) amount of which does not exceed the micro-purchase threshold.

Reference:  Federal Acquisition Regulation (FAR) Part 2.101 and the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs

 

Question: What are the micro-purchase thresholds?

Answer:  “Micro-purchase threshold” means $10,000 (10 U.S.C. 2338), 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. chapter 67, Service Contract Labor Standards, $2,500;

      (3) For acquisitions of supplies or services that, as determined by the head of the agency, are to be used to support a contingency operation; to facilitate defense against or recovery from cyber, nuclear, biological, chemical or radiological attack; to support a request from the Secretary of State or the Administrator of the United States Agency for International Development to facilitate provision of international disaster assistance pursuant to 22 U.S.C. 2292 et seq.), or to support a response to an emergency, or major disaster (42 U.S.C. 5122), as described in 13.201(g)(1), except for construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction) (41 U.S.C. 1903)

              (i) $20,000 in the case of any contract to be awarded and performed, or purchase to be made, inside the United States; and

              (ii) $30,000 in the case of any contract to be awarded and performed, or purchase to be made, outside the United States.

      (4) For acquisitions of supplies or services from institutions of higher education (20 U.S.C. 1001(a)) or related or affiliated nonprofit entities, or from nonprofit research organizations or independent research institutes—

              (i) $10,000; or

              (ii) A higher threshold, as determined appropriate by the head of the agency and consistent with clean audit findings under 31 U.S.C. chapter 75, Requirements for Single Audits; an internal institutional risk assessment; or state law.

The following table lists the current MPTs applicable to DoD.

 

GPC Micro-Purchases
	Function	Threshold	Authority
1	Federal-Wide Open Market	$10,000	FAR 2.101, FAR 13.2
2	Construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction)	$2,000	FAR 2.101, FAR 13.2
3	Services subject to 41 U.S.C. chapter 67, Service Contract Labor Standards	$2,500	FAR 2.101, FAR 13.2
4	GPC Contingency (Inside U.S.)	$20,000	FAR 2.101, DFARS 213.270(c)(3), DFARS PGI 213.201
5	GPC Contingency (Outside U.S.)	$30,000	FAR 2.101, DFARS 213.270(c)(3), DFARS PGI 213.201
6	Federal-Wide Higher Education Open Market	$10,000 or greater	Class Deviation 2018-O0018
7	GPC Convenience Checks (General – Unrelated to Contingency and Other Emergency Uses)	$5,000	P.L. 115-91, National Defense Authorization Act for Fiscal Year 2018, Sec. 806(b)
8	GPC Convenience Checks for Contingency and Other Emergency Uses (Inside U.S.)	$10,000	P.L. 115-91, National Defense Authorization Act for Fiscal Year 2018, Sec. 806(b)
9	GPC Convenience Checks for Contingency and Other Emergency Uses (outside U.S.)	$15,000	P.L. 115-91, National Defense Authorization Act for Fiscal Year 2018, Sec. 806(b)

References:  Office of the Under Secretary of Defense (Acquisition and Sustainment) Policy Memorandum, “Government-wide Commercial Purchase Card Guidance Related to Class Deviation 2018-O0018 dated August 31, 2018,” 21 September 2018 and the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs

 

Question: I need to purchase supplies exceeding the micro-purchase threshold. Can I split the purchase?

Answer:  No. If the Cardholder (CH) has a requirement exceeding the micro-purchase threshold, the requirement must be sent to the appropriate contracting office for action.

References:  FAR Part 2.101 and the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs

 

Question: I need to purchase some personal items for my home. Can I use the GPC to make the purchases and then pay the bank with a money order or my personal check?

Answer:  No. The GPC is only for official, mission-related Government purchases. It cannot be used for personal expenses of any kind. As stated in Section 2.3.5 of the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, use of the GPC for purchases for personal, family or household purposes is a violation and will not be tolerated.

References:  FAR 13.301, Governmentwide commercial purchase card; and the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs.

 

Question: Can Agency/Organization Program Coordinators (A/OPCs) issue GPCs to contractors?

Answer:  No. A/OPCs shall not issue GPCs to contractors.

However, the General Services Administration (GSA) Contracting Officer for SmartPay® may issue credit cards to contractors to purchase GSA sources of supply or services under cost-reimbursable contracts. The Contracting Officer responsible for the cost-reimbursable contract must authorize the contractor in writing to use GSA sources of supply or services. The contractor must submit a copy of the written authorization and a Request for Eligibility Determination to the GSA SmartPay® Contracting Officer before GSA will issue a SmartPay® credit card to the contractor.

References:  FAR 1.603, DFARS 201.603-3, Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, and GSA SmartPay® website.

 

Question: Can I use PayPal for GPC purchases?

Answer:  Purchases made through a third-party-payment merchant are authorized only when they are unavoidable. Where it is identified that a purchase will be processed via a third-party-payment merchant, Cardholders are required to make every attempt to choose another merchant, and Approving/Billing Officials are required to ensure there is adequate supporting documentation showing there was a detailed review of the purchase and that the use of the third-party-payment merchant was unavoidable.

Caution:  Third-party-payment merchants such as PayPal are considered high-risk transactions for both audits and data mining screening.

Note: Third-party payments mask the name of the actual merchant, thereby circumventing Merchant Category Code (MCC) blocking as an effective internal control and potentially allowing payments to counterfeit operations and other questionable merchants while losing valuable GPC data.

Reference:  Office of the Under Secretary of Defense (Acquisition, Technology and Logistics) Policy Memorandum, “Use of Third Party Payments – Policy Change” dated 17 October 2007

 

Question: Can I purchase seasonal decorations and Christmas cards with my GPC?

Answer:  Check your Service/Agency policy.

In 1987, the Government Accountability Office (GAO) overruled 52 Comp. Gen. 504, concluding that the rules for office decorations should be the same whether the decorations are seasonal or permanent (67 Comp. Gen. 87, 1987). Thus, seasonal decorations are permissible “where the purchase is consistent with work-related objectives [such as enhancement of morale], agency or other applicable regulations, and the agency mission, and is not primarily for the personal convenience or satisfaction of a government employee” (Id. at 88. See also B-226781, Jan. 11, 1988). The rationale of 67 Comp. Gen. 87 does not apply to Christmas cards, which remain “basically individual good will gestures and are not part of a general effort to improve the work environment” (Id. See also B-247563.4, Dec. 11, 1996).

References:  52 Comp. Gen. 504, 67 Comp. Gen. 87, and GAO B-226781 and B-247563.4.

 

Question: Can I purchase flowers for ceremonies with my GPC?

Answer:  Check your Service/Agency policy. Is the ceremony a traditional groundbreaking expense or a dedication for the laying of a cornerstone in public buildings?

For example, in GAO B-158831, June 8, 1966, the cost of flowers used as centerpieces at a dedication ceremony was held to be a proper expenditure (See also B-247563.4, Dec. 11, 1996, regarding a floral centerpiece at an awards ceremony). Similarly, the cost of engraving and chrome-plating a ceremonial shovel used in a groundbreaking ceremony was viewed as a necessary expense of the ceremony in 53 Comp. Gen. 119 (1973). In the cited decision, however, the voucher could not be paid because there was no evidence as to who authorized the work, where the shovel originated, the subsequent use to be made of the shovel, and why there was a year's delay between the ceremony and the engraving.

Agencies should develop policy in alignment with the GAO decisions to ensure uniformity in the use of appropriations to purchase flowers, groundbreaking shovels, etc. for traditional ceremonies and dedications.

Note:  These items remain the property of the Government and may not be given away as gifts or door prizes.

References:  GAO B-158831 and B-247563.4

 

Question: Can I purchase kitchen appliances for the office with my GPC?

Answer:  Check your agency policy. GAO B-302993, June 25, 2004, stated that agencies should develop an agency policy to ensure uniformity in the use of appropriations to acquire kitchen appliances and determine the usefulness of appliances such as these in light of operational benefits, such as employee health and productivity, and the responsibility to provide a safe work environment.

Reference:  GAO B-302993

 

Question: Can I purchase bottled water with my GPC?

Answer:  Special drinking water may be purchased with appropriated funds in situations where water supply systems providing service to DoD organizations do not meet the standards prescribed in 40 CFR, Part 141, National Primary Drinking Water Regulations, Subpart C, only when it is necessary from the Government’s standpoint, such as when:

• The public water is unsafe for human consumption.
• There is an emergency failure of the water source on the installation.
• There is a temporary facility with no drinking water available within a reasonable distance.
• There is no water fit for drinking purposes available without cost or at a lower cost to the government.

Consult agency policy and coordinate with facilities personnel to ensure the GPC file contains documentation stating the drinking water is non-potable, along with a public announcement or a copy of the water testing results. Obtain written coordination from the agency Judge Advocate General/General Counsel and confer with an agency Financial/Resource Manager to ensure proper funds are in place.

References:  40 CFR, Part 141, Subpart C, Monitoring and Analytic Requirements; and GAO decisions B-247871, April 10, 1992; B-324781, December 7, 2013; B-310502, February 4, 2008; and B-318588, September 9, 2009.

 

Question: I ordered some supplies, and a $25 gift certificate was attached to the invoice. There is no name on the gift certificate. Can I use this gift certificate for my personal use?

Answer:  No. U.S. Government funds paid for the supplies, as well as any gift certificates, items, rebates, etc. are the property of the U.S. Government. Check your Service/Agency policy on the appropriate process to handle these items.

 

Question: When must Delegation of Authority Letters be reissued?

Answer:  Delegation of Authority Letters shall be reissued when there is a change to any part of the Delegation of Authority Letter; e.g., name, single purchase and monthly limits (even if the change is for one purchase/payment); monthly limits, etc. The Delegation of Authority Letter is a binding authorization and requires an original acknowledgment signature and date from the individual being issued the letter. Pen-and-ink changes are not acceptable for any reason; therefore, any changes require reissuance of the Delegation of Authority Letter.

 

Question: What should I do if my GPC is lost or stolen?

Answer:  Immediately notify the card-issuing bank, your A/BO, and your A/OPC. You must make these notifications within three working days.

 

Question: What is a split purchase?

Answer:  A split purchase occurs when a requirement that exceeds a CH’s single purchase limit is separated into two or more buys as a means of getting around the purchase limit. No CH may fragment/split purchases that exceed their single purchase limit as means to use the GPC. To do so is a violation of Federal procurement law.

Split purchases include splitting requirements among merchants; splitting requirements among CHs and splitting requirements over a period of time. Requirements that exceed the CH’s single purchase limit must be sent to the contracting office for award.

A/BOs and CHs should contact their contracting office when they identify repetitive requirements for supplies, services, or construction increasing to levels that will surpass the CH’s single purchase limit. The contracting office may establish Blanket Purchase Agreements (BPAs) or other contracting instruments that will allow the CH to place orders at a higher level than the micro-purchase thresholds to avoid splitting requirements while negotiating better pricing and delivery for the best interest of the Government.

References:  FAR 2.101, 13.2 and 13.3.

 

Question: Am I required to pay state tax on GPC purchases?

Answer:  You can find an interactive state tax information tool on the GSA website.

As an example, for the state of Kentucky, GPC purchases are exempt from state sales tax. (Note: The GSA Office of Charge Card Management confirms that GPC accounts are considered centrally billed accounts (CBAs).)

Reference:  GSA website

 

Question: Our office allows “dress down” Fridays, and we would like to purchase polo shirts with our office symbol imprinted on the shirts for everyone to wear on Fridays. Can I use the GPC to make the purchase?

Answer:  No.  This type of clothing is not required by law or regulation. GAO Decision B-289683 (October 7, 2002) considers clothing to be a personal expense of the employee, and appropriated funds are not generally available for personal expenses. Every Government employee is required to present themself for duty properly attired according to the requirements of their position.

Note: Clothing required by law or regulation is generally provided to the employee by a clothing allowance.

Reference:  GAO Decision B-289683

 

Question: Can I purchase protective clothing and safety shoes with my GPC?

Answer:  Per GAO Decision B-289683, the Government may provide protective clothing if the Agency determines that it is necessary under the Occupational Safety and Health Administration’s implementing regulations. Check your Service/Agency policy. Protective clothing, safety shoes, etc. are generally provided through a clothing allowance to the employee. All purchases of protective clothing, safety shoes, etc. require approvals from the appropriate Safety Officer and Resource Manager.

Reference:  GAO Decision B-289683

 

Question: Can I purchase from merchants that charge a surcharge/checkout fee to use the GPC?

Answer:  It depends on where the merchant is located.

If the merchant is located within a U.S. state or U.S. territory that permits merchants to impose a surcharge/checkout fee for charge/credit card purchases, then the CH may either make the purchase with the fee pursuant to the following requirements or consider another merchant that does not charge a surcharge/checkout fee. Surcharge/checkout fees are not imposed by merchants within the following states, which do not permit such fees: Colorado, Connecticut, Kansas, Massachusetts, and Oklahoma.

Merchants are required to notify CHs in advance of purchasing if a surcharge/checkout fee applies. The merchant must include the fee on any receipt provided to the CH. Maine and New York require additional disclosures for merchants choosing to impose surcharge/checkout fees.

CHs shall ensure:

• The total amount of the purchase plus the surcharge/checkout fee does not exceed the CH’s single purchase limit.
• The price, including the surcharge/checkout fee, is considered fair and reasonable.
• Surcharges/checkout fees imposed in Colorado, Connecticut, Kansas, Massachusetts, and Oklahoma are reported to the proper State authority.

 

References:

• GSA SmartPay® Smart Bulletin No. 017, “Charge Card Brands VISA and MasterCard Permit Merchant Imposed Surcharges, updated October 21, 2019.”
• MasterCard webpage, “What Merchant Surcharge Rules Mean to You.”

 

Question: Can one individual perform more than one GPC function (e.g., A/OPC, A/BO, and CH functions)?

Answer:  Separation of duties is key to the success of the GPC Program. Duties such as making purchases, authorizing payments, certification of funding, and reviewing and auditing functions are assigned to different individuals to minimize the risk of loss to the Government to the greatest extent possible. Requirements are as follows:

• If a CH is also an Accountable Property Officer, they should not be allowed to make purchases for themselves.
• An A/OPC shall not be an A/BO or CH, nor shall they act on behalf of an A/BO or CH under their level(s) of oversight and management.
• An A/BO shall not be a CH under their Prime or Alternate A/BO accounts.
• A CH shall not be an A/BO over their credit card accounts.
• A Prime A/BO may function as an Alternate A/BO under another Prime A/BO if they are not a CH under that Prime A/BO’s account.

Reference:  Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, section A.1.2.4

 

Question: Can being a GPC CH affect my personal credit rating?

Answer:  No.  GPC purchases are paid by the Government, not by the individual CHs. Also, the GSA SmartPay® 3 master contract prohibits the release of personal or confidential information to credit bureaus.

 

Question: There are non-Government websites with Frequently Asked Questions (FAQs) regarding the GPC Program. Can I use these sites to search for GPC answers?

Answer:  No. Non-Government websites, blogs, newspapers, magazine articles, TV/radio reports, etc. are not official guidance for the GPC Program. Official GPC Program information and resources are available on the Defense Pricing and Contracting (DPC) website and individual Service/Agency websites. A/BOs and CHs can also obtain answers to their GPC questions by contacting the A/OPC responsible for the oversight of their GPC accounts.

Reference:  DPC website

 

Question: If a merchant only accepts cash, can I get a cash advance with my GPC to pay for the purchase?

Answer:  No.  Per Section A.1.2.4 of the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, use of the GPC to purchase cash advances, including money orders and travelers’ checks, is prohibited because cash and near-cash is easily misappropriated.

Reference:  Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs

 

Question: Can the GPC be used for funeral details or other group travel?

Answer:  No.  Per Section A.1.2.4 of the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, use of the GPC for travel-related expenses is prohibited.

Reference:  Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs

 

Question: We have personnel who take the Metro for official Government meetings. Can I use the GPC to purchase Metro fare passes for these personnel?

Answer:  No.  Per Section A.1.2.4 of the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, use of the GPC for travel-related expenses is prohibited.

Reference:  Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs

 

Question: I need to dispute a charge on my billing statement from last month. Can I still file a dispute?

Answer:  Per Section A.1.10 of the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, the CH has 90 calendar days from the date of the transaction as reflected in the bank’s system, to dispute a transaction.

Reference:  Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs

 

Question: Can the GPC be used to purchase ammunition or explosives?

Answer:  No.  Per Section A.1.2.4 of the Department of Defense Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs, use of the GPC to purchase weapons, ammunition and explosives is prohibited.

As controlled DoD commodities, weapons, ammunition, and explosives are assigned to the Army (see DFARS 208.70), which has contracting responsibility to supply all DoD Components with weapons, ammunition, explosives, and other commodities listed in DFARS PGI 208.7006. DoD Components are to submit their commodity requirements via Military Interdepartmental Purchase Request to the assigned Component in accordance with DFARS 208.7002 and DFARS PGI 208.7002-1. There are no exceptions.

References:  DFARS 208.70, Coordinated Acquisition; DFARS 208.7002, Assignment Authority; DFARS PGI 208.7002-1, Acquiring department responsibilities; and DFARS PGI 208.7006, Coordinated acquisition assignments.

 

Question: Which GPC personnel must take Certifying Officer’s Legislation training?

Answer:  A summary of required GPC training courses by role is available on the DPC website.

 

Question: Where can I find GPC Certifying Officer’s Legislation training?

Answer:  CLG 006, “Certifying Officer’s Legislation (COL) for Purchase Card Training,” is available on the DAU website.

Because this course specifically addresses GPC content, Certifying Officers who have previously completed an alternate authorized COL training module are encouraged to take DAU CLG 006 as soon as practicable. However, current Certifying Officers are not required to take CLG 006 or an alternate approved course until their annual refresher training is required. As individual Defense Components may require completion of alternate or additional course materials, please consult your Component procedures to ensure compliance.

 

Question: Is there an electronic capability to process and store Certifying Officer DD Form 577, “Appointment/Termination Record—Authorized Signature”?

Answer:  Answer: Yes the ability to appoint GPC Certifying Officers using the Joint Appointment Module (JAM) was released on 15 December 2018. JAM allows users to view and print their DD Form 577. It also allows individuals with the DD577 View Only Role (including DFAS) to see all appointments. JAM web-based training is available at https://wawftraining.eb.mil/wbt/xhtml/wbt/jam/index.xhtml. Please remember that in accordance with DoD FMR Volume 5, Chapter 5, Paragraph 050401.F, Certifying Officers who certify manual vouchers or submit manual certifications of electronic payments must submit original, manually signed DD Form 577s to the DFAS Indianapolis (DFAS-IN) disbursing official (secure email: dfas.indianapolis-in.jfd.mbx.dfas-incddd577@mail.mil).

 

Question: Can I use my GPC for advance payments to purchase subscriptions?

Answer:  Yes. Limitations on advance payments do not apply to advance payments authorized by law for subscriptions or publications. Advance payment is authorized in Title 31 of the United States Code (U.S.C.) Section 3324(d)(2) for “charges for a publication printed or recorded in any way for the auditory or visual use of the agency.” CHs must place subscription orders in the name of an organization or a position title (e.g., Building Manager or Director, XXX Division) rather than in the name of an individual employee. CHs must retain the renewal notice or a statement that reflects the beginning and ending date of the subscription service.

References:  FAR 32.404(a)(6), Advance Payments for Non-Commercial Items—Exclusions; and 31 U.S.C. Section 3324(d)(2), Advances.

 

Question: Can I use my GPC to purchase membership fees and expenses for attendance at meetings?

Answer:  No.  Title 5 U.S.C Section 5946 states the following:

“Except as authorized by a specific Appropriation, by express terms in a general appropriation, or by sections 4109 and 4110 of this title, appropriated funds may not be used for payment of—

      Membership fees or dues of an employee as defined by section 2105 of this title or an individual employed by the government of the District of Columbia in a society or association; or

      Expenses of attendance of an individual at meetings or conventions of members of a society or association.”

References:  5 U.S.C. 5946, Membership fees; expenses of attendance at meetings; limitations.

 

Question: Can I use my GPC to obtain professional credentials?

Answer:  Yes, with certain limitations. Title 5 U.S.C Section 5757 states the following:

(a) An agency may use appropriated funds or funds otherwise available to the agency to pay for:

      (1) Expenses for employees to obtain professional credentials, including expenses for professional accreditation, state-imposed and professional licenses, and professional certification; and

      (2) Examinations to obtain such credentials.

(b) The authority under subsection (a) may not be exercised on behalf of any employee occupying or seeking to qualify for appointment to any position that is excepted from the competitive service because of the confidential, policy-determining, policy-making, or policy-advocating character of the position.

Reference:  5 U.S.C. Section 5757, Payment of expenses to obtain professional credentials.

 

Question: How is the GPC Program affected when DoD appropriations are not passed?

Answer:  The card-issuing bank shall not deactivate any account during a Government-wide shutdown unless otherwise required by GSA or the Agency/organization. However, before an anticipated shutdown, A/OPCs may want to reduce GPC transaction limits to $1 to minimize risk. CHs must be extremely careful during a Government-wide shutdown, especially if the shutdown occurs over a weekend. The Anti-Deficiency Act (ADA) prohibits most Agencies from incurring obligations in the absence of appropriations (unless otherwise allowed by law or for emergencies involving the safety of life or limb, the protection of property, or other excepted services). Funding authority to operate will be issued through Office of the Under Secretary of Defense (Comptroller) command channels. Due to the ADA prohibitions, it is crucial that any GPC use during a shutdown is preapproved by the Resource Manager. ADA violation penalties are severe, and a CH could be fined or imprisoned for violating the statute.

To minimize Prompt Payment Act (PPA) interest, all GPC Program officials should ensure that all accounts are current and up to date before a Government shutdown, as PPA interest continues to accrue during a shutdown. Delinquent accounts are subject to suspension or cancellation as early as 61 days after becoming delinquent but must be suspended or canceled within 180 days as required by the GSA Master Contract. A/OPCs must work with the card-issuing bank if this situation applies.

 

Question: I am a cardholder who is located overseas with delegated authority to purchase up to $25,000. My Component has a requirement to purchase a commercial item valued at $13,000 for delivery to my overseas base, but it is only available from a U.S. merchant. Can I make the purchase using my GPC?

Answer:  No. You must send this requirement to the supporting contracting office for action. GPC Overseas Simplified Acquisition Cardholders reaching back to vendors in the United States are limited to the applicable micro-purchase threshold (generally $10,000, but see FAQ number 2 above).

 

Question: Can I pay tariff charges that are being quoted for GPC purchases?

Answer:  Yes, tariff charges are allowable costs with GPC purchases. Cardholders (CHs) are required to add any tariff charges to the quoted price of the required supplies/services to determine if they are authorized to make the purchase.

In the event the inclusion of the tariff charge causes the quoted price to exceed the CH’s single purchase limit (SPL), the CH can either (1) request that the vendor reduce the quoted price so it is below the CH’s existing SPL, or (2) contact their A/OPC, who will determine if an adjustment to the CH’s SPL is appropriate.

If the CH’s SPL is equal to the Micro-Purchase Threshold (MPT) and inclusion of the tariff charge causes the quoted price to exceed the MPT, the CH can either (1) request that the vendor reduce the quoted price below the MPT so the GPC can be used as the method of purchase, or (2) send the requirement to their supporting contracting office for action.

 

Question: What are Official Representation Funds (ORF), and should I have a separate GPC account for purchases made with these funds?

Answer:  ORF involves a separate budget allocation for the use of appropriated funds for official representation purposes throughout the Department of Defense (DoD), pursuant to the DoD Annual Appropriations Act and United States Code (U.S.C.) Title 10, Section 127. ORF funding is designated for a specific purpose: to facilitate official representation activities that further the interests of the United States. Per DoD Instruction 7250.13, Use of Appropriated Funds for Official Representation Purposes, paragraph 3a, Policy, “The authority within the AAA shall be used to host official receptions, dinners, and similar events, and to otherwise extend official courtesies to guests of the United States and the Department of Defense for the purpose of maintaining the standing and prestige of the United States and the Department of Defense. These events are normally hosted and attended by (not simply sponsored by) members of the Senior Executive Service (SES) or flag officers (FOs). In lieu of an SES or FO, when the situation warrants, the ability to host and attend these events can be delegated to a GS15/NSPS equivalent or 06 level of leadership. If an event involves a base/ship commander, the level of leadership can be delegated to an 05/06. These exceptions should be documented within the ORF package.”

Components are required to ensure appropriate management controls are established in Component-level policy when the GPC is used to make ORF purchases. These controls must require issuance of card accounts dedicated for ORF purchases (i.e., do not comingle standard open-market micro-purchase and official representation transactions on a single card account) and assignment of an authorized ORF line of accounting. Additionally, Components must ensure appropriate spending and Merchant Category Code (MCC) limitations are assigned to these accounts and any necessary preapprovals for ORF purchases are in place to avoid misuse of Government funds, gold-plating requirements, and Anti-Deficiency Act violations.

Reference:  DoDI 7250.13, Use of Appropriated Funds for Official Representation Purposes; Army Regulation 37-47, Official Representation Funds of the Secretary of the Army; Air Force Policy Directive 65-6, Budget; Secretary of the Navy Instruction 7042L, Use of Official Representation Funds; Department of Defense (DoD) Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs; DoD Comptroller Memo, Preferred Payment Method for Official Representation Funds; and 31 U.S.C. 1341, Antideficiency Act.

 

Question: What is the Computer/Electronic Accommodation Program (CAP)?

Answer:  Established by DoD in 1990, CAP is a centrally funded program that provides assistive technology (AT) and reasonable accommodations to DoD employees with disabilities and wounded Service members. CAP's mission is to ensure that DoD employees with disabilities and wounded Service members have equal access to the information environment and opportunities throughout DoD. CAP can assist in identifying proper information technology (IT) related accommodation solutions and/or purchasing the accommodation at no cost to the employee or employing agency. CAP serves as an additional resource to each agency’s reasonable accommodation process.

Before purchasing accommodation solutions using the GPC, Cardholders should obtain documentation that CAP was unable to provide the required item(s). For more information about CAP and the types of accommodations it can provide, visit www.cap.mil and www.cap.mil/AboutCAP/FAQs.aspx.

Reference:  CAP website

 

Question: Can a GPC be sent to a home address?

Answer:  Standard practice is to have the card mailed to the CH’s work address in accordance with the GSA SmartPay^®3 contract. Using a CH’s home address may be a fraud indicator and should not be a normal practice. However, there are situations where an alternate address, including the CH’s home address, may be valid.

Whether the card is mailed to the CH’s work address or an alternate address—including the CH’s home address, Section 2.3.1.6(f) of the Department of Defense (DoD) Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs specifically mandates CHs to “Maintain the physical security of the card. This includes not keeping the card with the account holder at all times unless operationally required.” Physical security of the card, as determined by Component policy, is required.

Examples of alternate address uses include, but are not limited to:

• When an A/OPC wants all cards mailed to the A/OPC’s work address, and then the A/OPC provides each card to the new CH’s work location, when all Agency-specific requirements have been met;
• When the A/OPC feels it is more reliable to have the card mailed to the A/OPC’s work address and then sent by express mail to a CH’s work address overseas;
• When the organization has a policy that all cards will be sent to the work address of the responsible A/BO, who will then deliver each card to the CH in person or to the CH’s work address; or
• When the CH will not be at the work location (duty station) for an extended period (COVID-19 stay-at-home orders would be one such example), the CH’s home address could be used. If the CH’s home address is used for card delivery, a note or memorandum for the record should be added to the account notes stating why the home address was used.

Reference:  GSA SmartPay^®3 contract and Department of Defense Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs.