Whenever a government agency wants to acquire a product or service, it's not always as easy as clicking the "place order" button we're used to on e-commerce sites. Depending on the price threshold, they may be able to purchase from your GSA Schedule directly and use that easy button, or they will need to solicit information from several contractors before they decide on a purchase.
These ordering procedures are determined by the Micro-Purchase Threshold (MPT) and Simplified Acquisition Threshold (SAT). You can read all about these two terms in the Federal Acquisition Regulation (FAR), but as with any government document, it’s not always easy to follow.
The MPT and the SAT were established to reduce the administrative costs associated with a lengthy bid review and response process, maintaining fair allocation of government contracting funds. Let’s review the MPT vs. the SAT and what it means for GSA Schedule contractors.
We like to view the Micro-Purchase Threshold as the federal government’s “smallest limit” set on purchases of commercial goods and services that do not require a competitive quotation process. Micro-Purchases can be made directly with the contractor if the Contracting Officer (CO) or appointed federal buyer considers the pricing to be reasonable.
The MPT is currently $10,000, meaning authorized buying agencies can purchase directly from the contractor without adhering to the more formal competitive processes when they are acquiring goods and services for $10,000 and below.
In cases where the head of an agency determines the need for supplies or services to support a contingency operation, response to emergency or major disaster, or facilitate defense against cyber, nuclear, biological, chemical, or radiological attack, the MPT is $20,000 inside the U.S. and $35,000 outside the U.S.
For more detail on ordering procedure language, you can check out Subpart 13.2 - Actions at or Below the Micro-Purchase Threshold.
Authorized government buyers make Micro-Purchases directly from companies using their government credit card. The Government Purchase Card (GPC) is the government’s version of a commercial credit card and it's issued to authorized government agency personnel for services and supplies. This is the preferred method to pay for micro-purchases.
All GSA Schedule contractors are required to accept the GPC for purchases up to the Micro-Purchase Threshold. This makes it significantly easier for government agencies to quickly and efficiently acquire solutions that satisfy their needs. The use of a GPC to make purchases under the MPT is highly encouraged by the U.S. government to its employees.
Most purchase card orders will be under the Micro-Purchase level, however, some purchase card holders may have a spending limit above the MPT, so contractors are highly encouraged to accept GPC orders greater than the MPT as well.
The Simplified Acquisition Threshold (SAT) has also experienced an increase in the past few years from $150,000 to $250,000 in an effort to provide relief for COVID-19. Much like the MPT, the SAT is established to streamline the government procurement process, however, purchases between the MPT and the SAT have additional elements in place that purchasing under the MPT do not.
For purchases between the MPT and the SAT (between $10,000 and $250,000), authorized government buyers need to follow Simplified Acquisition Procedures (SAP) and show reasonable consideration for supplies and services offered. Government buyers must:
In addition, government agencies must place the order with the contractor who can offer the "best value" determination. Once the government buyer determines the contractor with the “best value” option, the award is granted. Best value considerations are not always based on lowest costs factors, but they allow the government flexibility to consider other aspects beyond both price and the highest technical rating. If a contractor offers higher prices, those prices may be justified by other factors or tradeoffs the contractor presents.
It's important to note that contracts and subcontracts at or below the SAT ($250,000 or less) are not applicable to certain laws and regulatory requirements. FAR 13.005 provides a list of inapplicable laws to contracts at or below the SAT.
For any contract above the SAT (greater than $250,000), a Request for Quote (RFQ) must be posted on GSA eBuy or government buyers must send the RFQ to as many contractors as practicable. Subpart 13.5 of the electronic code of Federal Regulations provides special authority for acquisitions of commercial supplies and services in amounts exceeding the Simplified Acquisition Threshold but not exceeding $7.5 million.
We know this is a lot to process, so we created a graphic that might help you visualize the MPT and SAT and the ordering procedures for each threshold:
Acquisition.gov also has a table you can use to check all the thresholds.
It’s easy to see the many benefits of increased MPT and SAT from both the government and contractor perspective. The government buyer has more spend flexibility when placing orders under pre-existing contract vehicles such as the GSA Schedule. They also have their immediate needs fulfilled in a more cost effective and timely manner.
With the MPT and SAT, Government Purchase Card funds are better managed as purchasing from pre-existing contract vehicles vs. open market (or commercially available business) typically provides better rates.
Contractors, whether small or large businesses, have increased opportunity to grow in revenue and broaden their customer base. The MPT and SAT lead to increase in award opportunities, lowered administrative costs, and less bidding and proposal writing efforts. It also fosters fair competition for small businesses for purchases between and above the SAT.
Although these terms are essential to understand if you're a government contractor, we know the stipulations and changes that come with them can be hard to follow. It's important you keep up with the MPT and SAT in case the government decides to alter the thresholds in the future.
Do you still have questions about Micro-Purchase Threshold or the Simplified Acquisition Threshold and what they mean for your GSA MAS contract? We can help answer any questions you may have. If you want to learn more about the world of GSA and stay up to date with the latest contracting news, you can subscribe to our blog and our monthly newsletter.