United States Office of
Environmental Protection Administration and
Agency Resources Management
EPA/20 2/B-92/009
September 1992
. i
&EPA Small Purchases
A Guide For
Program Offices
Recycled/Recyclable
Printed on paper that contains
at least 50% recycled fiber
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Table of Contents
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Introduction 1
Frequently Used Procurement Terms 1
Methods Of Procurement 3
Procedures 4
Plan In Advance 4
Prepare a PR 4
Circulate The PR Internally '.'.'.'. 5
Circulate The PR Externally 6
Forward The PR To The Servicing Purchasing Activity 6
Hints For Unusual Procurements 6
Blanket Purchase Agreements (BPAs) 6
Imprest Fund 7
Use Of GSA Federal Supply Schedules .... 7
Temporary Help Services 8
Acquisition Of Books And Subscriptions 9
Office Furniture 9
ADP Equipment 10
Conferences/Meetings 10
Contracting With Former EPA Employees 11
Status Of PRs 12
Contractor Performance Reports 12
Future Automation 12
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Introduction
The purpose of this guide is to provide basic information about small
purchases and purchase orders for all program personnel who require
procurement of supplies or services. The Guide includes basic terminology
and procedures and examples that will help you understand the increasingly
complex procurement process.
Frequently Used Procurement Terms
Several basic terms are used in Government "procurement," which is the
acquisition of supplies or services.
One of the most important players in the procurement process is the
"Contracting Officer" (CO). Only a CO has official authority to place orders
for supplies or services, thereby obligating the Government to pay.
"Purchasing Agents," using their delegated contracting officer authority,
process small purchase requirements, placing orders with vendors up to
varying dollar limits, depending on their authority.
"Ratification" is an important term. Only authorized persons may obligate
funds. Those persons include COs and Purchasing Agents, as well as
program personnel who have been delegated procurement authority.
Unauthorized persons who commit EPA for the expenditure of funds in
exchange for goods or services must prepare detailed documentation and
request the CO to "ratify" (approve the purchase even though correct
procedures were not followed) the purchase by issuing an appropriate
document to the vendor. If the CO is unable to ratify the procurement, either
due to insufficient justification or because the procurement is illegal and
therefore could not be effected by an authorized person, the person who
placed the order may be held personally liable for the costs incurred and
subject to Agency disciplinary action.
U.S. Erwironmoiv.i protection Agency
Region 5, Library 1PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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"PR" is one of the most common procurement terms at EPA. A PR, or
Procurement Request/Order (EPA Form 1900-8), is mandatory for most
procurement methods. Internal program procedures may not require a PR
for bankcard or BPA purchases, but generally a similar document will be
necessary for tracking commitments of funds. Ask your supervisor or a
co-worker to explain the applicable procedures in your office.
All procurement personnel frequently quote the "FAR." The FAR is the
Federal Acquisition Regulation, with which all Government agencies must
comply. The "EPAAR" is the EPA Acquisition Regulation and implements
the FAR. EPA also issues the "CMM," the Contracts Management Manual,
which sets forth formal Agency policy on many procurement issues, including
preparation of a PR (Ch. 2), Blanket Purchase Agreements (Ch. 4), and
ratifications of any unauthorized commitments (Ch. 12).
"Competition" is another frequently used term. The FAR requires
Government COs to solicit several vendors/offerers to obtain competitive
price quotes prior to award of a purchase order or contract valued in excess
of $2,500. To accomplish competition, Purchasing Agents generally call
several qualified vendors and obtain verbal price quotations. The FAR
generally requires that all small purchases be reserved for small business
concerns.
Requests for "sole source" procurements require additional documentation
from the requisitioner justifying the use of only one source. Justifications are
discussed in more detail below.
For complex statements of work or long lists of items, Purchasing Agents
may issue "RFQs" (Requests for Quotations) and obtain written price quotes
rather than obtaining oral quotes by telephone.
Another term frequently used by procurement personnel is "GSA" or "FSS."
These terms usually refer to contracts awarded by the General Services
Administration's Federal Supply Service for mandatory use by all
Government agencies. Those contracts, or "schedules," are established
with commercial firms to provide supplies or services at stated prices for fixed
periods of time. They include various types of office equipment, file cabinets,
and many other commercial items. Purchasing Agents can assist in
determining whether the item you require is on schedule. Use of schedules
can often eliminate the need to obtain price quotes.
If schedules are not used, the purchase order is issued on the "open
market" and, if in excess of $2,500, requires competition unless justified on
a sole source basis. Open market orders may not exceed $25,000. Orders
may not be split to avoid that limit.
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Methods Of Procurement
There are several methods by which Purchasing Agents and others who
have been delegated authority may place orders.
A "purchase order" is used for most procurements valued at $25,000 or
less. (A "contract" is used for most procurements over $25,000 and is not
discussed in this guide). Purchase orders require the signature of an
authorized CO, or Purchasing Agent. A variation is the "delivery order,"
which is an order placed by a designated CO against an existing Government
contract. In certain instances, purchasing agents issue oral orders to
vendors.
"Blanket Purchase Agreements" (BPAs) are essentially unfunded
purchase orders issued by a Purchasing Agent to vendors from which
programs have recurring needs for small items or services. Verbal orders,
placed by program personnel, eliminate the need for written orders. BPAs
are not always appropriate, but the purchasing activity will assist you in
determining their propriety.
The "imprest fund" provides program personnel funds to pay for supplies
or services as long as the purchase was previously approved by a CO. In
this method, a requisitioner, after obtaining internal approval, obtains
permission from a CO to purchase supplies and may then obtain advance
funds or reimbursement from the imprest fund.
A "Bankcard," a Government charge card maintained and used by
authorized program personnel, is the most efficient procurement method for
small purchases. Although there are certain restrictions on the types of items
and services that may be ordered, it is an extremely quick method of filling
requirements because properly trained and authorized program personnel,
rather than purchasing office personnel, retain and use the card. Less
paperwork is necessary. Your office may have one or more authorized
bankcard users. Check with your supervisor to learn the procedures
established in your office for use of bankcards.
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Procedures
Plan In Advance
Advance planning is essential to ensure that the purchasing activity has
sufficient time to place orders and the vendor has time to deliver without
interruption to a program's activities. Procurement personnel must comply
with many complex regulations, some of which mandate allowing vendors
certain periods of time in which to respond to solicitations. Unfortunately,
issuance of orders cannot be accomplished immediately after receipt of your
PR.
The following leadtimes for processing PRs using small purchase
procedures apply:
D Purchase orders, both competitive and sole source:
15 days if the Purchasing Agent can issue an oral order, including
bankcard orders, or
25 days if the order must be in writing.
D Blanket Purchase Agreements:
45 days
Remember, however, that issuance of an RFQ to several vendors will require
additional time.
Purchasing activities establish cut-off dates prior to the end of each fiscal
year. You must submit by that date all requirements to be awarded by
September 30. For example, in FY 1992, the cut-off date at Headquarters
was July 31. The Small Purchase Unit attempts to award all requirements
received by that date. If your requirement is complex, there may be
insufficient time for award. End-of-year workload may adversely impact
requirements submitted late. Submit your requirements as early as
possible!
Prepare a PR
The procedures you must follow for obtaining supplies or services by
purchase order are relatively simple. You must complete a PR, follow your
office's internal procedures for obtaining approvals and funds, and forward
the documents to the purchasing office.
You must complete EPA Form 1900-8, Procurement Request/Order in
accordance with the instructions on the reverse of the form. You may include
with the specification brand names and model numbers as examples of
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supplies or equipment that meet your requirements. If only one brand is
acceptable, explain why. If complex services are required, include a
complete, detailed description of the requirement. Be sure to include a
specific required delivery or completion date.
Typing the form error free allows the Purchasing Agent to use the form as
the purchase order and process your order more quickly. Other time savers
include use of attachments for information other than a description of the
supplies or services required, as well as checking "yes" in Block 15, which
allows the Purchasing Agent to include small additional amounts such as
those necessary for shipping and handling charges without calling you to
obtain additional funds.
If your location has an electronic system, you will use an electronic form
instead of Form 1900-8 and may secure electronic approvals. Lead time
requirements will remain unchanged.
You may include suggested sources (name and telephone number) that
might satisfy your requirements. If the value of the requirement exceeds
$2,500 and only one source is available, you must include a written
justification explaining the circumstances. The FAR allows sole source
acquisitions only in certain circumstances. They include the following:
D only one source and no other supplies/services will satisfy the
requirement,
CD the need for the supplies or services is of such an unusual and
compelling urgency that the Agency would be seriously injured
unless the number of sources solicited is limited, and
D the source is authorized by statute.
The first two instances are self-explanatory. The third includes procurement
of expert testimony authorized by the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
Justifications must be detailed and fully describe your specific situation. For
example, if only one source is available, you must explain why that is true;
what efforts you made to locate another source; and, in the case of supplies,
why no other item produced by another vendor is acceptable. If you need
supplies or services urgently, you must fully describe the urgency. Lack of
advance planning is not sufficient justification for a sole-source procurement.
That is why advance planning, described above, is so important.
Circulate The PR Internally
You must circulate PRs within your office to obtain any signatures your office
mandates, including that of the funds certifying officer. COs cannot place
orders unless funds are certified as available.
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Circulate The PR Externally
You may have to circulate the form to other offices if additional Agency
approvals are necessary. A frequent requirement is Facilities Management
and Services Division approval for non-expendable equipment, including
furniture and office equipment. Other examples include requirements for
ADP equipment, calculators, printing, and telecommunications equipment.
(See CMM, Ch. 2, Attachment 2-F2-1.)
Forward The PR To The Servicing Purchasing Activity
Forward the completed document to the purchasing activity that serves your
office. Allow sufficient time for the Purchasing Agent to process your
requirement and for the vendor to deliver. Generally, allow 15 days for award
of simple purchase orders and at least 25 days for award of more complex
orders. Remember that vendors will require additional time after receipt of
an order to deliver items or perform services.
Hints For Unusual Procurements
Blanket Purchase Agreements (BPAs)
Purchasing Agents can establish BPAs for programs that have recurring
repetitive needs for supplies or services. Procedures are the same as for a
routine order except that you should include the names of individuals who
should be authorized to make verbal calls to the vendor to order supplies.
Those individuals are called Call Ordering Officers, but they must complete
training in an approved small purchases course or EPA's Bankcard/Ordering
Officer's Training Course. Attach a copy of the training certificates to the PR.
Generally, Call Ordering Officers will have authority to place orders up to
$2,500 at one time. They may not split orders to avoid that limit. They must
also maintain internal documentation (logs) to record purchases, funding,
and deliveries. Remember that BPAs with an estimated value over $2,500
(and orders over $2,500 under BPAs) will require competitive price quotes
prior to award unless they are issued under existing Government contracts
or justified on a sole source basis. The total value of all calls placed under
any BPA may not exceed $100,000 over a three-year period.
Contact your purchasing activity if you are contemplating establishing a BPA.
A bankcard may be a more efficient means of acquiring the goods or services
you need.
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Imprest Fund
Use of the imprest fund allows program office personnel, after approval by
a CO, to obtain supplies or services from local vendors and claim
reimbursement or to obtain funds in advance to pay vendors. The process
requires more paperwork than use of a bankcard, but it is a viable procedure.
You must prepare a PR and obtain any required approvals, including
approval by an authorized contracting officer. COs in Headquarters, the
Contract Management Divisions at Research Triangle Park and Cincinnati,
and the regions have authority to approve imprest fund purchases up to
$500, or $750 in an emergency. At Headquarters certain individuals in the
Facilities Management and Services Division are authorized to approve
imprest fund purchases up to $150. You must justify in writing the need for
imprest fund purchases over $500.
Once you have obtained all the necessary approvals, including CO approval,
you may take the PR to the imprest fund cashier to pick up funds with which
to pay the vendor. You must obtain a receipt of payment from the vendor
and return it to the cashier within three days. If it is more convenient (for
example, when the imprest fund office is closed), you may also pay the
vendor from your own funds and obtain a receipt to include with the PR when
claiming reimbursement from the imprest fund cashier, but only if you
previously obtained approval from a CO for the purchase.
Use Of GSA Federal Supply Schedules
GSA's FSS schedules cover a variety of commercial items, ranging from
office supplies to office furniture and laboratory equipment, as well as some
services, such as carpet cleaning. GSA classifies schedules as mandatory
use or non-mandatory use. Agencies must use mandatory schedules to
purchase items or services covered in the schedule. Dollar limits on delivery
orders placed under schedule contracts are established in the individual
schedules. Generally, orders may exceed the open market order $25,000
limit for small purchases.
Schedules may also be single award, in which only one vendor is available,
or multiple award, in which various vendors are available. In the latter case,
orders must be placed with the lowest price vendor that offers a product or
service that meets the requisitioner's minimum needs.
Agencies must purchase items or services that meet the requisitioner's
minimum needs. A requisitioner's personal preference for a specific brand
or firm may not be considered. Therefore, you may not tailor an item
description in order to purchase the item from a specific vendor or to favor
one brand over another. You must justify the need for each characteristic or
specification or rush delivery, if desired. However, if you determine the item
or service available on a mandatory-use schedule absolutely will not meet
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your needs, you must provide the purchasing activity sufficient
documentation to support the determination. The purchasing activity must
transmit that information to GSA to request a waiver from use of the schedule.
GSA will not grant a waiver based on personal preference, subjective
evaluations, or lower costs for similar items. GSA responses generally take
30-45 days.
Temporary Help Services
EPA's Office of Human Resources promulgates guidance on obtaining
temporary help as permitted by the Office of Personnel Management.
Although you should consult the current version of that guidance, the basic
principles are as follows:
D Temporary help may be obtained to meet short term staffing needs
when an office is faced with an immediate, critical need that cannot
be met readily through temporary appointment procedures.
Examples include personal emergencies, accidents, illness,
mandatory jury services, or family responsibilities. Vacations are not
included.
D Temporary help may not be procured to avoid FTE ceilings.
D Temporary employees are not Federal employees and must not be
treated as such.
LJ The duration of the assignment may not exceed 45 days within a
six-month period, or in the case of maternity leave, without additional
justification to extend the period for 20 days.
You must prepare a justification of need for temporary services, including a
statement that the services needed are not recurring, that they are needed
to fill a temporary vacancy such as maternity leave or illness, and that
temporary employees will not be treated as Government employees.
You must include a specific description of the duties that a temporary
employee will perform, including duty hours, location, description of actual
work to be performed (such as receptionist duties, clerical work, etc.), the
name of a Government monitor, provisions for overtime and payment, and
the duration of the assignment. Monitors may provide only technical,
task-related instructions, including orientation, assignment of tasks, and
review of work products. Government employees may not reward, reassign,
grant leave to, discipline, or terminate a private sector temporary employee.
Purchasing Agents must obtain temporary help contractors through the
competitive procurement process.
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You must prepare a PR and forward it with a Request for Temporary Help
Services to your servicing human resources office for approval. The form
must be signed at the Division or Office Director level.
Acquisition Of Books And Subscriptions
Books
Use of a bankcard is the most efficient and quickest method of purchasing
books. You may also use the imprest fund for local purchases. If those
methods are unavailable, you may submit a PR to the purchasing activity for
processing. Use a separate PR for each vendor.
Subscriptions
Use of a bankcard, as with books, is the most efficient method of purchasing
subscriptions. You may also submit a PR to the purchasing activity for
processing. If your office needs multiple copies, consolidate the requests on
a single PR to reduce processing time. PRs should indicate the publication
title, a "deliver to" address, the number of copies required, estimated unit
price, and the subscription period. To renew a subscription, include the
previous purchase order number and renewal notice you received from the
vendor.
Office Furniture
FAR requires Government agencies to purchase office furniture from
UNICOR (Federal Prison Industries). UNICOR has several types of furniture.
They are (a) wood, both for executives and all grades; (b) modular; and (c)
systems. The purchasing activity and the Facilities Management and
Services Division have catalogs available for review. You should review the
catalogs and determine the type of furniture that meets your needs before
you prepare a PR. UNICOR orders require a 15% shipping and handling
charge, so budget your requirements accordingly.
Wood furniture is available in two types Allenwood (for executives) and
Centurion (for all grades). Modular furniture consists of separate metal
components, some with wood grain tops, that can be combined into various
configurations for desks, work tops, shelves, and credenzas. GSA must
conduct a space survey and review your requirements to determine whether
UNICOR will provide the furniture or issue a waiver for acquiring furniture
from a mandatory FSS vendor. The decision usually takes 30 days after the
survey is complete.
Systems furniture consists of complete workstations and cluster
workstations. Various standardized configurations are available for
managers, supervisors, professional staff, and clerical staff. A computer
workstation is also available. The mandatory procurement process requires
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obtaining and evaluating offers from each contractor and selecting the lowest
cost items that best meet your needs. Contractors may also charge design,
layout, and installations costs.
File cabinets are a frequently needed item. Orders for file cabinets must be
placed with GSA, or in certain circumstances with FSS vendors. GSA usually
maintains a supply of vertical and horizontal file cabinets in several colors.
ADP Equipment
Acquisition of ADP equipment is unusual because it requires approval by the
Senior Information Resources Management Officer (SIRMO), a designated
person responsible for serving your office on issues related to information
resources management. EPA generally has a contract in place under which
COs place delivery orders for PCs and associated software and hardware.
You must prepare a PR and obtain the SIRMO's review and approval before
you send the PR to the designated purchasing/contracting activity.
Conferences/Meetings
Federal regulations require agencies that need conference facilities first
attempt to obtain facilities within the agency. If none are available, the
Facilities Management and Services Division must try to help you find space
elsewhere within the Government. If both attempts are unsuccessful, you
may then consider non-Government facilities.
You may informally survey hotels or other facilities to determine space
availability and cost estimates. If the estimated cost is over $2,500, at least
three sites must be considered. You must then prepare a PR and submit it
to the purchasing activity. Include the conference title, dates, number of
attendees, agenda, and a list of any audiovisual or other equipment needed.
Do not indicate to any vendor that you intend to use their site until the
purchasing activity has approved your selection of a vendor.
Conference facilities within a 50-mile radius of your office require special
procedures. Contact your servicing Finance Office for more information.
You may acquire a conference room only. You may also acquire conference
space, lodging, and meals if they are part of an official training session. If
lodging and meals are included, you may not exceed the applicable per diem
rate in that location. Use of a purchase order sometimes allows an exemption
from certain types of hotel taxes. The dollar limit on purchase orders is
$25,000. Bankcards may not be used to acquire conference facilities.
Agencies may use appropriated funds to pay for conference rooms,
audiovisual equipment rental, lodging, and/or meals. At EPA "Abatement,
Control and Compliance" funds are generally used. The cost of coffee and
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other refreshments at breaks generally is not allowable. Appropriated funds
may never be used to pay for alcoholic beverages.
The Comptroller General has issued many decisions on allowable costs for
conferences and training. To consolidate the principles contained in those
earlier decisions, EPA issued several Controller Policy Announcements.
Comptroller Policy Announcement No. 92-07 entitled "Procuring
Subsistence for Training/Conferences/Meetings", issued in August 1992,
updated all earlier issuances. It will be incorporated into the Resources
Management Directives System, Chapter 2550B - EPA Travel. Your
purchasing activity can assist you if you have questions about conferences,
meetings, or training.
Contracting With Former EPA Employees
To avoid favoritism or the appearance of favoritism toward former EPA
employees, EPA implemented FAR requirements in establishing the
following policy:
D No contract (including purchase orders) may be awarded without
competition to a former regular or special EPA employee (or to a
business concern or other organization owned or substantially
owned or controlled by a former employee) whose employment
terminated within 365 calendar days before submission of a proposal
to EPA.
D No contract shall be awarded without competition to a firm which
employs (or proposes to employ) a current regular or special EPA
employee or one whose employment terminated within 365 calendar
days before submission of a proposal to EPA if either one of the
following conditions exist:
The employee is or was involved in developing or negotiating the
proposal for the prospective contractor; or
The employee will be involved directly or indirectly in the
management, administration, or performance of the contract.
The Assistant Administratorfor Administration and Resources Management,
in consultation with the Agency Ethics Official, may authorize an exception.
If you require an exception, you must submit a written request with a sole
source justification approved by the CO to the AA through the Ethics Official.
A sole source justification involving a former EPA employee whose
employment was terminated less than 365 days must indicate the measures
taken to perform the requirement in-house.
You must also write the statement of work to satisfy minimum needs. You
may not be so restrictive that only the former employee can submit a
meaningful proposal.
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Status Of PRs
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Purchasing activities send a copy of each order to the requisitioner when the
order is issued. You should retain the copy until the items or services are
received. In the event you do not receive a copy within the leadtimes stated
above, you may obtain status in two ways.
You may call the purchasing activity. Be sure to reference the account
number and document control number.
Purchasing activities at Headquarters, RTP, and CINN have automated
systems that may be accessed by program offices. Instructions (titled
Remote Query Instructions) on accessing the Small Purchasing Automated
Management System (SPAMS) at Headquarters are available from the
Small Purchases Unit. The customer service telephone number is
202-260-2943. Contact the small purchase activity at RTP and CINN for
instructions for the other systems.
If you know the purchase order number, you may contact the vendor
regarding delivery dates, etc.
Contractor Performance Reports
To ensure satisfactory performance and timely delivery by vendors, you
should notify the purchasing activity if vendors do not provide the supplies
or services ordered or deliver late. The purchasing activity will use that
information to evaluate vendors for future awards. You should also request
the assistance of the purchasing activity if adjustments are required of the
vendor.
Future Automation
Efforts are underway to automate the PR process Agency-wide. Preparation,
approval, and transmission of forms may eventually be accomplished
electronically. See your supervisor for the status of this initiative.
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If it's September 30th and it's Midnight-
Then it's too Late!
PURCHASING AGENT
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