What Can I Buy Using my GSA SmartPay Purchase Account?
It is important to understand the limits on purchase account use and to manage your purchases against those limits.
You are allowed to purchase any commercially available supply or service not prohibited by either Federal or agency-specific procurement regulations. To find out your agency specific procurement requirements regarding purchase amounts, receipt documentation and approvals contact your A/OPC or contracting officer. An approval may be required prior to purchase and may be needed in conjunction with a subsequent review of the purchase activity. If a purchase appears questionable, consult your A/OPC or contracting office.
John S. McCain National Defense Authorization Act for Fiscal Year 2019, Section 889(a)(1)(A):
Effective August 13, 2019, Federal Acquisition Regulation (FAR) Case 2018-017 amends the FAR to implement section 889(a)(1)(A) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 to better mitigate risks from identified foreign actors.
This interim rule prohibits agencies from procuring, obtaining, extending, or renewing a contract for equipment, systems, or service that uses covered telecommunications and video surveillance equipment or services. This applies to purchases of commercial and off-the-shelf items made at or below the Simplified Acquisition Threshold and the micro-purchase threshold.
Applicable FAR clauses are required in all solicitations to prohibit the use of covered equipment, systems, or services and will require all offerors to identify any covered equipment or services that will be provided to the Federal Government. In addition, contractors and subcontractors are required to report any such equipment, systems, or services discovered during contract performance.
Waivers to this interim rule require executive agency head approval and are subject to restrictions. For more information, please consult FAR 4.2104 Waivers.
A list of the sources (“vendors”) of the covered telecommunications equipment and/or services is posted on the GSA SmartPay website at: https://smartpay.gsa.gov/content/ndaa-section-889
John S. McCain National Defense Authorization Act for Fiscal Year 2019, Section 889(a)(1)(B):
Effective August 13, 2020, Federal Acquisition Regulation (FAR) Case 2018-017 amends the FAR to implement section 889(a)(1)(B) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 which prohibits Federal agencies from purchasing products or services from entities that use covered equipment or services as a substantial or essential component of any system, or as critical technology as part of any system, regardless of whether that usage is in performance of work under Federal contract.
This prohibition applies to all contracts, regardless of dollar amount, including micropurchases on charge cards as well as formal contracting actions.
The full text of the related Federal Acquisition Regulation (FAR) interim rule on section 889 can be
viewed at: https://www.regulations.gov/document?D=FAR-2019-0009-0003.
Government-to-Government Transactions are payments between different agencies (inter-governmental) or within the same agency (intra-governmental). In most instances, these transactions are classified under Merchant Category Code 9399, Miscellaneous Government Services. See Treasury Financial Manual Announcement A-2014-04 , Limitations on Credit Card Collection Transactions and Policy for Splitting Transactions.
Effective June 1, 2015 the Treasury Department lowered the maximum dollar amount allowed for intergovernmental transactions to $24,999 per day (not per single transaction). This change does not impact agency purchases from commercial vendors, either via open market or through GSA Advantage. It does apply to purchases from GSA Global Supply or GSA's retail stores, as well as purchases from Personal Property or GSA Fleet. A few notes to keep in mind:
- Customers cannot divide transactions into smaller pieces to evade this limit. For example, a buyer cannot make two purchases of $15,000 each, because that total on a given day would exceed the $24,999 limit.
- Transactions that exceed the limit will be denied by Vantiv, the contractor Treasury uses to manage transactions.
- Treasury retains the option to lower the limit further at a later date. One goal is to reduce the fees government pays when it accepts the purchase account for large transactions.