Five Card Orders for One Laptop Requirement
A Department of the Air Force program office needs 48 ruggedized laptops for a field exercise starting in 25 days. The identical model is listed at $2,300 per unit, for a total of $110,400. The office holds a government purchase card with a $10,000 single-order limit and proposes to issue five separate card orders of nine or ten laptops each, all to the same reseller, all on the same day, using one funding document. The program manager says this keeps each order under the micro-purchase threshold and avoids a slow competitive solicitation. You also learn that the office bought 12 identical laptops on the same card three weeks ago and that the reseller will ship all 60 units in one delivery. The requirement is severable only by quantity, not by function. The agency's simplified acquisition threshold is $250,000.
1. Identify the FAR principle the program office's plan violates and explain why the 12 earlier laptops matter.
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The plan violates the prohibition on splitting requirements in FAR 13.003(c). The micro-purchase threshold ($10,000 under FAR 2.101) applies to a purchase, not to a requirement that has been carved into pieces. The 48 laptops are one requirement: same model, same funding document, same delivery, same operational need. Dividing them into five card orders would be done solely to stay under the micro-purchase threshold and avoid competition, which is exactly what FAR 13.003(c) forbids.
The 12 earlier laptops matter in two ways. First, they show a pattern rather than an isolated buy. If they were part of the same known need, the aggregate requirement may already exceed $110,400. Second, the earlier buy undermines any argument that the program office did not know the full quantity. The CO should aggregate the requirement, conduct market research, and use the appropriate procedure. At $110,400, the requirement is above the micro-purchase threshold but below the simplified acquisition threshold, so simplified acquisition procedures are available and should be used with competition to the maximum extent practicable.
2. Assume the total requirement is $24,000 and there is no purchase history. May the CO use simplified acquisition procedures, and what competition is required?
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Yes. $24,000 is above the micro-purchase threshold but below the $250,000 simplified acquisition threshold, so FAR Part 13 procedures apply. The CO must still promote competition to the maximum extent practicable (FAR 13.104) and obtain quotations from as many sources as practicable (FAR 13.106-1).
For a $24,000 buy, the CO should normally seek at least three quotes if practicable, document the sources solicited, and use a purchase card only if the card limit and agency policy permit. The CO may not use the card's single-order limit as a reason to split the requirement. If only one source is reasonably available, the CO must document the basis for a sole-source award under FAR 13.106-1(b). The key judgment is that simplified procedures reduce process, not the obligation to compete.
3. What corrective action should the CO take for the original $110,400 requirement, including the 12 laptops already purchased?
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The CO should immediately stop the five card orders and consolidate the requirement. The CO should document the market research and the acquisition strategy, then compete the remaining requirement using simplified acquisition procedures or a formal solicitation if agency policy requires.
For the 12 laptops already purchased, the CO should review whether that buy was itself part of a known aggregate requirement. If it was, the CO should consult counsel about whether the earlier purchase was an unauthorized commitment or a violation of FAR 13.003(c); ratification may be needed if the card holder lacked authority. If the earlier buy was a separate, legitimate micro-purchase at the time, the CO should still document the analysis. The CO should also counsel the program office on the anti-splitting rule and require a single funded requisition for the full quantity. Corrective action should prevent recurrence, not just fix the current buy.