3.2 Simplified Acquisition Procedures (SAP) & Micro-Purchases (FAR Part 13)

3.2 Simplified Acquisition Procedures (SAP) & Micro-Purchases (FAR Part 13)

FAR Part 13 codifies the rules and procedures for Simplified Acquisition Procedures (SAP) and Micro-Purchases. The primary objective of FAR Part 13 is to streamline the acquisition process for small-dollar purchases, reducing administrative overhead for both executive agencies and commercial contractors, while maximizing small business participation and maintaining high standards of fiscal integrity.

Under FAR 13.002, simplified acquisition procedures are designed to:

1. Reduce administrative costs in acquiring supplies and services;
2. Improve economy and efficiency in soliciting, evaluating, and awarding contracts;
3. Avoid unnecessary burdens on agencies and contractors; and
4. Encourage suppliers to do business with the Federal Government.

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Mandatory Application & Statutory Threshold Architecture

Contracting officers are mandated to use simplified acquisition procedures for all acquisitions of supplies or services not exceeding the Simplified Acquisition Threshold (SAT), unless the requirement can be satisfied through mandatory sources of supply under FAR Part 8 (such as Federal Prison Industries, AbilityOne, or existing Federal Supply Schedules).

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Micro-Purchase Procedures (FAR Subpart 13.2)

A micro-purchase is an acquisition of supplies or services using simplified procedures, the aggregate amount of which does not exceed the micro-purchase threshold defined in FAR 2.101.

Key Procedural Rules governing Micro-Purchases:

• No Formal Competition Required (FAR 13.203(a)): Micro-purchases may be awarded without soliciting competitive price quotations if the Contracting Officer or authorized cardholder considers the price to be fair and reasonable. Verification of price reasonableness is required only if the cardholder suspects the price may be excessive or if purchasing an item for which no comparable pricing history exists.
• Equitable Distribution (FAR 13.203(a)(1)): Micro-purchases must be distributed equitably among qualified suppliers to the extent practicable. Cardholders are prohibited from placing repetitive orders with a single preferred vendor when other qualified local suppliers are readily available.
• Primary Purchase & Payment Method (FAR 13.201(c)): The Governmentwide Commercial Purchase Card (GPC) is the preferred purchasing and payment method for micro-purchases across all executive agencies.
• Prohibition Against Splitting Requirements (FAR 13.003(c)): Requirements aggregate based on total known agency needs. Dividing a requirement into multiple smaller acquisitions to remain below the MPT or avoid competition rules is illegal.

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Simplified Acquisition Procedures between MPT and SAT ($15,000 to $350,000)

For acquisitions exceeding the micro-purchase threshold ($15,000) up to the simplified acquisition threshold ($350,000), specific statutory rules apply:

1. Mandatory Small Business Set-Aside (FAR 19.502-2(a))

Each acquisition of supplies or services with an estimated value exceeding the MPT ($15,000) but not exceeding the SAT ($350,000) is automatically reserved exclusively for small business concerns. This statutory set-aside is mandatory unless the Contracting Officer determines there is no reasonable expectation of receiving quotes from at least two responsible small business concerns capable of offering the required products or services at fair market prices (the "Rule of Two").

2. Promoting Maximum Practicable Competition (FAR 13.104)

Contracting officers must promote competition to the maximum extent practicable to obtain supplies and services from the source offering the best value. When soliciting quotes:

• Oral Solicitations (FAR 13.106-1(c)): Permitted for minor acquisitions not exceeding $25,000 when written solicitations are impractical or inefficient.
• Electronic Solicitations: Standard practice using electronic commerce platforms or posting Requests for Quotations (RFQs).
• Minimum Quote Rule: Contracting officers should generally solicit quotes from at least three qualified sources when public posting is not conducted.

3. Publicizing Requirements (FAR 5.101 & FAR 13.105)

• Under $15,000: No public synopsis or posting required.
• Over $15,000 up to $25,000: Displaying notice in a public place at the contracting office or posting on an agency website for at least 10 days.
• Exceeding $25,000: Mandatory electronic public posting on the Government Point of Entry (GPE, SAM.gov) pursuant to FAR 5.101(a)(1), unless a statutory synopsis exception applies under FAR 5.202.

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Simplified Procedures for Commercial Items up to $7.5M / $15M (FAR Subpart 13.5)

Under FAR Subpart 13.5, Congress established permanent authority for Contracting Officers to use simplified acquisition procedures to acquire commercial products and commercial services up to $7.5 million (or $15 million for acquisitions conducted in support of a contingency operation, humanitarian assistance, or defense against chemical, biological, radiological, or nuclear [CBRN] attack).

Operational Advantages of FAR Subpart 13.5:

• Eliminates formal FAR Part 15 source selection requirements while handling high-dollar commercial procurements;
• Allows comparative evaluation of commercial proposals using streamlined review methods;
• Drastically reduces solicitation response times and documentation burdens; and
• Requires public notice on SAM.gov under FAR 5.101, but permits flexible, simplified evaluation criteria.

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Strict Prohibition Against Splitting Requirements (FAR 13.003(c))

FAR 13.003(c) establishes an absolute prohibition against splitting requirements:

"A contracting officer shall not split a requirement into two or more purchases that individually do not exceed the simplified acquisition threshold, or the micro-purchase threshold, solely to avoid the application of simplified acquisition procedures or any requirement that applies to purchases exceeding the micro-purchase threshold."

Enforcement & Compliance Scenarios

• Scenario A (Non-Compliant): An agency requires 30 laptop computers valued at $30,000 total. A cardholder with a $15,000 single-purchase limit issues three separate $15,000 card purchases to the same vendor over three consecutive days. Violation: Prohibited split purchase intended to bypass card limits and competitive SAP procedures.
• Scenario B (Compliant): The requirement for 30 laptops ($30,000) is submitted to the Contracting Officer, who issues an electronic RFQ on SAM.gov set aside 100% for small business concerns under standard SAP rules.