JOINT BASE CHARLESTON, S.C. –
The Department of Defense calls upon its employees to accomplish remarkable things while upholding the highest standard of excellence. Our actions are heavily scrutinized by Congress and the American public, but every day we meet and, most often, exceed the expectations placed upon us. However, in this atmosphere of decreased manning and increased operations tempo, the success we work so hard to achieve sometimes gets tainted by unauthorized commitments made by those who may not understand completely what they can and cannot do when procuring supplies or services. According to the Federal Acquisition Regulation, the rules that outline Government purchasing, only a warranted contracting officer can obligated federal funds. Sometimes it may be tempting to make an urgent purchase when time is tight or a commander wants something right now. But keep in mind all military and government civilian personnel are subject to disciplinary action and may be held personally and financially liable if such a purchase cannot be ratified.
Only warranted contracting officers have the authority to enter into purchase agreements, obligate federal funding and sign contracts on behalf of the government. As a matter of good business, contracting officers consider the advice of specialists in audit, legal, engineering and other fields, as appropriate, but no one other than the contracting officer has either implied or actual authority to negotiate contracts. Ratifications are a process of approving an unauthorized commitment by a contracting officer. As the 628th Contracting Squadron commander, I have ratification authority up to $30,000. Anything above that threshold must be approved through the joint base commander to the Air Mobility Command senior contracting officer. Regardless of the amount involved, ratification procedures are difficult, time consuming and very embarrassing for the individual who made the unauthorized commitment. Additionally, payment to contractors who acted in good faith is unduly delayed, which causes the government needless embarrassment. The contracting professionals who support you can keep you legal and out of trouble in an emergency. We have efficient and effective emergency contracting procedures. Call us, day or night!
The end of the fiscal year is another time when there's the potential for trouble. In an effort to avoid ratifications, improve our customer support and ensure all our funding is obligated this fiscal year, here's how 628th CONS plans to provide for Joint Base Charleston. The end of the fiscal year is quickly approaching. Contracting has established specific timelines to facilitate getting every unit's dollars obligated and, more importantly, supporting every unit's mission in a timely manner. These dates provide the minimum lead times required to ensure purchases are completed and funds obligated before the end of the fiscal year, Sept. 30. Administrative lead times to write contracts vary based on complexity, dollar threshold, item, service or construction projects being purchased. All unfunded requirements should have been already identified through your unit Resource Advisor so that all requirements can be prioritized by Groups and Wings in the coming weeks.
Here are the key dates to remember:
Commodity is a commercial item that can be purchased over the counter such as ink:
*Under $2,500 - use your unit government purchase card until your unit's resource advisor has expended fiscal year funding or Sept. 30.
*Between $2,500 - $25,000 - GPC usage may be authorized if the purchase can be made through a previously competed contract. If GPC is not appropriate, a funded Form 9 must be received by 628 CONS by 6 July 12. GPC usage under a Best Value Determination (BVD) must be received by 3 Aug 12.
*More than $25,000 but less than $150,000- Process the funded Form 9 for receipt by CONS by 6 July 12.
*More than $100,000 - Process the funded Form 9 for receipt by CONS by 6 July 12.
Services are any paid services such as janitorial; basically paying for an individual's time and/or action:
*Under $2,500 (and not recurring) - use your unit GPC card until your unit's RA has expended fiscal year funding or Sept. 30.
*If the service is to be performed on multiple occasions resulting in a total cost of more than $2,500, process a funded Form 9 to CONS by 6 July 12.
*More than $2,500 but less than $150,000 - process a funded Form 9 and Performance Work Statement (PWS) to CONS by 6 July 12.
*More than $150,000 - process a funded Form 9 and PWS to CONS by 6 July 12.
Construction
*Under $2,000- use your unit GPC card until your unit's RA has expended fiscal year funding or Sept. 30.
*More than $2,000- please call the 628th CONS immediately. Both the 628th Civil Engineer Squadron and 628thCONS must coordinate on scope of work, level of effort and magnitude early in the process prior to submission of requirement to CONS. Acquisition development and approvals can take more than 120 days.
The 628th CONS mission is to provide your unit with timely support anytime, anywhere. We have some constraints in the process but will do everything we can to meet mission needs. If requirements occur outside the timelines above, and they often do, please call me. We understand failure is not an option and will find a legal way assist you in your mission.