Evidently, the GAO seems to have defined de minimus as at or below the micro purchase threshold over the entirety of the purchase order contract, including any option periods. The decisions reviewed, however, included incidental products; there was no mention of services such as travel. Presumably, if an agency has to order incidental services that are not included in any offeror's FSS Schedule, then the requirement for competition will be satisfied by the agency obtaining competitive quotes. If there is full and open competition for these incidental services, then the micro-purchase threshold will not be applicable.
Tom Petruska, Owner
Contracts Unlimited, Incorporated
Do you need assistance with open market items in GSA schedules or other issues?
Footnotes:
1. 10 U.S.C. §2302 (2)
2. 10 U.S.C. §2304
3. 10 U.S.C. §2304 (c)
4. 10 U.S.C. §2302(2)
5. Dictaphone Corp., B-254920; American Body Armor & Equipment, Inc. B-238860
6. Raymond Corp., B-246410 (incidental items amounted to 17% of total contract value)
7. FAR 6.302-1 (c) (1)
8. FAR 6.302-1 (c) (2)
9. B-282469; B-282469.2, July 15, 1999.
10. B-284550.2, August 4, 2000
11. B-285687.2, September 28, 2000
