COVID-19: Emergency Acquisition Thresholds

On March 13, 2020, President Trump issued a national emergency declaration under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the “Stafford Act”) in response to the Coronavirus (COVID-19) pandemic.

As a result, the Office of Management and Budget (OMB) issued guidance encouraging Federal Agencies to utilize the flexibilities provided under FAR Part 18 – Emergency Acquisitions – for certain procurements.  This includes the temporary increase of the following thresholds:

 

Threshold TypeStandard Threshold FAR Part 18 Thresholds
Micro-Purchase Threshold$10,000* 

$20,000     (domestic purchases)

$30,000     (purchases outside the U.S.)

 

Simplified Acquisition Threshold$250,000* 

$750,000     (domestic purchases)

$1.5 million (purchases outside the U.S.)

 

Simplified Acquisition Threshold – Commercial Items$7 million$13 million

 

*The FY2018 NDAA increased the micro-purchase threshold to $10,000 (formerly $3,500) and the simplified acquisition threshold (SAT) to $250,000 (formerly $150,000). The FAR Council is in the process of updating these thresholds in the FAR.

Department of Defense (DoD) Commercial Item Determinations

On March 27, 2020, the Defense Contract Management Agency (DCMA) Commercial Item Group (CIG) issued a memo with a list of Commercial Item Determinations (CID) for items and services being procured for COVID-19 related activities.  This memo also encourages the DoD acquisition community to use the $13 million simplified acquisition procedures for the products and services it has provided a CID.

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