DEPARTMENT OF THE TREASURY

WASHINGTON, D.C. 20220

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MEMORANDUM FOR BUREAU CHIEF PROCUREMENT OFFICERS

FROM: IRIS B. COOPER, 

SENIOR PROCUREMENT EXECUTIVE, 

OFFICE OF THE PROCUREMENT EXECUTIVE

 

SUBJECT: Class Deviation— The Federal Acquisition Regulation to implement 

changes to the Micro-Purchase Threshold and Simplified Acquisition

Threshold.

1. PURPOSE: This class deviation is issued in accordance with Federal Acquisition 

Regulation (FAR) 1.404 to implement an increase in the micro-purchase threshold (MPT) and 

simplified acquisition threshold (SAT) as authorized by the National Defense Authorization Act

(NDAA) for Fiscal Year (FY) 2018 (Public Law 115-91) (Sections 806 and 805 respectively)

and to implement the requirements of Section 217(b) of the NDAA FY 2017 (Public Law 114-

328) until such time the FAR is amended. 

2. EFFECTIVE DATE: Upon issuance

3. EXPIRATION DATE: Until superseded, incorporated in the FAR or otherwise rescinded.

4. BACKGROUND: The NDAA for FY18 (Public Law 115-91) (Sections 806 and 805 

respectively) increased the MPT to $10,000 and the SAT to $250,000. In addition, Section 

217(b) of the NDAA FY 2017 (Public Law 114-328) amended the definition of micro-purchase 

threshold as defined in FAR 2.101 to increase the MPT for acquisitions from institutions of 

higher education or related or affiliated nonprofit entities, or from nonprofit research 

organizations or independent research institutes, to $10,0001. 

FAR Case 2018-004 has been opened by the FAR Council to implement these statutory changes 

in the FAR. However, it takes time for the FAR to be amended. As a result, the Chair of the 

Civilian Agency Acquisition Council (CAAC) issued CAAC Letter 2018-02 on February 16, 

2018 authorizing civilian agencies, which includes the U.S. Department of the Treasury

(Treasury), to issue a deviation in order to implement these statutory changes prior to

amendment of the FAR2

. The Senior Procurement Executive (SPE) has determined issuance of a 

deviation provides substantial administrative efficiencies and flexibilities for Treasury. Overall, 

this class deviation is authorized in accordance with FAR 1.404 and Department of Treasury 

Acquisition Regulation (DTAR) 1001.404.

 1

This amendment to the FAR was part of the now-closed FAR Case 2017-012. Instead, this amendment has been 

included within FAR Case 2018-004. 2

The CAAC Letter constitutes consultation with the Chairof the CAAC as required by FAR 1.404(a)(1). 

Acquisition Bulletin No. 18-02

Deviation No. 2018-00002

 
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5. DESCRIPTION OF THE DEVIATION: Attachment A of this Acquisition Bulletin (AB)

provides the FAR citations being amended to implement the changes described in Section 1

above. The FAR baseline used for this class deviation is FAC Number 2005-97, effective 

January 24, 2018 (see https://www.acquisition.gov) and AB 17-02 (Deviation No. 2017-

00002) issued August 31, 2017.

6. IMPORTANT INFORMATION

a. General. Not all thresholds related to the MPT and SAT are increased by this deviation. 

Some dollar amounts are set by statute, and are therefore not affected by this deviation. 

For example, the thresholds for the Construction Wage Rate Requirements statute 

(previously known as the Davis-Bacon Act) (i.e., $2,000), the Service Contract Labor 

Standards statute (previously known as the Service Contract Act) (i.e., $2,500), the 

Anti-Kickback Act of 1986, the Fair Opportunity Procedures found in 16.505(b) and a 

few other statutorily established thresholds do not change as a result of this deviation.

b. Government-wide Systems. In conjunction with the actions being taken by the FAR 

Council to implement these changes, other stakeholders are working to address impacts

to government-wide systems such as Federal Procurement Data System - Next 

Generation (FPDS-NG), Contractor Performance Assessment Reporting System

(CPARS), Electronic Subcontracting Reporting System (eSRS) and the beta.sam.gov. 

Until these systems are updated, users will find some inconsistencies and may encounter 

some challenges with the data. Some of these inconsistencies may require manual 

correction by the user’s organization. Treasury has been informed that system owners 

will provide notification to the acquisition community as these changes are 

implemented.

c. Purchase Cardholders. This deviation does not result in the automatic increase of a 

purchase cardholder’s single purchase limit or modify any other prescribed purchase 

card holder limits or Treasury Charge Card Program policies and procedures.

Agency/Organization Program Coordinators will make an assessment based on need and 

submit the assessment to the Office of Procurement Executive (OPE) for final 

determination

7. REQUIRED BUREAU ACTIONS: Bureau Chief Procurement Officers shall take

immediate steps to:

a. Ensure dissemination of this AB to all acquisition personnel; 

b. Update related Bureau policies and procedures, and guidance impacted by this deviation; 

c. Determine how this deviation will affect and take appropriate action oni. Internal systems (e.g., Contract Writing Systems), business processes, and reporting 

requirements; and,

ii. Existing delegated authorities (e.g. warrant contracting officers). This may depend 

on how the Bureau delegated the authority, e.g., Does a contracting officer’s SF 

1402 refer to "the simplified acquisition threshold" or to a set amount of "$150,000"

d. Coordinate with the Office of the Procurement Executive (OPE) in implementing this 

deviation.
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8. ADDITIONAL INFORMATION: See Attachment B for some Frequently Asked 

Questions (FAQ). System specific questions (e.g. FPDS-NG, CPARS and Bureau contract 

writing system) can be addressed by your respective Bureau representatives. General questions 

regarding this AB can be directed to Mr. Thomas O’Linn, who may be reached at 

thomas.olinn@treasury.gov or OfficeoftheProcurementExecutive@treasury.gov.

9. ATTACHMENTS:

a. Attachment A - Acquisition Bulletin No. 18-02 – Class Deviation (Deviation No. 2018-

00002)

b. Attachment B – Frequently Asked Questions (FAQs)
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Attachment A – AB No. 18-02 – (Deviation No. 2018-00002)

Attachment A –

Acquisition Bulletin No. 18-02 –

Class Deviation (Deviation No. 2018-00002)

The following represent the FAR citations being amended by this class deviation to implement 

an increase in the micro-purchase threshold and simplified acquisition threshold as authorized 

by the National Defense Authorization Act for Fiscal Year 2018 (NDAA FY18) (Public Law

115-91) (Sections 806 and 805 respectively) as well as the change to the micro-purchase 

threshold definition found in FAR 2.101(b) as authorized by Section 217(b) of the NDAA FY 

2017 (Public Law 114-328) until such time the FAR is amended.

The FAR baseline used for this class deviation is FAC Number 2005-97, effective January 24, 

2018 (see https://www.acquisition.gov) and AB 17-02 (Deviation No. 2017-00002) issued 

August 31, 2017. Changes to the FAR text as authorized by this deviation are shown by yellow 

highlighted text. Changes to the FAR text as authorized by AB No. 17-02 are shown by light

grey highlighted text. ***** are used to show there is no change in the FAR text proceeding or 

following as a result of this deviation.

Additional instruction. For provisions or clauses being amended by this deviation Contracting 

Officer shall ensure that the following text is inserted after the title of the clauses/provision and 

before the month year: (Deviation No. 2018-00002). For example, the clause title for “Small 

Business Subcontracting Plan (Jan 2017)” which is being amended by this deviation would now 

read “Small Business Subcontracting Plan (Deviation No. 2018-00002) (Jan 2017)”

1. FAR 2.101(b) is amended to revise the existing definitions for “micro-purchase 

threshold” and “simplified acquisition threshold” as follows:

2.101 Definitions.

* * * * *

(b) * * * * *

“Micro-purchase threshold” means $10,000, except it means—

(1) For acquisitions of construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage 

Rate Requirements (Construction), $2,000;

(2) For acquisitions of services subject to 41 U.S.C. chapter 67, Service Contract Labor 

Standards, $2,500; and

(3) For acquisitions of supplies or services that, as determined by the head of the agency, are 

to be used to support a contingency operation or to facilitate defense against or recovery from 

cyber, nuclear, biological, chemical or radiological attack; international disaster assistance (22 

U.S.C. 2292 et seq.); an emergency, or major disaster (42 U.S.C. 5122), as described in 

13.201(g)(1), except for construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate 

Requirements (Construction) (41 U.S.C. 1903)—

(i) $20,000 in the case of any contract to be awarded and performed, or purchase to be 

made, inside the United States; and

(ii) $30,000 in the case of any contract to be awarded and performed, or purchase to be 

made, outside the United States; and
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Attachment A – AB No. 18-02 – (Deviation No. 2018-00002)

(4) For acquisitions of supplies or services from institutions of higher education (20 U.S.C. 

1001(a)) or related or affiliated nonprofit entities, or from nonprofit research organizations or 

independent research institutes—

(i) $10,000; or

(ii) A higher threshold, as determined appropriate by the head of the agency and 

consistent with clean audit findings under 31 U.S.C. chapter 75, Requirements for Single Audits; 

an internal institutional risk assessment; or State law.

“Simplified acquisition threshold” means $250,000 (41 U.S.C. 134), except for–

(1)Acquisitions of supplies or services that, as determined by the head of the agency, are to 

be used to support a contingency operation or to facilitate defense against or recovery from 

cyber, nuclear, biological, chemical, or radiological attack; international disaster assistance (22 

U.S.C. 2292 et seq.); an emergency or major disaster (42 U.S.C. 5122), (41 U.S.C. 1903), the 

term means–

(i) $750,000 for any contract to be awarded and performed, or purchase to be made, 

inside the United States; and

(ii) $1.5 million for any contract to be awarded and performed, or purchase to be made, 

outside the United States; and

(2) Acquisitions of supplies or services that, as determined by the head of the agency, are to 

be used to support a humanitarian or peacekeeping operation (10 U.S.C. 2302), the term means 

$500,000 for any contract to be awarded and performed, or purchase to be made, outside the 

United States.

* * * * *

2. FAR 13.003(b)(1) is amended as follows: 

13.003 Policy.

* * * * *

(b)(1) Acquisitions of supplies or services that have an anticipated dollar value exceeding 

$10,000 ($20,000 for acquisitions as described in 13.201(g)(1)) but not exceeding $250,000

($750,000 for acquisitions described in paragraph (1)(i) of the simplified acquisition threshold 

definition at 2.101) are reserved exclusively for small business concerns and shall be set aside 

(see 19.000, 19.203, and subpart 19.5). 

* * * * *

3. FAR 13.501(a)(2)(i) is amended as follows: 

13.501 Special documentation requirements.

(a) * * * * *(2) * * * * *

(i) For a proposed contract exceeding $250,000, but not exceeding $700,000, the 

contracting officer’s certification that the justification is accurate and complete to the best of the 

contracting officer’s knowledge and belief will serve as approval, unless a higher approval level 

is established in accordance with agency procedures. 

* * * * *
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Attachment A – AB No. 18-02 – (Deviation No. 2018-00002)

4. FAR 19.203(b) is amended as follows: 

19.203 Relationship among small business programs.

* * * * *

(b) At or below the simplified acquisition threshold. For acquisitions of supplies or services 

that have an anticipated dollar value exceeding $10,000 ($20,000 for acquisitions as described in 

13.201(g)(1)), but not exceeding $250,000 ($750,000 for acquisitions described in paragraph 

(1)(i) of the simplified acquisition threshold definition at 2.101), the requirement at 19.502-2(a) 

to exclusively reserve acquisitions for small business concerns does not preclude the contracting 

officer from awarding a contract to a small business under the 8(a) Program, HUBZone Program, 

SDVOSB Program, or WOSB Program.

* * * * *

5. FAR 19.2502-1(b) is amended as follows: 

19.502-1 Requirements for setting aside acquisitions.

* * * * *

(b) This requirement does not apply to purchases of $10,000 or less ($20,000 or less for 

acquisitions as described in 13.201(g)(1)), or purchases from required sources of supply under 

Part 8 (e.g., Committee for Purchase From People Who are Blind or Severely Disabled, and 

Federal Supply Schedule contracts).

6. FAR 19.502-2 is amended as follows: 

19.502-2 Total small business set-asides.

(a) Before setting aside an acquisition under this paragraph, refer to 19.203(b). Each 

acquisition of supplies or services that has an anticipated dollar value exceeding $10,000

($20,000 for acquisitions as described in 13.201(g)(1)), but not over $250,000 ($750,000 for 

acquisitions described in paragraph (1) (i) of the simplified acquisition threshold definition at 

2.101), is automatically reserved exclusively for small business concerns and shall be set aside 

for small business unless the contracting officer determines there is not a reasonable expectation 

of obtaining offers from two or more responsible small business concerns that are competitive in 

terms of market prices, quality, and delivery. If the contracting officer does not proceed with the 

small business set-aside and purchases on an unrestricted basis, the contracting officer shall 

include in the contract file the reason for this unrestricted purchase. If the contracting officer 

receives only one acceptable offer from a responsible small business concern in response to a 

set-aside, the contracting officer should make an award to that firm. If the contracting officer 

receives no acceptable offers from responsible small business concerns, the set-aside shall be 

withdrawn and the requirement, if still valid, shall be resolicited on an unrestricted basis. The 

small business reservation does not preclude the award of a contract as described in 19.203.

(b) Before setting aside an acquisition under this paragraph, refer to 19.203(c). The 

contracting officer shall set aside any acquisition over $250,000 for small business participation 

when there is a reasonable expectation that—

* * * * *
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Attachment A – AB No. 18-02 – (Deviation No. 2018-00002)

7. FAR 19.508(e) is amended as follows: 

19.508 Solicitation provisions and contract clauses.

* * * * *

(e) The contracting officer shall insert the clause at 52.219-14, Limitations on 

Subcontracting, in solicitations and contracts for supplies, services, and construction, if any 

portion of the requirement is to be set aside or reserved for small business and the contract 

amount is expected to exceed $250,000. This includes multiple-award contracts when orders may 

be set aside for small business concerns, as described in 8.405-5 and 16.505(b)(2)(i)(F).

* * * * *

8. FAR 52.203-16 is amended as follows: 

52.203-16 Preventing Personal Conflicts of Interest.

* * * * *

(d) Subcontract flowdown. The Contractor shall include the substance of this clause, 

including this paragraph (d), in subcontracts—

(1) That exceed $250,000; and 

* * * * *

9. FAR 52.212-1 is amended as follows: 

52.212-1 Instructions to Offerors—Commercial Items.

* * * * *

(j) Unique entity identifier. (Applies to all offers exceeding $10,000, and offers at any dollar 

level if the solicitation requires the Contractor to be registered in the System for Award 

Management (SAM) database.)

* * * * *

10. FAR 52.219-9 is amended as follows: 

52.219-9 Small Business Subcontracting Plan.

* * * * * 

(d) * * * * * (11) * * * * * 

(iii) Records on each subcontract solicitation resulting in an award of more than 

$250,000, indicating—

* * * * *

* * * * *

Alternate IV (Jan 2017). * * * * * 

* * * * * 

(d) * * * * * (11) * * * * * 

(iii) Records on each subcontract solicitation resulting in an award of more than 

$250,000, indicating–

* * * * *
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Attachment B – Frequently Asked Question (Reference AB No. 18-02 – Deviation No. 2018-00002

Attachment B –

Frequently asked questions (FAQs)

(Reference: Acquisition Bulletin No. 18-02 –

Class Deviation (Deviation No. 2018-00002)

A. General.

1. Question: Why is a FAR deviation being issued before the finalization of FAR case 2018-

004, which will implement the increase in the micro-purchase threshold (MPT) and 

simplified acquisition threshold (SAT)?

Answer: FAR case 2018-004 is being processed in accordance with the rulemaking process. 

The rulemaking process takes time to complete, thus it will be some time before these 

changes are implemented within the FAR. In the interim, agencies have been authorized by 

the Chair of the CAAC via CACC letter 2018-02 to issue a FAR deviation to implement 

these changes prior to implementation within the FAR. The Treasury Senior Procurement 

Executive (SPE) has determined that Treasury can achieve substantial administrative 

efficiencies and provide additional flexibilities to the acquisition workforce by implementing 

these statutory changes now. 

2. Question: Does the change in the MPT and the SAT affect FAR subpart 22.4-Labor

Standards for Contracts Involving Construction?

Answer: No, it doesn’t. The Construction Wage Rate Requirements statute, previously 

known as the Davis-Bacon Act (DBA) remains at $2,000 (see FAR 2.101(b) definition for 

MPT). Contracting Officers (CO) shall continue to refer to FAR subpart 22.4 for direction 

when acquiring construction subject to the DBA. Additionally, any clause or provision 

prescription tied to the MPT or the SAT still requires a CO to determine whether or not 

applicable clauses or provisions need to be inserted in the solicitation or resultant award.

3. Question: Does the change in the MPT and the SAT affect FAR subpart 22.10-Service

Contract Labor Standards?

Answer: No, it doesn’t. The Service Contract Labor Standards statute, previously known as 

the Service Contract Act (SCA) remains at $2,500 for services (see FAR 2.101(b) definition 

for MPT). COs shall continue to refer to FAR subpart 22.10 for direction when acquiring 

services that are subject to the SCA. Additionally, any clause or provision prescription tied 

to the MPT or the SAT still requires a CO to determine whether or not applicable clauses or 

provisions need to be inserted in the solicitation or resultant award.
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Attachment B – Frequently Asked Question (Reference AB No. 18-02 – Deviation No. 2018-00002

4. Question: Does this deviation, which increased the SAT to $250,000 impact FAR subpart 

13.5, which authorizes the use of simplified procedures for the acquisition of supplies and 

services in amounts greater than the simplified acquisition threshold, but not exceeding $7 

million ($13 million for acquisitions as described in 13.500(c)), including options?

Answer: Yes, it does. The reason is that FAR 13.500(a) identifies the SAT as text (i.e. 

“simplified acquisition threshold”), which ties back to the definition of SAT in FAR 2.101(b)

and thereby is tied to the increase in the SAT. 

5. Question: Does this deviation impact solicitation already issued? For example, I have 

requested quotes from vendors for an acquisition estimated at $5,000 and have received 

several quotes, what should I do?

Answer: This deviation does not impact solicitations already issued. However, as a

Contracting Officer you are to use your best business judgement based on the specifics of the 

acquisition to determine whether or not to it is in the best interest of the Government to 

leverage the changes in these thresholds as authorized by this deviation. This may be to 

continue to proceed without change (e.g. complete the evaluation process and proceed with 

the issuance of the award) or to cancel and convert the procurement to a micro-purchase in 

order to take advantage of the flexibilities afforded by the change in the MPT. 

6. Question: Does this deviation which increases the MPT and the SAT affect emergency 

procedures as prescribed by FAR part 18-Emergency Acquisitions?

Answer: No, it doesn’t as the FAR and Treasury supplemental requirements prescribed to 

support such situations remain unchanged. 

7. Question: Does the new SAT threshold impact ordering under my existing blanket purchase 

agreement (BPA)? I ask as I am an authorized ordering official under a Bureau established 

BPA. 

Answer: The best person to answer this question is the CO administering the BPA. The 

reason is that it depends on many factors, one of which is the language used in the BPA 

concerning ordering. For example, does the text concerning ordering use terms such as 

“SAT" or “simplified acquisition threshold”? If so, then the change in SAT is essentially 

self-executing. Alternatively, the text concerning ordering may use the dollar amounts, such 

as $150,000; thereby there would be no change to those amounts as a result of this deviation.

Altogether, there are a number of issues that need to be reviewed and considered by the CO 

to determine whether not one can leverage the increase in the SAT. 

8. Question: Do I need to still perform past performance evaluations per FAR subpart 42.15-

Contractor Performance Information, for existing awards that were awarded under the 

previous SAT procedures?
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Attachment B – Frequently Asked Question (Reference AB No. 18-02 – Deviation No. 2018-00002

Answer: Yes, as existing awards are not impacted by this deviation. As a result, the FAR 

requirement to perform past performance reports for existing awards above the SAT (i.e. 

$150,000) is still in effect and must be completed by the Contracting Officer/ respective 

Bureau representative responsible for completing past performance evaluations per FAR 

subpart 42.15. See DTAP subpart 1042.15 for additional information as well. 

9. Question: Does the increase in the MPT and the SAT affect the fair opportunity 

requirements described under FAR 16.505(b), which applies to ordering under multi-award 

indefinite-delivery contracts?

Answer: As always, one needs to read the FAR in context given the many nuances and 

prescriptions based on the requirements surrounding a particular acquisition. In this instance, 

the answer is straight forward as FAR 16.505(b) identifies the SAT as text (i.e. “simplified 

acquisition threshold”), which ties to the definition of the SAT in FAR 2.101(b). Therefore, 

as a result of this deviation one can now read the text referring to the simplified acquisition 

threshold as meaning $250,000 instead of $150,000. Nonetheless, FAR 16.505(b) also uses 

the dollar amount of “$3,500”, which is not tied to the MPT definition in FAR 2.101(b)

thereby that dollar amount remains unchanged.

10.Question: Does the increase in the MPT and the SAT affect ordering under FAR subpart 8.4, 

which applies to ordering under Federal Supply Schedule? 

Answer: As always, one needs to read the FAR in context given the many nuances and 

prescriptions based on the requirements surrounding a particular acquisition. In this 

instance, ordering procedures for Federal Supply Schedules is prescribed under FAR 8.405. 

The text used in FAR 8.405 is “micro-purchase threshold” and “simplified acquisition 

threshold”, both terms tie back to the definitions of MPT and SAT in FAR 2.101(b). 

Therefore, as a result of this deviation one could read the text referring to these terms as 

meaning $10,000 and $250,000 respectively. Other than that, there is no other change to the 

ordering procedures or other dollar amounts prescribed under FAR 8.405. 

B. Systems.

11.Question: Does the increase in the MPT and the SAT have any impact on governmentwide 

acquisition systems?

Answer: Yes, raising the MPT and the SAT does impact governmentwide acquisition 

systems such as the Federal Procurement Data System - Next Generation (FPDS-NG), 

Contractor Performance Assessment Reporting System (CPARS), Electronic Subcontracting 

Reporting System (eSRS) and the beta.sam.gov environment. Specifically, these systems 

will require modification to their business rules to use the new values, remove any 

text/screen references that use the exact dollar amount thresholds, and update user 

documentation (user guides, help material, data dictionaries, etc.). These systems rely on text 

prescribed by the FAR as part of its programming logic; therefore, changes will not be made 

until the FAR changes have been implemented.
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Attachment B – Frequently Asked Question (Reference AB No. 18-02 – Deviation No. 2018-00002

The system owners are working on resolving these issues as they prepare for the 

implementation of these changes within the FAR. Until these systems are updated, users 

generating reports from these systems (e.g. FPDS-NG, CPARS, eSRS, etc.) may not receive

accurate information. For example, they may receive error messages; or encounter overreporting of actions due to possible double counting of actions, or under-reporting actions 

due to not capturing actions that fall between the $150,000 and $250,000 threshold.

12.Question: Does the changes to the MPT and the SAT have any impact on the contract 

writing system my Bureau uses?

Answer: It is highly likely that the contracting writing system your Bureau uses will be 

impacted by these changes. Typically, these contract writing systems rely on text prescribed 

by the FAR as part of its clause logic programming. As a result, due to the issuance of this 

deviation it is likely the clause logic programming will need to be updated to ensure the 

proper insertion of FAR, DTAR, DTAP and any Bureau supplement prescribed provisions 

and clauses in solicitations and resultant awards issued by your respective Bureau contracting 

activity. Your respective Bureau representatives are responsible for implementing this 

deviation and ensuring Bureau systems can process acquisitions accordingly.

C. Purchase Card. 

13.Question: Does this deviation result in Treasury purchase card holders single purchase card 

limit being raised automatically to $10,000? 

Answer: No, this FAR deviation does not result in the automatic increase of a purchase 

cardholder’s single purchase limit or modify any other prescribed purchase card holder limits

or policies. Agency/Organization Program Coordinators will make an assessment based on 

need and submit the assessment to the Office of Procurement Executive (OPE) for final 

determination.

14.Question: Does the changes to the MPT and the SAT require an update to my purchase card 

delegation of procurement authority (DPA)?

Answer: Yes, depending on whether or not your Agency/Organization Program Coordinator 

advises you of a change to your single purchase card limit or other cardholder limits. 

However, prior to receiving such notification, Agency/Organization Program Coordinators 

must make an assessment based on need and submit the assessment to the Office of 

Procurement Executive (OPE) for final determination.
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Attachment B – Frequently Asked Question (Reference AB No. 18-02 – Deviation No. 2018-00002

15.Question: Does the changes in the MPT and the SAT authorized by this deviation impact 

Treasury TAGs?

Answer: No, Treasury TAG agencies will not be impacted by this deviation. This deviation 

only applies to the U.S. Department of the Treasury and its Bureaus. TAG agencies with 

their own procurement authority will need to issue their own FAR deviation.

 

16.Question: Does the changes in the MPT and the SAT change the dollar threshold for thirdparty drafts/ convenience checks?

Answer: No, the dollar threshold for third-party drafts/convenience checks is not changed as 

a result of this deviation. 

17.Question: Does the changes in the MPT and the SAT change impact requisitions/ 

procurement requests already submitted to my respective contracting activity? I ask as 

should I cancel the requisition and have the requirement processed via purchase card (in this 

example the requirement is estimated at $5K).

Answer: There should be no impact to requisitions already submitted to your respective 

contracting activity. Nonetheless, Bureau Chief Procurement Officers are responsible for 

implementing this deviation for their respective organization(s); thereby responsible for 

communicating to customers any impact to business processes, such as the submission of 

requirements that could possibly be procured using a purchase card because it now falls into 

the increased MPT. 

D. Contracting Officer Warrant.

18.Question: Does the increase in the SAT affect my Contracting Officer (CO) warrant (i.e. 

Standard Form (SF) 1402)?

Answer: The increase in the SAT should not affect your CO warrant (i.e. SF 1402). 

However, you need to review your SF 1402 to verify there is no impact to your warrant. 

Specifically, you should review to see whether or not language such as "Up to Simplified 

Acquisition Threshold" is used or if a dollar value (i.e. $150,000) is stated instead. The 

reason is that if your SF 1402 states a dollar value then your warrant may be impacted as a 

result of the increase in the SAT. In such instances, you need to contact your respective 

Bureau representative who handles the Contracting Officer warrant program for guidance on 

how to proceed.
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Attachment B – Frequently Asked Question (Reference AB No. 18-02 – Deviation No. 2018-00002

19.Question: Will there by an update to the DTAP concerning the warrant thresholds described 

in DTAP 1001.603-1?

Answer: The Office of the Procurement Executive (OPE) is continuing to review the impact

to policies and procedures such as the Department of the Treasury Acquisition Procedure 

(DTAP). Any amendment to the DTAP will be issued via a separate action. Amendments to 

the DTAP are issued via Acquisition Procedure Updates (APUs).