Click on any of the FAQs below to expand the content each has to offer. To promote compliance with local and Component policy, please direct any questions to your Agency/Organization Program Coordinator, who, when necessary, will escalate them up the GPC hierarchy to your Component Program Manager. If you still have trouble finding the answers to your questions, contact us here for help.
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A micro-purchase is an acquisition of supplies or services using simplified acquisition procedures, the aggregate (total) amount of which does not exceed the micro-purchase threshold.
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No. If the Cardholder (CH) has a requirement exceeding the micro-purchase threshold, the requirement must be sent to the appropriate contracting office for action.
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No. The GPC is only for official, mission-related Government purchases. It cannot be used for personal expenses of any kind. As stated in Section 2.3.5 of the Department of Defense Governmentwide Commercial Purchase Card Guidebook, use of the GPC for purchases for personal, family or household purposes is a violation and will not be tolerated.
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No. A/OPCs shall not issue GPCs to contractors.
However, the General Services Administration (GSA) Contracting Officer for SmartPay® may issue credit cards to contractors to purchase GSA sources of supply or services under cost-reimbursable contracts. The Contracting Officer responsible for the cost-reimbursable contract must authorize the contractor in writing to use GSA sources of supply or services. The contractor must submit a copy of the written authorization and a Request for Eligibility Determination to the GSA SmartPay® Contracting Officer before GSA will issue a SmartPay® credit card to the contractor.
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Purchases made through third-party-payment vendors such as PayPal, Venmo, Square, Stripe, and Zelle are authorized only when they are unavoidable.
Where it is identified that a purchase will be processed via a third-party-payment vendor, Cardholders (CHs) are required to make every attempt to choose another vendor. If it is still determined to be necessary to purchase from a vendor requiring use of a third-party payment processor, CHs must ensure:
Approving/Billing Officials are required to ensure there is adequate supporting documentation showing that (1) a detailed purchase review was completed and (2) purchase from a vendor requiring use of a third-party-payment processor was unavoidable.
Caution:Third-party-payment vendors such as PayPal, Venmo, Square, Stripe, and Zelle are considered high-risk transactions for both audits and data mining screening.
Note:Third-party payments may mask the name of the actual vendor, thereby circumventing Merchant Category Code blocking as an effective internal control and potentially allowing payments to counterfeit operations and other questionable vendors while losing valuable GPC data. Additionally, use of third-party payment processors can adversely affect reporting, reconciliation, and oversight, (including data mining improper use detection) and also may adversely affect transaction dispute terms and processes.
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Check your Service/Agency policy.
In 1987, the Government Accountability Office (GAO) overruled 52 Comp. Gen. 504, concluding that the rules for office decorations should be the same whether the decorations are seasonal or permanent (67 Comp. Gen. 87, 1987). Thus, seasonal decorations are permissible “where the purchase is consistent with work-related objectives [such as enhancement of morale], agency or other applicable regulations, and the agency mission, and is not primarily for the personal convenience or satisfaction of a government employee” (Id. at 88. See also B-226781, Jan. 11, 1988). The rationale of 67 Comp. Gen. 87 does not apply to Christmas cards, which remain “basically individual good will gestures and are not part of a general effort to improve the work environment” (Id. See also B-247563.4, Dec. 11, 1996).
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Check your Service/Agency policy. Is the ceremony a traditional groundbreaking expense or a dedication for the laying of a cornerstone in public buildings?
For example, in Government Accountability Office (GAO) Decision B-158831, June 8, 1966, the cost of flowers used as centerpieces at a dedication ceremony was held to be a proper expenditure (See also GAO Decision B-247563.4, Dec. 11, 1996, regarding a floral centerpiece at an awards ceremony). Similarly, the cost of engraving and chrome-plating a ceremonial shovel used in a groundbreaking ceremony was viewed as a necessary expense of the ceremony in GAO Decision B-177788 (1973). In the cited decision, however, the voucher could not be paid because there was no evidence as to who authorized the work, where the shovel originated, the subsequent use to be made of the shovel, and why there was a year's delay between the ceremony and the engraving.
Agencies should develop policy in alignment with the GAO decisions to ensure uniformity in the use of appropriations to purchase flowers, groundbreaking shovels, etc. for traditional ceremonies and dedications.
Note:These items remain the property of the Government and may not be given away as gifts or door prizes.
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Check your agency policy. Government Accountabilty Office (GAO) Decision B-302993, June 25, 2004, stated that agencies should develop an agency policy to ensure uniformity in the use of appropriations to acquire kitchen appliances and determine the usefulness of appliances such as these in light of operational benefits, such as employee health and productivity, and the responsibility to provide a safe work environment.
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Special drinking water may be purchased with appropriated funds in situations where water supply systems providing service to DoD organizations do not meet the standards prescribed in 40 CFR, Part 141, National Primary Drinking Water Regulations, Subpart C, only when it is necessary from the Government’s standpoint, such as when:
Consult agency policy and coordinate with facilities personnel to ensure the GPC file contains documentation stating the drinking water is non-potable, along with a public announcement or a copy of the water testing results. Obtain written coordination from the agency Judge Advocate General/General Counsel and confer with an agency Financial/Resource Manager to ensure proper funds are in place.
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No. U.S. Government funds paid for the supplies, as well as any gift certificates, items, rebates, etc. are the property of the U.S. Government. Check your Service/Agency policy on the appropriate process to handle these items.
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Delegation of Authority Letters shall be reissued when there is a change to any part of the Delegation of Authority Letter; e.g., name, single purchase and monthly limits (even if the change is for one purchase/payment); monthly limits, etc. The Delegation of Authority Letter is a binding authorization and requires an original acknowledgment signature and date from the individual being issued the letter. Pen-and-ink changes are not acceptable for any reason; therefore, any changes require reissuance of the Delegation of Authority Letter.
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Immediately notify the card-issuing bank, your A/BO, and your A/OPC. You must make these notifications within three working days.
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A split purchase occurs when a requirement that exceeds a CH’s single purchase limit is separated into two or more buys as a means of getting around the purchase limit. No CH may fragment/split purchases that exceed their single purchase limit as means to use the GPC. To do so is a violation of Federal procurement law.
Split purchases include splitting requirements among merchants; splitting requirements among CHs and splitting requirements over a period of time. Requirements that exceed the CH’s single purchase limit must be sent to the contracting office for award.
A/BOs and CHs should contact their contracting office when they identify repetitive requirements for supplies, services, or construction increasing to levels that will surpass the CH’s single purchase limit. The contracting office may establish Blanket Purchase Agreements (BPAs) or other contracting instruments that will allow the CH to place orders at a higher level than the micro-purchase thresholds to avoid splitting requirements while negotiating better pricing and delivery for the best interest of the Government.
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You can find an interactive state tax information tool on the GSA website.
As an example, for the state of Kentucky, GPC purchases are exempt from state sales tax. (Note: The GSA Office of Charge Card Management confirms that GPC accounts are considered centrally billed accounts (CBAs).)
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No. This type of clothing is not required by law or regulation. GAO Decision B-289683 (October 7, 2002) considers clothing to be a personal expense of the employee, and appropriated funds are not generally available for personal expenses. Every Government employee is required to present themself for duty properly attired according to the requirements of their position.
Note:Clothing required by law or regulation is generally provided to the employee by a clothing allowance.
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Per Government Accountabilty Office (GAO) Decision B-289683, the Government may provide protective clothing if the Agency determines that it is necessary under the Occupational Safety and Health Administration’s implementing regulations. Check your Service/Agency policy. Protective clothing, safety shoes, etc. are generally provided through a clothing allowance to the employee. All purchases of protective clothing, safety shoes, etc. require approvals from the appropriate Safety Officer and Resource Manager.
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Yes; however, if a vendor is imposing a surcharge or checkout fee, the Cardholder (CH) may want to consider another vendor that offers the same or similar item(s), to avoid paying the surcharge.
If a surcharge is imposed, the CH shall ensure:
Note:Not all vendors will choose to impose a surcharge, and each state may have its own policy regarding surcharge allowability.
For more information, please refer to the GSA Smart Bulletin No. 17.
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Separation of duties is key to the success of the GPC Program. Duties such as making purchases, authorizing payments, certification of funding, and reviewing and auditing functions are assigned to different individuals to minimize the risk of loss to the Government to the greatest extent possible.
Requirements are as follows:
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No. GPC purchases are paid by the Government, not by the individual CHs. Also, the GSA SmartPay® 3 master contract prohibits the release of personal or confidential information to credit bureaus.
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No. Non-Government websites, blogs, newspapers, magazine articles, TV/radio reports, etc. are not official guidance for the GPC Program. Official GPC Program information and resources are available on the Defense Pricing, Contracting, and Acquisition Policy (DPCAP) website and individual Service/Agency websites. A/BOs and CHs can also obtain answers to their GPC questions by contacting the A/OPC responsible for the oversight of their GPC accounts.
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No. Per Section the Department of Defense Governmentwide Commercial Purchase Card Guidebook, use of the GPC to purchase cash advances, including money orders and travelers’ checks, is prohibited because cash and near-cash is easily misappropriated.
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No. Per the Department of Defense Governmentwide Commercial Purchase Card Guidebook, use of the GPC for travel-related expenses is prohibited.
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No. Per Section A.1.2.4 of the Department of Defense Governmentwide Commercial Purchase Card Guidebook, use of the GPC for travel-related expenses is prohibited.
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Yes. Per the GSA SmartPay 3 Master Contract, Section C.3.3.14.1; and Department of Defense Governmentwide Commercial Purchase Card Guidebook, Section, the account holder (CH) has 90 calendar days from the date of the transaction as reflected in the bank’s system, to dispute a transaction.
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No. Per Section A.1.2.4 of the Department of Defense Governmentwide Commercial Purchase Card Guidebook, use of the GPC to purchase weapons, ammunition and explosives is prohibited.
As controlled DoD commodities, weapons, ammunition, and explosives are assigned to the Army (see DFARS 208.70), which has contracting responsibility to supply all DoD Components with weapons, ammunition, explosives, and other commodities listed in DFARS PGI 208.7006. DoD Components are to submit their commodity requirements via Military Interdepartmental Purchase Request to the assigned Component in accordance with DFARS 208.7002 and DFARS PGI 208.7002-1. There are no exceptions.
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A summary of required GPC training courses by role is available on the DPCAP's Purchase Cards - Training webpage.
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The Defense Acquisition University (DAU) course "Certifying Officer's Legislation (COL) for Purchase Card Training" (currently CLG 006) is available on the DAU website is available on the DAU website.
Because this course specifically addresses GPC content, Certifying Officers who have previously completed an alternate authorized COL training module are encouraged to take this course as soon as practicable. However, current Certifying Officers are not required to take this course or an alternate approved course until their annual refresher training is required. As individual Defense Components may require completion of alternate or additional course materials, please consult your Component procedures to ensure compliance.
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Yes the ability to appoint GPC Certifying Officers using the Joint Appointment Module (JAM) was released on 15 December 2018. JAM allows users to view and print their DD Form 577. It also allows individuals with the DD577 View Only Role (including DFAS) to see all appointments..
JAM web-based training is available at:
https://pieetraining.eb.mil/wbt/xhtml/wbt/jam/index.xhtml
Please remember that in accordance with DoD FMR Volume 5, Chapter 5, Paragraph 050401.F, Certifying Officers who certify manual vouchers or submit manual certifications of electronic payments must submit original, manually signed DD Form 577s to the DFAS Indianapolis (DFAS-IN) disbursing official (secure email: dfas.indianapolis-in.jfd.mbx.dfas-incddd577@mail.mil).
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Yes. Limitations on advance payments do not apply to advance payments authorized by law for subscriptions or publications. Advance payment is authorized in Title 31 of the United States Code (U.S.C.) Section 3324(d)(2) for “charges for a publication printed or recorded in any way for the auditory or visual use of the agency.” CHs must place subscription orders in the name of an organization or a position title (e.g., Building Manager or Director, XXX Division) rather than in the name of an individual employee. CHs must retain the renewal notice or a statement that reflects the beginning and ending date of the subscription service.
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No. Title 5 U.S.C Section 5946 states the following:
“Except as authorized by a specific Appropriation, by express terms in a general appropriation, or by sections 4109 and 4110 of this title, appropriated funds may not be used for payment of—
Membership fees or dues of an employee as defined by section 2105 of this title or an individual employed by the government of the District of Columbia in a society or association; or
Expenses of attendance of an individual at meetings or conventions of members of a society or association.”
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Yes, with certain limitations. Title 5 U.S.C Section 5757 states the following:
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The card-issuing bank shall not deactivate any account during a Government-wide shutdown unless otherwise required by GSA or the Agency/organization. However, before an anticipated shutdown, A/OPCs may want to reduce GPC transaction limits to $1 to minimize risk. CHs must be extremely careful during a Government-wide shutdown, especially if the shutdown occurs over a weekend. The Anti-Deficiency Act (ADA) prohibits most Agencies from incurring obligations in the absence of appropriations (unless otherwise allowed by law or for emergencies involving the safety of life or limb, the protection of property, or other excepted services). Funding authority to operate will be issued through Office of the Under Secretary of Defense (Comptroller) command channels. Due to the ADA prohibitions, it is crucial that any GPC use during a shutdown is preapproved by the Resource Manager. ADA violation penalties are severe, and a CH could be fined or imprisoned for violating the statute.
To minimize Prompt Payment Act (PPA) interest, all GPC Program officials should ensure that all accounts are current and up to date before a Government shutdown, as PPA interest continues to accrue during a shutdown. Delinquent accounts are subject to suspension or cancellation as early as 61 days after becoming delinquent but must be suspended or canceled within 180 days as required by the GSA Master Contract. A/OPCs must work with the card-issuing bank if this situation applies.
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No. You must send this requirement to the supporting contracting office for action. GPC Overseas Simplified Acquisition Cardholders reaching back to vendors in the United States are limited to the applicable micro-purchase threshold (generally $10,000, but see FAQ number 2 above).
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CHs are allowed to purchase from vendors that include a tariff charge in their quoted price if they are authorized to make the purchase and the price is reasonable.
If the inclusion of the tariff causes the quoted price to exceed the CH’s single purchase limit (SPL), the CH should:
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ORF involves a separate budget allocation for the use of appropriated funds for official representation purposes throughout the Department of Defense (DoD), pursuant to the DoD Annual Appropriations Act and United States Code (U.S.C.) Title 10, Section 127. ORF funding is designated for a specific purpose: to facilitate official representation activities that further the interests of the United States. Per DoD Instruction (DoDI) 7250.13, Use of Appropriated Funds for Official Representation Purposes, paragraph 3a, Policy, “The authority within the AAA shall be used to host official receptions, dinners, and similar events, and to otherwise extend official courtesies to guests of the United States and the Department of Defense for the purpose of maintaining the standing and prestige of the United States and the Department of Defense. These events are normally hosted and attended by (not simply sponsored by) members of the Senior Executive Service (SES) or flag officers (FOs). In lieu of an SES or FO, when the situation warrants, the ability to host and attend these events can be delegated to a GS15/NSPS equivalent or 06 level of leadership. If an event involves a base/ship commander, the level of leadership can be delegated to an 05/06. These exceptions should be documented within the ORF package.”
Components are required to ensure appropriate management controls are established in Component-level policy when the GPC is used to make ORF purchases. These controls must require issuance of card accounts dedicated for ORF purchases (i.e., do not comingle standard open-market micro-purchase and official representation transactions on a single card account) and assignment of an authorized ORF line of accounting. Additionally, Components must ensure appropriate spending and Merchant Category Code (MCC) limitations are assigned to these accounts and any necessary preapprovals for ORF purchases are in place to avoid misuse of Government funds, gold-plating requirements, and Anti-Deficiency Act violations.
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Established by DoD in 1990, CAP is a centrally funded program that provides assistive technology (AT) and reasonable accommodations to DoD employees with disabilities and wounded Service members. CAP's mission is to ensure that DoD employees with disabilities and wounded Service members have equal access to the information environment and opportunities throughout DoD. CAP can assist in identifying proper information technology (IT) related accommodation solutions and/or purchasing the accommodation at no cost to the employee or employing agency. CAP serves as an additional resource to each agency’s reasonable accommodation process.
Before purchasing accommodation solutions using the GPC, Cardholders should obtain documentation that CAP was unable to provide the required item(s). For more information about CAP and the types of accommodations it can provide, visit www.cap.mil.
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Standard practice is to have the card mailed to the CH’s work address in accordance with the GSA SmartPay®3 contract. Using a CH’s home address may be a fraud indicator and should not be a normal practice. However, there are situations where an alternate address, including the CH’s home address, may be valid.
Whether the card is mailed to the CH’s work address or an alternate address—including the CH’s home address, the Department of Defense Governmentwide Commercial Purchase Card Guidebook specifically mandates CHs to maintain the physical security of the card. This includes not keeping the card with the account holder at all times unless operationally required. Physical security of the card, as determined by Component policy, is required.
Examples of alternate address uses include, but are not limited to:
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Some GPC transactions must be reported to FPDS. Each Component must determine which acceptable method it will use to accomplish these requirements.
The GSA OCCM confirmed it reports only high-level GPC data (i.e., total numbers of transactions and dollars) outside the FPDS database and does not associate orders placed using the GPC with specific GSA indefinite-delivery vehicles. OCCM further confirmed that the data it reports is not commingled with data submitted by Components, thus removing any concerns regarding duplicative reporting.
In accordance with DFARS PGI 204.606(5)(ii) DoD Components are required to report:
DFARS PGI 204.606(5)(i) states, “do not report open-market purchases (i.e., not under a Federal Supply schedule, agreement, or contract) made with the GPC valued less than the micro-purchase threshold to FPDS.” FAR 4.606(c) includes a list of actions that are not to be reported, which includes orders from GSA Global Supply, purchases made at GSA or AbilityOne service stores, individual Government personnel training orders, and Defense Printing orders. This list should be reviewed in detail.
Guidance to support Component decisions on how best to accomplish GPC-related FPDS reporting requirements is available in DFARS PGI 204.606(5). At a high level, DoD requires that:
Helpful Hint: Search DFARS PGI 204.606 using the keyword “card” to quickly find relevant sections.
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Maybe. UAS can pose significant cybersecurity risks, so use of the GPC to purchase them is limited. On February 26, 2025, the Principal Director, Defense Pricing, Contracting, and Acquisition Policy, signed the memo "Updated Unmanned Aircraft System Governmentwide Commercial Purchase Card Prohibited Purchase Limited Exception to Policy Requirements," updating the requirements for a limited exception to the GPC UAS purchasing prohibition. See FAQ 42 for UAS Procurement and Operation policies.
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No. This FAQ will be updated once SAM deploys the list.
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UAS Procurement and Operation policies can be accessed by CAC holders after they are granted access to a DoD SharePoint Site. Follow this link to request permission:
https://intelshare.intelink.gov/sites/DoDJRASE/SitePages/Home.aspx.
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