The 2019 NDAA brought a welcome surprise for many defense contractors—the DoD plans to increase its micro-purchase threshold from $5,000 to $10,000, which matches the increase given to civilian agencies in last year’s NDAA.
Earlier this year, the Civilian Agency Acquisition Council (CAAC) issued a class deviation to the FAR to implement the revised simplified acquisition threshold (SAT) and micro-purchase threshold that were included in the 2018 NDAA before the FAR was revised. These deviations increased the SAT to $250,000 and the micro-purchase threshold to $10,000 (from $150,000 and $3,500, respectively). However, CAAC’s instructions left it to the individual agencies to authorize the threshold changes in their own regulations, which created a less than uniform implementation of these changes across civilian agencies.
Because the 2019 NDAA’s increase to the micro-purchase threshold is applicable only to DoD, it is likely that DoD will act quickly to put in place a similar class deviation until the FAR can be amended to account for the changed limit. Stay tuned to see when this change will become a reality for DoD contractors.
About the Author: Katie Flood is counsel with PilieroMazza in the Government Contracts Group. She may be reached at firstname.lastname@example.org.