Comment on FR Doc # 2026-12559

Subject: Unintended Administrative Burden on GPC Purchases Over the MPT (Reference: Proposed FAR Part 40 and 52.240-2) To the FAR Council: I am writing to provide feedback on the proposed rule regarding the consolidation of supply chain and cybersecurity requirements, specifically the removal of Section 889 and related security representations from the System for Award Management (SAM.gov) and the mandate to include FAR 52.240-2 on a per-solicitation basis. While I understand the intent to ensure transaction-specific compliance, this proposed change creates a severe and impractical administrative burden when utilizing the Governmentwide commercial purchase card (GPC) for purchases of standard commercial products that exceed the standard Micro-Purchase Threshold (MPT). This burden is exponentially worse for specialized GPC programs designed for rapid response and overseas support. The Operational Issue: The proposed rule fails to account for the operational reality of the GPC as a streamlined payment method. For simplified acquisitions over the MPT (e.g., standard office supplies, commercial services), the GPC is utilized precisely to avoid the heavy administrative lead times of drafting formal purchase orders and attaching clauses. By removing the representation from SAM.gov, the proposed rule forces cardholders to manually send the FAR 52.240-2 provision to commercial merchants, wait for a signature, and retain the documentation for every single GPC transaction over the MPT. Impact on Specialized GPC Operations (Cardholder Special Designations): This transaction-by-transaction requirement fundamentally breaks the agility of Cardholders (CH) operating under Special Designations (SD), particularly in the following scenarios: Emergency-Type Operations (ETO): During an ETO, CONUS and OCONUS MPTs are significantly elevated, and warranted overseas CHs are authorized to use the GPC to support operations up to the Simplified Acquisition Threshold (SAT). Forcing a CH in an emergency environment to halt critical supply purchases to execute a formal FAR representation with a local merchant defeats the entire purpose of ETO flexibilities. Overseas Simplified Acquisition: Overseas CHs routinely have the authority to use the GPC for commercial purchases up to $25,000. Mandating a formal solicitation and representation cycle for a routine $20,000 supply purchase introduces severe delays, particularly when dealing with foreign commercial merchants who are entirely unfamiliar with complex U.S. regulatory forms. Proposed Realistic Changes: To maintain supply chain security without crippling the efficiency of the GPC—especially during emergencies and overseas operations—I propose the FAR Council adopt one of the following alternatives before finalizing the rule: GPC / SAT Exemption for Commercial Products: Explicitly exempt all GPC purchases for Commercially Available Off-The-Shelf (COTS) items up to the SAT from the transaction-specific FAR 52.240-2 requirement (including ETO and Overseas SDs), provided the vendor has an active SAM registration indicating compliance. Retain an "Entity-Level" Commercial Representation in SAM: Allow vendors whose primary NAICS codes do not involve IT or telecommunications to maintain an entity-level security representation in SAM.gov. If a GPC cardholder verifies the vendor is active in SAM and the purchase does not include IT/telecom equipment, the transaction-specific representation should be waived. Expand the MPT Exemption to all GPC Transactions: Apply the micro-purchase exemptions outlined in the proposed rule to all GPC transactions for non-covered articles, regardless of whether they exceed the standard or elevated MPT, to preserve the GPC's function as a streamlined procurement tool for authorized Special Designations. Thank you for your consideration of the operational impacts on standard and emergency procurement actions.