Just as with my Quick Hitter series on the FAR, my Quick Hitter series on the GSAR is meant to simplify contracting business with the government. This time with GSA.
GSAR 513.370 Certified Invoice Procedure, GSAR 513.370-1 Applicability, GSAR 513.370-2 Limitations, GSAR 513.370-3 Invoices
These parts are specific to GSA. However, Let’s start from the beginning. As found in my Quick Hitter on FAR Part 13, the SAT merely requires an abstract and the MPT only requires a GPC. So, both processes are truncated.
In addition, FAR 32.905 depicts what constitutes a proper invoice. Check out my Quick Hitter on FAR Part 32 for more information.
The CO in GSA does not need a purchase order (PO) to acquire or procure. They can use an invoice and use the open market. This means they can just buy it and throw the receipt in the contract file, but I’m guessing supervisors are able to build a wall around this perceived shortcut. After all, contracts are routinely cheaper and better than COTS buys. So, they may be just challenging their COs here.
We synopsized the perimeters for the buy above, but GSA does have limitations. They are that any one purchase cannot exceed the MPT ($10,000), neither side requires a PO and both sides must accommodate both the use of and accounting for the GPC
The CO must verify that the price is reasonable and ensure the invoice matches the agreement and buys not exceeding the MPT can be purchased by a non-warranted employee of the government if authorized by a warranted CO
We’ve also briefly covered proper invoices above. The receiving office must time stamp the invoice upon receipt, verify if the amount matches the sale price, acknowledge acceptance or rejection within seven (7) days complete with certificate of inspection, which is obtained within five (5) days and complete the accounting portion.
One of the most common mistakes or missteps that a contractor makes is that pertaining to invoices. When I served as a CO in the VA’s FSS program, I routinely found improper invoices and supplied each vendor with the text at FAR 32.905 so that they could revise and return.
If you think I can help you then email nicholas.s.robertson@outlook.com for your introductory email and free consultation. 
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