The Federal Acquisition Streamlining Act of 1994 (FASA) was signed into law on October 13, 1994 by President Clinton. Pursuant to FASA an interim rule for simplified acquisition procedures and FACNET was issued July 3,1995. This interim rule replaced regulation provisions peratining to "small purchases." The rule was effective immediately. The following is a synopsis of the significant revisions to the new regulation (Additional information concerning the FASA and the FAR changes implemented as result may be obtained by contacting the Federal Acquisition Institute.):

a. There is a difference between the simplified acquisition threshold ($100,000) and authorization to use simplified acquisition procedures (SAP). Authorization to use SAP depends upon the extent to which an agency has implemented FACNET. Neither DOL, as an agency, nor any of our contracting activities has implemented FACNET. Therefore, our authorization to use SAP is limited to $50,000.

b. Simplified acquisitions are divided into two types: those using FACNET and those not using FACNET. All DOL acquisitions are currently non-FACNET.

c. Non-FACNET acquisitions between $25,000 and $50,000 must be publicized in the Commerce Business Daily (CBD). In fact, slightly more information is required in the CBD notice for these acquisitions than for acquisitions exceeding $50,000.

d. Contracting officers are encouraged to use approaches in awarding contracts using SAP. Contracting officers may adapt procedures in other parts of the FAR such as Parts 14 and 15. (The old rules were much more restrictive: formerly a contracting officer using Part 13 could only use the procedures set forth in Part 13.)

e. Acquisitions over the micro-purchase limit ($2,500) but not exceeding $100,000 are reserved for small businesses. There are a few exceptions such as required sources of supply or a sole source.

f. Before the interim rule, a small non-manufacturer could furnish any domestically produced or manufactured product on a small business, small purchase set aside. This rule has been abolished. Acquisitions between $2,500 and $100,000 are now reserved for small business and must furnish the product of a small business manufacturer, unless SBA has granted a waiver (see FAR 19.502-2(c).

Be advised, these guidance documents and the videotape are not meant to take the place of reliance upon the revised FAR regulations. They should be used only as an aid to understanding the new provisions.