HomeVA ProstheticsVA Handbook 1173.2 - Furnishing Prosthetic Appliances and ServicesDirect Purchasing by Prosthetic Activities Under COCP

2.9. Direct Purchasing by Prosthetic Activities Under COCP

a. Scope

(1) The Contracting Officers Certification Program (COCP) is a formal process for the delegation of procurement authority to contracting officers. This program establishes a chain of contracting authority within the Department as required by law, regulations, and Executive Order 12931, and ensures a trained, experienced and regulated workforce.

(2) Warrants to Prosthetic and Sensory Aids Service (PSAS) are authorized up to $100,000 for open market purchases and "the maximum order limitation of the contract," which means the money limit is determined by the specific established Federal Supply Schedules, decentralized and local beneficiary service contracts. The purchasing authority encompasses procurement of all items required for the medical treatment and rehabilitation of beneficiaries. Appropriate delegations of authority are required for Prosthetic staff in addition to their warrants to ensure compliance with MP-2, 108-25.5002.

b. Responsibility

(1) Managers of Fiscal Service and Acquisition and Materiel Management Service will conduct periodic reviews, to ensure that Prosthetic purchasing activities are in compliance with applicable acquisition and accounting regulations. Monthly reports are required to provide information for the Federal Procurement Data System (FPDS).

(2) OA&MM is responsible for providing required training to the appropriate prosthetic staff. This training should consist of "VA Small Purchase Procurement Procedures: Level A, Module I & II."

(3) All PSAS personnel involved in purchasing must complete the required training, pass the written exam, and obtain a warrant. A pre-test will be administered by the responsible training official to determine the level of familiarity or training required. A post-test will be administered to ensure successful completion of the training and to issue a warrant. Any PSAS employee requiring a warrant, who has not been provided the requisite training for reasons beyond the employee's control, may be issued an interim warrant for a period of 90 days from the date of issuance.

c. Procedures

(1) VA Form 1358, Estimated Miscellaneous Obligation or Change in Obligation, may be established on a monthly basis for utilizing known sources of procurement not capable of processing orders through the Purchase Card system. VA Form 1358 will be closed on a monthly basis in compliance with established fiscal regulations.

(a) A review of the past 12 months of activity with the source(s) requiring VA Form 1358 use, will be conducted to determine the average monthly allocation.

(b) Funds used in establishing VA Form 1358s are deducted from assigned control points on the basis of appropriate BOC designation. The authorization number, for example C80423, provided by Fiscal Service delineates the year (C8), month (04), and expenditure purpose (23) in an alphanumeric format.

(c) When control point balances are not sufficient to support the VA Form 1358 requirement, a written request to Fiscal Service justifying the need for additional funds will be made.

(d) The IFCAP option of VISTA will be used to create and record sequential transactions against the balance of the existing VA Form 1358. These transactions are identified as purchase order numbers, i.e., #POC40823-0002, when using documents other than those in the Purchase Card system.

(2) Purchase Card Procurement. The Purchase Card, a procurement card with a pre-set monetary limit, will be the primary method of authorizing purchases by designated employees. The use of this card results in obligations against a specific fund control point in a sequential manner. Available fund control balances will not reflect purchase charges until reconciliation of applicable invoices.

(a) PC 2421 is the software option for generating an Purchase Card document containing the necessary information to procure the items and/or services requested.

(b) Whenever feasible, deliveries of Purchase Card items should be made directly to the cardholder. However delivery of equipment and/or supplies may be to the veteran, the Prosthetic Department, or to the facility's receiving warehouse.

(c) A Dispute Officer or Purchase Card Auditor is responsible for coordinating and monitoring billing errors, disputed procurements, and credits which can not be resolved within 30 days. Activity of this type is identified as a Statement of Questioned Item (SQI).

(3) VA Form 10-2421. VA Form 10-2421 will be used when the Purchase Card is not accepted by the procurement source. It must be obligated against an established VA Form 1358. Use of this form will require that the vendor submit an invoice which must be certified for payment purposes.

(4) Rescinding of Procurement Authority by PSAS Under COCP

(a) Authority to procure under COCP may be rescinded when supplies and services are not consistent with organizational responsibilities and are outside the applicable VA Acquisition Regulations (VAAR) and Federal Acquisition Regulations (FAR).

(b) Any decision by the local contracting officer to rescind a warrant for other than normal reasons, i.e., change of duty station, retirement, etc., will be reported to the Deputy Assistant Secretary for Acquisition and Materiel Management and the Chief Consultant, Prosthetic and Sensory Aids Service SHG through the Veterans Integrated Services Network (VISN) Director, along with a complete explanation of the circumstances leading to the rescission action. The decision shall be reviewed by both OA&MM and VHA Program staff. The local contracting officer will be notified in writing as to the concurrence or non-concurrence in the warrant rescission.


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