ALCOAST 332/20 - SEP 2020 INCREASED THRESHOLDS FOR PROCUREMENTS SUPPORTING HURRICANE LAURA RESPONSE, DEPARTMENT OF LABOR LIMITED EXEMPTION AND WAIVER, AND INCREASED THRESHOLDS EXTENSION FOR COVID-19 RESPONSE

R 091555 SEP 20
FM COMDT COGARD WASHINGTON DC//CG-91//
TO ALCOAST
UNCLAS //N07500//
ALCOAST 332/20
COMDTNOTE 7500
SUBJ:  INCREASED THRESHOLDS FOR PROCUREMENTS SUPPORTING HURRICANE LAURA RESPONSE,
DEPARTMENT OF LABOR LIMITED EXEMPTION AND WAIVER, AND INCREASED THRESHOLDS EXTENSION
FOR COVID-19 RESPONSE
A. CPO Memo Increased Thresholds for Procurements Supporting Hurricane Laura Response
Efforts, dated 27 August 2020
B. DHS Acquisition Alert 20-28, DOL-OFCCP Hurricane Laura Limited Exemption, dated 27
August 2020
C. Joint CPO and CFO Memo Further Extension to Increase in Micro-Purchase Threshold and
the Use of DHS Purchase and Fleet Card Transactions Supporting Coronavirus (COVID-19)
Response, dated 27 August 2020
1. Background – An emergency for Hurricane Laura was declared by the President on 24
August 2020 for the states of Louisiana and Texas. To facilitate response to this
emergency, and in accordance with Federal Acquisition Regulation (FAR) Subpart 13.201(g),
the Chief Procurement Officer (CPO) issued REF (A), which increased the micro-purchase
threshold (MPT)(a) to $20,000 in the case of any contract to be awarded and performed,
or purchase to be made, inside the United States; and (b) to $30,000 in the case of any
contract to be awarded and performed, or purchase to be made, outside the United States.
Note that the portion of the FAR 2.101 MPT definition relating to the thresholds for the
Construction Wage Rate Requirements statutes (commonly referred to as the Davis-Bacon Act,
$2,000) and the Service Contract Labor Standards statutes (commonly referred to as the
Service Contract Act, $2,500) do not change.
2. REF (A) also increased the FAR 2.101 simplified acquisition threshold to (a) $750,000
for any contract to be awarded and performed, or purchase to be made, inside the United
States; and (b) $1.5 million for any contract to be awarded and performed, or purchase
to bemade, outside the United States. The threshold for the use of simplified procedures
for certain commercial items in FAR13.500(c) is increased to $13 million for procurements
in support of this emergency.
3. The authority to use these increased thresholds applies only to procurements with
a clear and direct relationship to the support of this emergency.
4. For procurements with a clear and direct relationship in support of Hurricane Laura
response, the DHS purchase card is the preferred method to purchase and pay for goods
and services below the increased MPT.
5. All requests for cardholder increase to the MPT must have Field Organizational Program
Coordinator (FOPC) and Chief of the Contracting Office (COCO) concurrence, and be submitted
to the CGHQ Purchase Card Team identifying the cardholder, account number, and amount of
increase. The CGHQ Purchase Card Team will update the bank's system to reflect the increased
single purchase limit. The system should also be updated to reflect subsequent monthly
purchase limit increases.
6. All purchases must clearly document the direct connection to Hurricane Laura response
when using these increased thresholds for single purchases and all documentation (i.e.
receipts, invoices, etc.) must be maintained to support this effort.
7. As a reminder, CHs should make every effort to obtain three (3) quotes prior to making
purchases. CHs should obtain verification from vendors that commodities are readily
available prior to making the purchase and anticipate increased costs as a result of
“price gouging.” It is imperative that CHs appropriately document why paying more is
justified and the cost is considered fair and reasonable.
8. CHs deployed in response to any related relief effort should make every attempt to
ensure prior approval from their AO is obtained. CHs should contact their AOs and provide
all relevant information so that their AOs can then document the pre-approval by email.
In situations where communication channels are impaired and CHs are prevented from
contacting their AOs, the CHs should document all purchases on the DHS Form 1501. When
communications are resumed, CHs should contact their AOs immediately to obtain the
required approval. Please ensure all documentation is maintained and filed accordingly
for possible future audits/reviews.
9. Procurement officials should take into account local area set-asides, giving first
consideration to small business, local area set-asides when feasible. See Job Aid - Steps
to Comply with Local Area Preference AND Justification for Expenditures
to Other than Local Firms template on the Coast Guard Acquisition Road Map at
https://cg.portal.uscg.mil/units/cg9/Pages/CGArm.aspx
10. Cardholders and Approving Officials must perform timely verification and
certification of statements in the Purchase Card Application (PCA) system. The CGHQ
Purchase Card Team is available to assist with hardcopy certification if there are
issues with accessing PCA.
11. A new FPDS-NG National Interest Action (NIA) code for Hurricane Laura and it has
been added to FPDS as H20L. Please use this NIA Code to track purchases made in support
of response efforts within the E-Contingency Tracker
https://cg.portal.uscg.mil/communities/SILCCOCOBSS/SitePages/DISASTERS.aspx.
FPDS-NG reports must identify the National Interest Action code related to Hurricane Laura
2020 by selecting H20L in the drop-down. When selecting the code, users must also select
a drop-down in the Emergency Acquisition field, as follows: Presidential issued emergency
declaration, or a major disaster declaration.
12. The threshold increases will remain in effect until 30 November 2020 unless otherwise
amended.
13. REF (B) shared U.S. Department of Labor’s Office of Federal Contract Compliance Programs
(DOL-OFCCP) limited exemption and waiver for new Federal contracts providing Hurricane Laura
relief efforts from 27 August 2020 – 27 November 2020. Applicable contracts should contain
the FAR clauses provided in REF (B) which exempt the contractor from developing written
affirmative action programs, preparing reports, or providing notices required by some DOL-
OFCCP administered laws.
14. The exemption and waiver do not exempt a covered contractor from their obligation to
comply with other federal, state and local civil rights laws.
15. REF (C) indicates that the emergency thresholds for COVID-19 response are extended
through 12 March 2021. 
16. Please email questions regarding your purchase card use to the Purchase Card team at
PURCHASE.CARD@USCG.MIL
17. POC: Maroulla Dallas, COMDT (CG-9131), 410-562-9406 or Maroulla.P.Dallas@uscg.mil.
18. Mr. Michael W. Derrios, Head of Contracting Activity, sends.
19. Internet release is authorized.