1. Purpose:

This policy release revises Departmentwide policy on the Contracting Officers Warrant System (COWS) to allow non-procurement staff to purchase off-the-shelf training using the Standard Form-182, Request for Training Form.

2. Effective Date:

Effective upon issuance.

3. Expiration Date:

No expiration unless superseded or canceled.

4. Background and Explanation:

Several bureaus expressed concern that the current policy in the COWS manual on the Standard Form 182, Request for Training Forms, significantly affects their ability to arrange for and deliver group training. They requested that the warrant system be changed to again allow the purchase of off-the-shelf training over $2,500 by non-procurement staff using the SF-182. After considering these issues, we agree to modify the existing policy.

Bureau Procurement Chiefs are now authorized to delegate procurement of off-the-shelf training up to $25,000 using the SF-182s to offices with the need and ability to meet this duty. BPCs are responsible for the proper use of procurement authority warrants and implementation of the warrant system, and may set standards which are more limited than those outlined in the COWS Manual.

BPCs should remind offices charged with this additional authority to challenge published price lists to get better deals and to document attempts to negotiate better prices. It is also important to remind these offices that even though these transactions are exempt from the warrant system, warranted contracting officers are available for assistance and advice.

BPCs are responsible to review the effectiveness of the delegation and must advise the Director - Office of Acquisition and Property Management of any significant problems encountered in the administration of this authority.

The Contracting Officers Warrant System Manual, paragraph 3 is modified to read as follows:

III. EXEMPTIONS FROM THE WARRANT SYSTEM

Part A. Exemptions

The following transactions are not covered by the Federal Acquisition Regulation, and therefore are exempt from the Department of the Interior Warrant System:

* Standard Form (SF) 182, Request for Training Forms - - off-the-shelf training up to $25,000. The purchase of any classes requiring course development or over $25,000 must be completed by a warranted contracting officer.

This change applies only to training that is available off-the-shelf (or with minor customizing to include Interior examples.) For example, this would not include substantial changes to a course's content. Classes requiring course development must continue to be purchased by contracting officers in accordance with the Federal Acquisition Regulation procedures.

5. Action Required: Distribute this policy release and ensure that bureau policy reflects this change.

Any questions on this policy release may be directed to Gayle A. Fischetti on (202) 208-6705.

Debra E. Sonderman, Director
Office of Acquisition and Property Management