Comment #4 on FAR Case 2006-026, Government wide Commercial Purchase Card Restrictions for Treasury Offset Program Debts

If the government really wanted to solve the problem they'd automate the VISA/GPC system to offset - then they could really realize a savings and not just create more work internally for the agencies. Further, this action could capture transactions below the micropurchase level - which it appears did not get studied - one wonders what those numbers would have brought with the sheer volume at that level! Also, implementation of this rule will likely put an awkward burden on the front-line folks, to have to change the payment method after award/options/delivery orders so that you can withhold payment. Finally, while potential recovery of $73 million sounds like a lot, and that figure represents about the best results that can be hoped for according to this study, this is only 2% of the $3.1 BILLION delinquent debt owed to the US Government. My comment is that this is like swatting mosquitos in the alligator swamp. Are we so confident that we'll get the other 98% that we can spend time/resources on this 2%? Please reconsider this additional burden on contracting/procurement folks and instead fix/automate the payment and credit card systems.