The Department of Veterans Affairs (VA) Office of General Counsel overturned the VA’s previous determination that VETS First and Rule of Two did not apply to purchases under the $10,000 micropurchase threshold.  The Office of the General Counsel in fact determined that VA micropurchases also fall under the Vets First and Rule of Two, which opens up an additional $5 billion in business to Service Disabled Veteran Owned Businesses (SDVOSBs). This is especially good news for SDVOSBs that sell products, which are frequently purchased under the micropurchases program.

This follows on the case of PDS Consultants, Inc. v U.S. (Federal Circuit 2018), decided October 17, 2018.  The court determined that the Veterans Benefits, Health Care, and Information Technology Act of 2006, commonly called “VBA,” takes precedence over any other Federally established procurement requirements when applied to purchases by the VA.    

The VA Office of Legal Counsel made a determination that the court’s decision and the legislative requirements applies to all VA purchases, including those under the $10,000 micropurchase threshold.

Five weeks remain of the government’s fiscal year and during the final month many purchases using the Government Purchase Card are made. Therefore, if you haven’t already, now is time to make a final marketing push to VA customers and contracting officers.

As a Veteran-owned Small Business ourselves, Coley GCS takes great pride in our ability to assist other Veterans in selling to the VA.  Also, this legal determination opens new doors for Veteran-owned small businesses, let us know if you want our help. You can reach us via email at or directly by phone at 210-402-6766.

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