Purchasing officer
Identifies the source. Decides what to buy. Signs the SF 44 or places the BPA call. Accepts the supply or service. Builds the purchase file. This is the obligation side.
DAFFARS 5301.603-3 (Air Force)
Field Ordering Officer Program
You've decided you need a Field Ordering Officer (FOO) program. Maybe you're forward in theater and the warranted CO is ten time zones away. Maybe the unit is doing recurring local-purchase buys for fuel, food, or billeting consumables and the round-trip to a contracting office isn't realistic. Whatever brought you here, the next question is the practitioner one: how do you actually stand it up? That's what this page is for. The 10-step build, the Paying Agent boundary, the forms, and the lines you don't cross.
10-step build
FOO + PA
DD 1081 / DD 2665
SF 44 / Imprest
RFO Part 12
The Build
Standing it up, step by step
Ten steps from "we need a FOO program" to "the first transaction is in the file." This is the order to do them in. Steps run roughly sequential, but Steps 2 and 4 (appointing authority and finance integration) you can work in parallel.
| # | Step | What to do |
|---|---|---|
| 1 | Confirm the mission case | Write down the operational reason a FOO program is the most advantageous solution for this requirement. The regs treat FOO appointments as exception-based, so a one-paragraph mission narrative covers you when somebody asks why you didn't just use a warrant or a Blanket Purchase Agreement (BPA). Keep it short and concrete. |
| 2 | Find your appointing authority | Air Force: trace your local Head of the Contracting Activity (HCA), Senior Contracting Official (SCO), and Chief of the Contracting Office (COCO) chain. Army: find the official with delegated appointing authority for ordering officers, generally at or above the CoCO level. A regular warranted CO isn't automatically the issuing authority for a FOO appointment unless local delegation says so. Pull the delegation memo before you draft the letter. |
| 3 | Pick the instrument set and the cap | Decide what the FOO will use. Cash via imprest fund, SF 44 (Purchase Order – Invoice – Voucher), BPA calls, Indefinite Delivery Indefinite Quantity (IDIQ) orders, or some combination. Set a dollar cap that fits the mission, not the maximum the regulation allows. Specify the supplies, equipment, and non-personal services the FOO can buy. The appointment letter has to name all three: instrument, cap, scope. |
| 4 | Bring finance in early | Loop in your Disbursing Officer (DO) and Financial Management (FM) before you finalize anything. If the FOO will use cash or imprest funds, you need a Paying Agent (PA), and you need the DO to agree to advance the cash. Joint contracting-and-finance training is the documented best practice. The Army's been running this exact joint exercise model with contracting and finance battalions training together. |
| 5 | Pick the right people | The FOO needs to be operationally credible, disciplined enough to keep clean files, and willing to push back on commanders who try to pressure the appointment. The FOO and the PA can't be the same person (more on that below). Pick alternates for both roles up front so leave, illness, and personnel moves don't break the program. |
| 6 | Train them | Cover procedures, ethics, procurement integrity, contract action reporting, funds availability, file assembly, invoice and receipt requirements, DD 1081 and DD 2665 handling, and Unauthorized Commitment (UC) prevention. Add scenario-based drills for the actual mission. Joint sessions with finance work better than separate ones. |
| 7 | Issue the appointment letter | The letter names the individual, states that the authority is non-delegable, lists the methods permitted, the subject-matter scope, the dollar cap, the effective period, and the file requirements. Get a signed acknowledgment back. Distribute copies to the appointee, disbursing, cashiers and imprest personnel, and anybody else who'll need to recognize the authority. |
| 8 | Build the file architecture before the first transaction | One purchase-file template per instrument type, with checklists for purchase request, funds certification, market or pricing support as required, receipt and invoice, SF 44 or order documentation, PA receipt documents, DD 1081, DD 2665, review memo, and retention. Get this set up before anyone buys anything. |
| 9 | Pilot narrowly, then watch closely | Run a small first cohort. Review every transaction in the first 30 days regardless of what the regulatory minimum says. Air Force rules require 100% surveillance within 30 days plus annual review. Army rules require at least annual review. Run the stricter Air Force cadence either way. You'll catch problems early, and you'll know your file architecture works. |
| 10 | Migrate stable demand out | If a requirement turns out to be steady-state and predictable (recurring IT consumables, monthly fuel deliveries, weekly billeting buys), move it from cash or SF 44 into a BPA, IDIQ task order, or a designated Government Purchase Card (GPC) ordering official. The FOO lane is built for the unpredictable expeditionary stuff. Get the predictable stuff into a vehicle. |
FOO + PA
Two people, two roles
It's important that the FOO program separates the purchasing function from the disbursing function. Someone to buy, and someone to pay. Two roles, two letters, two people. DoD Financial Management Regulation (FMR) Volume 5 says paying agents may not act as purchasing officers. That's the rule.
Paying agent
Holds advanced cash. Makes the disbursement. Returns vouchers. Settles the account. PAs are accountable officials and pecuniarily liable for the funds in their possession. PAs get appointed only when adequate payment, check-cashing, or currency-conversion services aren't otherwise available.
DoD FMR Vol 5
One person, one role
FOO and PA stay separate. Different appointments, different files, different people. Build alternates for both so the program doesn't collapse when somebody takes leave or rotates out.
DoD FMR Vol 5
Forms and Cadence
Where the paper trail lives
The DD 1081 advances cash from the DO to the PA and settles the account when the cash comes back. The DD 2665 is the contingency turn-in document. Surveillance cadence is what makes the program self-correcting.
| Form / Cadence | Purpose | Practical rule |
|---|---|---|
| DD 1081 Statement of Agent Officer's Account | DO advances cash to the PA. Same form settles the account when the PA returns paid vouchers, negotiable instruments, and residual cash. | PA can't commingle funds. Can't advance cash to anyone else. Generally can't keep advanced cash overnight. Normal turn-in within 24 hours. Scanned submissions allowed in remote locations if the parent DO approves. |
| DD 2665 Daily Agent Accountability Summary | Contingency turn-in. PA prepares it the day they turn in business to the DO. | Required for contingency PAs. Day-of-turn-in, not retroactive. |
| Air Force surveillance | 100% transaction review. | Within 30 days of each transaction, plus annual review of all FOO program records. Written findings retained 3 years. |
| Army oversight | Technical supervision plus periodic record exam. | At least annual examination. Written findings retained 1 year. |
| House call | Use the Air Force cadence either way. | Monthly 100% review beats annual review. You spot trends sooner, you fix them sooner, and the program runs better. |
Hard Limits
What a FOO can't do
The lines on the appointment letter are real lines. Stay inside them and the program runs clean. Step over them and the authority doesn't exist for that buy.
Outside the named scope
If the buy isn't in the supplies, equipment, or non-personal services scope on the letter, the FOO doesn't have authority for it. That includes drift into adjacent commodities. The scope is the scope.
DAFFARS 5301.603-3
Above the cap
The lower of the regulatory threshold, the contract limit, the theater business-clearance restriction, the funds available, and the appointment-letter cap wins. Always. Whichever number is smallest, that's your ceiling.
FAR 2.101 thresholds
Personal services
The FOO appointment text covers non-personal services. Personal services contracting is a different authority with different controls. Don't draft an appointment letter so broadly that it would appear to authorize personal services.
DAFFARS 5301.603-3
Sub-delegation
A FOO can't delegate the authority to anyone else. The appointment runs to a named individual. Need backup coverage? Appoint an alternate FOO directly. The FOO themselves can't pass the authority along.
DAFFARS 5301.603-3
Splitting
Breaking one $24K buy into two $12K buys to stay under a $15K threshold is splitting. Forbidden whether the threshold is the Micro-Purchase Threshold (MPT), an appointment cap, or any other control.
FAR 12.403 (micro-purchase)
Bypassing other rules
If a buy would be questionable using the GPC or a contract, it's questionable using cash, SF 44, or any other FOO instrument. Changing the payment method doesn't change the underlying compliance question.
AF contingency budget guidance
References
Where the rules live
The Revolutionary FAR Overhaul (RFO) consolidated the micro-purchase methods into FAR 12.403. That's where the GPC, purchase orders, SF 44, imprest funds, and third-party drafts now live. DAFFARS is in flux as the Air Force aligns to the RFO, so verify current Air Force supplements before you draft an appointment letter. Army sources are listed lighter here on purpose, pull the current Army Ordering Officer Guide and AFARS yourself if you're operating under Army authority.
| Citation | Subject |
|---|---|
| FAR 12.403 | Micro-purchase methods, post-RFO. GPC, purchase orders, SF 44 (12.403(b)), imprest funds and third-party drafts (12.403(c)). Imprest fund transaction limit $500 (or higher if agency head approves). Third-party draft limit $2,500 (unless authorized higher). |
| FAR 12.402 | Price reasonableness for micro-purchases under the RFO. |
| FAR 12.6 | Streamlined procedures for evaluation and solicitation of commercial products and services. Where the broader commercial simplified procedures live post-RFO. |
| FAR 2.101 | Definitions. MPT $15K base, $25K CONUS / $40K OCONUS for covered contingency uses. Simplified Acquisition Threshold (SAT) $350K base. |
| DAFFARS 5301.603-3 / 5301.603-3-90 | Air Force authority to delegate FAR 1.603-3(b) purchase authority. Required scope, dollar, instrument, and training elements. Verify current text. The Air Force is realigning its supplements as the RFO progresses, so this citation may move or get renumbered. |
| AFI 64-105 | Air Force contingency contracting support. Service-specific scenario modules and SCO designation. Public AFI, with some annexes behind CAC. |
| AFARS 5101.602-2-92 (Army) | Ordering officer authority and appointment chain. If you're operating under Army authority, pull AFARS Appendix EE (GPC ordering official framework) and the current Army Ordering Officer Guide on Army SharePoint as the RFO updates roll through. |
| DFARS overlay (currently 213.305-3 / 213.306) | DoD overlay on imprest funds and SF 44. Overseas contingency carve-outs. Contracting-officer use of SF 44 up to SAT for fuel, oil, and certain overseas contingency transactions. DFARS is realigning to mirror the RFO Part 12 consolidation, so verify section numbers when you cite. |
| DoD FMR Volume 5 | Paying agent appointment, accountability, and the rule that PAs can't act as purchasing officers. The PA / FOO separation rule lives here. |
| DD Form 1081 | Statement of Agent Officer's Account. Cash advance and settlement between DO and PA. |
| DD Form 2665 | Daily Agent Accountability Summary. Contingency PA turn-in to the DO. |
Bottom line. Stand the program up tight. Appointment letter names the instrument, the cap, and the scope. FOO and PA stay on different letters held by different people. Build the file architecture before the first transaction. Pilot narrow, watch close, and migrate steady-state demand into BPAs, IDIQ orders, or GPC ordering programs once the requirement stabilizes. The RFO is moving citations around as it rolls out, so verify the supplement text before you sign anything.