VA Office of Financial Policy — Frequently Asked Questions
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| 1358 (contributed by VHA CFO Office) |
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Does approved use 20.A.(3), Intergovernmental Personnel Agreement (IPA), permit the use of the 1358 to obligate funds for payments to independent contractors?
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Can a 1358 be used to obligate funds to reimburse an employee (approved use 19) for purchase of fuel for a government vehicle when the purchase card was not accepted by the vendor?
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Can a 1358 be used to obligate funds to pay a third party vendor to make payments to Veterans involved in research studies?
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Clarify the start and end dates for a 1358 obligation.
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Can a 1358 be used to obligate funds for ambulance services?
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Clarify the use of approved use 10 and approved use 20 when using the 1358 to obligate funds: Approved use 10, Incentive Therapy/Compensated Work Therapy or approved use 20, Non-Procurement Obligations, (1) OneVA Plus Fund, Compensated Work Therapy (CWT) program, other VA internal programs and agreements, fees imposed by States for reviews of professional certifications of medical staff to ensure accreditation in the State, and Agent Cashier bank service charges.
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Can a 1358 be used to obligate funds to reimburse an individual who was erroneously charged a U. S. Treasury TOP fee?
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Can "multiple vendors" be input in the vendor field when inputting a 1358 obligation into IFCAP under approved use 19?
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When obligating funds for VA homeless Providers under the VA Homeless Providers Grant and Per Diem Program, can the vendor field be bypassed?
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Is obligating funds for tuition for a non-VA employee selected for a scholarship program that requires a 2-year commitment to work for VA an approved use of the 1358?
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Can a 1358 be used to obligate funds to pay for services from AT&T for recurring charges for data circuits, and Qwest for recurring charges for calling cards and local/long distance service, both of which are part of the Network contract.
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How are funds obligated for travel for an interviewee, as this is not an approved use of the 1358?
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Can a 1358 be used to obligate funds for an IPA Agreement between VA and a University?
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Can a 1358 be used to obligate funds for the purchase of a vehicle?
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Can a 1358 be used to obligate funds for attorney services associated with guardianship of a Veteran?
No, this approved use only applies to payments made for persons assigned to VA under the Intergovernmental Personnel Act of 1970. A Contract, VA Form 2237, Request, Turn-In and Receipt for Property and Services should be used to establish terms and obligate funds for payments to independent contractors. Below is additional information relating to the IPA and the URL to review the complete provisions of the Act.
Purpose of Program
Assignments to or from state and local governments, institutions of higher education, Indian tribal governments and other eligible organizations are intended to facilitate cooperation between the Federal Government and the non-Federal entity through the temporary assignment of skilled personnel. These assignments allow civilian employees of Federal agencies to serve with eligible non-Federal organizations for a limited period without loss of employee rights and benefits. Employees of State and local governments, Indian tribal governments, institutions of higher education and other eligible organizations may serve in Federal agencies for similar periods. The legal authority for assignments under the Intergovernmental Personnel Act is 5 USC sections 3371 through 3375. The regulations can be found in Code of Federal Regulations (CFR), part 5, chapter 334.
Each assignment should be made for purposes which the Federal agency head, or his or her designee, determines are of mutual concern and benefit to the Federal agency and to the non-Federal organization. Each proposed assignment should be carefully examined to ensure that it is for sound public purposes and furthers the goals and objectives of the participating organizations. Assignments arranged to meet the personal interests of employees, to circumvent personnel ceilings, or to avoid unpleasant personnel decisions are contrary to the spirit and intent of the mobility assignment program.
The goal of the Intergovernmental Personnel Act mobility program is to facilitate the movement of employees, for short periods of time, when this movement serves a sound public purpose. Mobility assignments may be used to achieve objectives such as:
- strengthening the management capabilities of Federal agencies, State, local and Indian tribal governments, and other eligible organizations;
- assisting the transfer and use of new technologies and approaches to solving governmental problems;
- facilitating an effective means of involving state and local officials in developing and implementing Federal policies and programs; and,
- Providing program and developmental experience which will enhance the assignee's performance in his or her regular job.
No, approved use 19 is not an approved use for reimbursing an employee for purchase of fuel for a government vehicle when the purchase card was not accepted by the vendor. The facility can determine the correct form, such as: the SF 1164, Claim for Reimbursement for Expenditures on Official Business; SF 1012, Travel Voucher; SF 1034, Public Voucher for Purchases and Services Other Than Personal; or SF 1047, Public Voucher for Refunds, are approved for employee reimbursements.
No, this is not an approved use of the 1358. The 1358 can only be used only for payments made directly to the Veteran and for minor costs. When using an outside vendor, VA should have a contract with the vendor stipulating the terms of the payments and any reporting provisions, and the funds would be obligated using the 2237.
The following is an excerpt from VA Policy, Volume II, Chapter 6, Appendix A:
5. Research Studies
A. Description. These can be studies conducted by both VA and external organizations. This item is for payment directly to multiple participants (VA patients) of research studies for minor costs, such as those associated with travel to their appointments. VA Form 1358 must reference the research study.
B. Justification. Multiple individuals with no contract(s). Miscellaneous vendors may be used; identify vendors in the Purpose Field.
C. VA Form 1358, Purpose Field. Reference the research study and provide a description.
4. Clarify the start and end dates for a 1358 obligation.
The period of performance should be the start and end date of the agreement or contract. The Purpose Field would include a specific start and end date, which would be the start and end date of the obligation.
5. Can a 1358 be used to obligate funds for ambulance services?
Yes, obligation of funds for non-contract ambulance service is an approved use of the 1358. This does not apply when there is a contract. If a contract is necessary or desired with a transportation vendor, the 2237 will be used to obligate the funds. Approved Use 11: Beneficiary Travel and Direct Payments to Veterans from General Post Fund.
A. Description. Payments to Veterans and/or attendant or non-contract transportation vendors for travel related to medical care from medical services appropriation and other payments to Veterans from the General Post Fund. (38 USC 111, Payments or allowances for beneficiary travel)
B. Justification.
(1) Multiple beneficiaries or vendors.
(2) No contract(s) or no opportunity to establish contracts.
(3) Small dollar amounts.
(4) High volume of transactions (workload issue).
Approved use 10, Incentive Therapy/Compensated Work Therapy, is for paying the program participants weekly salary. This is always 0160 funds.
Approved use 20, Non-Procurement Obligations, is to be used by the VA Service using CWT workers. For example, Environmental Management Service (EMS) has CWT workers helping with housekeeping: EMS would create a 1358 obligation in 0162 funds for the amount that the CWT program would be billing. CWT program would send a weekly bill for the salary plus overhead charges for the CWT workers. Accounting would offset the EMS 1358 each week for the billed amounts.
No, reimbursing individuals for TOPS fees is not an approved use of the 1358. Approved use number 20 (3) TOPS fees, refers to the fee that VA pays to the U. S. Treasury and not to individuals. Below are two policies with procedures for TOPS fees reimbursed to individuals. Refunds for TOP fees will be processed on the SF 1047 as described in VHA Directive 2011-021. If this is an injured spouse claim, the procedures are as follows:
Per VA Financial Policy, Volume XII, Chapter 1E…2. In situations when an amount referred to Treasury for offset is later deemed to not be a valid debt, the amount offset, including the TOP fee will be refunded by VA to the debtor. For previous offsets later deemed to be an invalid debt, a person will have up to 6 years (from the date the debt was deemed invalid), pursuant to 28 U.S.C. 2401(a), to request a refund of the TOP fee. Refunds will only be issued on an as-requested basis.
3. For all VA appropriations except MCCF, TOP fees refunded to the person will be paid from the appropriation used for the administrative expenses of collecting for the type of debt involved in each case. Therefore, for C&P debts, the TOP fee refunded to the debtor will be made from the Franchise Fund. For non-MCCF VHA debts, the medical administration appropriation (0152A1) will be used to refund the TOP fees. For debts recorded in MCCF, the medical services fund (0160X4) will be used to refund the TOP fees.
- VHA Directive 2011-021
- Volume XII, Chapter 1E
No, “multiple vendors” cannot be input in the vendor field. For each approved use, the vendor would be the person requesting the reimbursement. Multiple vendors would not apply. If the employee has not been vendorized, this will have to be done. (The following is the text of approved use 19 from Appendix A, VA Policy, Volume II, Chapter 6, 19. Reimbursements to or on behalf of VA Employees or Students:
A. Description. VA employees can be reimbursed for tuition, book expenses, and examination fees that have been approved on an SF-182, Authorization, Agreement, and Certification of Training, and when all requirements of VA Directive 5015, Employee Development, have been met. In addition, the following payments/reimbursements may be made:
(1) To employees for: Professional Liability Insurance (50% of cost), not to exceed $150; Certificates or certification licenses required by VA for employees to perform their duties (e.g., pesticide application); Education Debt Reduction Program (EDRP)
(2) To employees and students for:
Agreements between VA and an educational institution or an individual, to provide tuition reimbursement or scholarships for college students enrolled in visual impairment or health professional programs, such as the Employee Incentive Scholarship Program and the Health Professional Education Assistance Scholarship Program. The student agrees to work for VA at the end of the training.
Obligations for employee reimbursements can be made on VA Form 1358. Tuition expenditures made on behalf of an employee or scholarship recipient and paid directly to a vendor may also be made on VA Form 1358.
B. Justification.
(1) Because reimbursements to VA employees for training are not reportable obligations to the Federal Procurement Data System (FPDS), and they are not subject to procurement regulations, the obligation does not need to be made on a VA Form 2237/PO.
(2) A copy of the approved SF-182 or other documentation required by VA Directive 5015 must be kept on file by the Finance Activity as backup to VA Form 1358 expenditures.
No, the vendor field cannot be bypassed. The Grants Director has stated that these Grants are a joint effort between VA and HHS. In order to be able to reconcile expenditures with HHS, the amount obligated and paid to each Grant recipient is required.
Yes, under approved use 19 VA Policy provides:
To employees and students for:
Agreements between VA and an educational institution or an individual, to provide tuition reimbursement or scholarships for college students enrolled in visual impairment or health professional programs, such as the Employee Incentive Scholarship Program and the Health Professional Education Assistance Scholarship Program. The student agrees to work for VA at the end of the training.
No, this is not an approved use of the 1358. The 2237 is the correct process to obligate the funds.
12. How are funds obligated for travel for an interviewee, as this is not an approved use of the 1358?
When a VA employee travels to another VA facility for a pre-employment interview, the employee:
- must complete their travel arrangements outside of FedTraveler
- may not use their government travel card
- must be on annual leave not authorized absence (personal time not official travel)
- payment will be made manually
For VA Employees, the following manual process should be used for invitational travel:
- Manually complete VAF 50-5575 to pre-authorize the reimbursable expenses so an obligation can be established prior to travel; complete an itemized expense report utilizing SF-1012 to reimburse the traveler. The employee may not be reimbursed using SF-1164.
13. Can a 1358 be used to obligate funds for an IPA Agreement between VA and a University?
Yes, the 1358 is an approved use to obligate funds for an IPA Agreement between VA and a state-funded university. If the institution is not state funded, the 2237 would be the correct obligation document. If it is governed by a State governmental agency, the 1358 is approved for Intergovernmental agreements only. Note excerpt from policy below
20. Non-Procurement Obligations
A. Description. The following non-procurement obligations can be obligated on a VA Form 1358 as long as the source document for each expenditure is kept on file in the Finance Activity and the Using Service, in support of each authorized transaction against the VA Form 1358:
(3) Other government agency obligations for all GSA activity (including vehicle, property leasing and utilities), Government Printing Office, Inter-agency Sharing Agreements (including VA/DOD Sharing), Intra-agency Sharing Agreements (VHA, VBA, NCA, OI&T), Intergovernmental Personnel Agreements and services (includes Cooperative Administrative Support Units (CASUs)), and Treasury Offset Program (TOP) fees.
14. Can a 1358 be used to obligate funds for the purchase of a vehicle?
No, this is not an approved use of the 1358. GSA is the mandatory source for purchase of Federal agency vehicles. The instructions provided by GSA for the ordering agency require that the vehicles be purchased in accordance with Federal Acquisition Regulations. The purchase should be negotiated by the Contracting Officer, and the funds should be obligated using the 2237.
From the GSA web site:
In accordance with Federal Acquisition Regulation (FAR) 16.505 (a) and (b), each ordering agency must compare prices for each and every contractor that can meet the minimum order requirements when selecting the vehicle(s) which will meet their agency’s mission. Ordering agencies must also document the contract file with the rationale for placement and price of each order.
The following should be considered when determining the best value when ordering light trucks, medium and heavy trucks, and passenger cars:
Price; Greenhouse Gas Score; Optional Equipment; Delivery Time; Fuel Economy; Life Cycle Cost; Past Performance; Dealer/Maintenance Location.
Each order submitted to GSA for order placement must provide a statement affirming that all contractors were provided a fair opportunity to compete in accordance with FAR 16.505 (b).
No, the 1358 is not approved to obligate funds for payment of attorney fees associated with guardianship of a Veteran. A 1358 may only be used for specifically stated purposes. The appropriate form to obligate the funds is the 2237. The attorney is paid for providing an ongoing service, i.e., guardianship, which would require contractual relationship.
