VA Office of Financial Policy — Frequently Asked Questions
We just had an Internal Control Review and I was asked if there is a VA Policy or Directive on clearing FMS Rejects. From what I understand, FMS rejects should be cleared within one day and they only stay in SUSF for one month. Is that correct and is there a VA Policy or Directive on clearing FMS rejects?
Can you tell me where the Common Numbering breakdown that was published in 2008 is located?
I have an individual that is taking a class at Harvard Kennedy School that begins October 18 (our FY10) and they are requesting payment now; which means paying with FY09 funding. Is this acceptable?
1. We just had an Internal Control Review and I was asked if there is a VA Policy or Directive on clearing FMS Rejects. From what I understand, FMS rejects should be cleared within one day and they only stay in SUSF for one month. Is that correct and is there a VA Policy or Directive on clearing FMS rejects?
VA Policy does not have a requirement of clearing a reject in one day. However, administrative procedures may dictate when a finance office or facility is required to clear these. The following is the VA Policy contained in Volume I Chapter 6, Reconciliations:
- In accordance with section 060503 A. 1, to prevent a negative report on the monthly SUSF report, the following applies to the finance activity or facility: The finance activity or facility will review the monthly SUSF report and ensure that transactions more than 60 days old are processed or deleted within the next 30.
- In addition to this monthly requirement, section 060508 A., further defines the criteria for reconciliations: VA will complete monthly reconciliations to compare balances in various accounts, reports, subsidiary records and systems to ensure complete and accurate financial reporting. Where applicable, items will be traced to supporting documentation to verify agreement. High profile accounts (e.g., intra-Governmental accounts, suspense accounts, undelivered orders) will be monitored on a regular basis, daily if necessary, to determine any out-of-balance conditions. When monitoring or reconciliation activities identify out-of-balance conditions, immediate corrective action will be taken.
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2. Can you tell me where the Common Numbering breakdown that was published in 2008 is located?
The Common Numbering breakdown that was published in 2008 is being added as an Appendix A which is now called Standard Numbering Schema for Obligations in Vol II Ch 1 General Information. I attached a DRAFT copy that was reviewed by the Office Of Financial Policy. It has been finalized and updated in the OFP Publications Library Web site.
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3. I have an individual that is taking a class at Harvard Kennedy School that begins October 18 (our FY10) and they are requesting payment now; which means paying with FY09 funding. Is this acceptable?
In response to your question as to whether Fiscal Year (FY) 2009 funds can be obligated to pay for training on behalf of an employee that will occur subsequent to FY 2009. Based upon guidance obtained from GAO’s Principals of Appropriations Law, the following points were considered in making our decision:
- The bono fide rule needs rule must be met. “A fiscal year appropriation may be obligated only to meet a legitimate, or bona fide, need arising in, or in some cases arising prior to but continuing to exist in, the fiscal year for which the appropriation was made.”
- In situations involving transactions which cover more than one fiscal year, the question to answer is which fiscal should be charged. Appropriations Law states that if a need arise in one fiscal year for services (in this case training) for which by their nature cannot be separated from the time of actual performance, then payment is chargeable to the fiscal year in which the obligation is incurred.
- Further consideration by the Comptroller General of whether to charge the current or subsequent appropriation depends upon whether the services are “severable” or “non-severable (or entire) services.” Severable services have been herein classified as those of a recurring nature such as clerical, trucking, gardening, cleaning, and etc. On the other hand, “entire” refers to a single project or undertaking that cannot be divided between two fiscal years. Normally, the time between contracting and delivery should be not more within two to four weeks.
After careful consideration has been given to the above criteria (i.e., a valid need for training has been determined by requesting office and sufficient funding is available to pay for training) and there is a mandatory registration or prepayment requirement that must be accomplished before September 30, 2009, then current year (FY 2009) appropriated funds may be obligated for the training class to commence in the subsequent fiscal year (FY 2010), October 2009.
Reference: Appropriations Law Principles, Chapter 5, “Availability of Appropriations: Time”
VA may charge funds current at the time it enters into the training obligation so long as (1) it has a valid need for the training at that time and (2) the delay between the obligation and the start of the training is not excessive.