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Lesson Introduction

References made to publications are current as of April 2015.

The requirements for financial management are based in law . The Constitution,public laws,and several authorizations and appropriation acts require not only that financial management be performed,but also specify how it should be performed. Consider these mandates :

  • The Constitution forbids the disbursement of funds from the Treasury unless funds are specifically appropriated by law.
  • The Anti-Deficiency Act prohibits the illegal use of funds and has punitive provisions for violations.
  • The Chief Financial Officers Act focuses the financial management efforts of all federal departments

and agencies on how well taxpayer dollars are spent.

Finance Officers, Disbursing Officers,agents,and other financial personnel entrusted with public funds are accountable for those funds at all times. They may be held personally and pecuniarily (financially) liable for any financial losses.

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Lesson Objectives

Terminal Learning Objective: Provide an overview of Certifying Officer Legislation (COL) and the roles of the Departmental Accountable Officials (DAOs ), Certifying Officers (COs ), and Disbursing Officers. At the end of this lesson you will be able to :

  • Identify the legislation,regulation,and references that pertain to Certifying Officer Legislation .
  • Define what certification is with regard to certifying vouchers for payment.
  • Explain the types of certification.
  • Identify the key personnel involved and their responsibilities in the certification process.

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Lesson Objective 1

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Hi Hector. My name is Chris. Iwas recently assigned an additional role as a Certifying Officer. Iunderstand you're the supervisor

who trains new Certifying Officers. I'm looking

for some information on my new position. For

example, why was the Certifying Officer position added to the voucher certification process?

Nice to meet you, Chris. As the designated Training Officer within our DoD component,

I'll give you a look at some of what you'll be

expected to know in your new role. We'll start off by identifying the legislation, regulation, and references that pertain to Certifying Officer Legislation. Let's see how much you may already know about what a Certifying Officer does.

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IOUs are approved

Special certifications, if required are furnished

No duplicate payments

Goods received comply with the agreement

Payment is permitted by law Prompt payment requirements

followed

Warm Up Activity

Which of the points below apply to the review of Purchase Card payment transactions/vouchers? Drag the

correct answers with your mouse to the box.

Prices will be negotiated at a later date

Check Answer I

The correct answers are provided.

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Certifying Officer Legislation History

Ihope you found the correct answe<s on the Warm Up ActMty . f not, we'I cover the materialin the topics ahead.

Prior to a 1996 leg1slatJve change,only Disbursmg Officers w1th1n Department of Defense were pecunianly (financially) hable for fiscal irregulanties. Certifying Officers did exis t but were jus t administrative appointees.

Certification of payments is governed by the

Nati onal Defense Authoriza tion Act of 1 996 . Publi c Law 104- 106. Sec tion 193. This legislation established accountab1hty for an ind vidual's ac tions in the form of pecuniary riabmty.

Thelaw requires the appo1ntment of an individual who ts independent and organizationaly separa te from Otsburslfl9 Officers to certify vouchers .

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Certifying Officer Leoislation

The Cerbfytng Officer Legislation requires that an ndividual,other than the Disbursing Officer,be assigned responsi>llity for certifying vouchers for payment.

That vouchers are correc t and proper for payment from the appropnat1on(s) or other funds cited on them or on supporting vouc hers, and that the proposed payments are legal,proper, and correct. Reference DoD FMR Volume 5, Chapter 33 and Volume 10, Chapter 23, Annex 1, "Purchase Card Certification Statement".

Certifying Officers are pecuniarily liable for illegal, improper or incorrect payments resulting from improper cerbficabon.

Let's look at an example of how one Certifying Officer was found pecunarily liable and had to reimburse the Government for improper payments made with government purchase cards.

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Pecuniary Liability Example

Mr. X was a certifying officer for government purchase card payments for the Defense Automatic Addressing Systems Center (DAASC) at Wright-Patterson Air Force Base in Ohio. An audit of the DAASC purchase card program found four instances of improper payments made with government purchase cards using appropriated funds.

These payments were for two lunches for DAASC employees and defense contractors at a local restaurant,disposable coffee cups, and a late fee paid to Park University. For all four improper payments,the audit recommended that DAASC hold Mr. X, as the Certifying Officer,responsible to reimburse the government.

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Pecuniary Liability Example, Cont.

The Government Accounting Office report concluded that Mr. X had a responsibility to scrutinize and question potential improper payments before certifying a billing statement for payment to the bank servicing the purchase card and that he did not exercise good faith when certifying the four transactions for payment.

The GAO declined to grant relief and Mr. X was billed for $403 .

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Pre-Payment Reviews

Pre-payment reviews may occur any time before payment and are subject to management's judgment of the most appropriate stage in the voucher-preparation process for their conduct. These reviews ensure that vouchers are substantiated by documentation for lawful and proper payment. Under manual processing systems,they include verification of accurac y of computation. These requirements include ensuring that:

A . Payments are allowed by law and regulation (for purchase card only, is also in compliance with GSA Master Contract and applicable Task Order ).

8. Payments are authorized and approved for payment.

  1. Requests for payment are supported by basic documents.
  2. Payee identification is correct.
  3. Manual calculations are correct and data are input correctly to automated computation systems .
  4. Proper accounting classifications are charged (i.e.,supported by a proper obligating document).
  5. Funds are available to support disbursements.
  6. Any required special certificates or receipts are attached to the disbursement documents.

I. Duplicate payments are prevented through proper manual or automated edits and checks .

A detailed look at Certifying Officer Legislation can be found in

DoD FMR 7000.14R Volume 5 Chapter 33. 330602 .8.

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Knowledge Review 1

In making a certification,Certifying Officers are not responsible for :

D Certifying vouchers for payment.

D The existence,accurac y and legality of information

on a voucher.

D Illegal,improper or incorrect payments.

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Obtaining the signature of a Disbursing Officer before

validating the certification.

CpeckAnswer I

Certifying officers are not responsible for obtaining the signature of a Disbursing Officer before validating the certification

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Certifying Officer Legislation Reference Websites

Click the hyperl nks below to access additional information for Certifying Officer Legislation.

Public Laws/US Code,Code of Federal Regulations

uscode.house.govI

www .gpoaccess .gov

www .usa .gov

Financial Management Regulations

comptroller. defense .gov/ fmr

www .dfas .mil

Directives

www .dtic.mil/whs/directives/

The following regulations,laws, and directives pertain to COL:

  • Sections 3321,3325,3527,3528,and 3529 of Title 31, Money and Finance,of the united States Code
  • Title 10 Armed Forces,Section 2784
  • Public Law 104-106. Section 913
  • DoD Directives 7000.14R,DoD Financial Management Regulation (DoD FMR, Volumes, 33,Accountable

Officials and Certifying Officers ), and 7000.14R,DoD Accountable Officials and Certifying Officers

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Lesson Objective 2

Thanks Hector. Ifeelpretty good about understanding how and why the role of

Certifying Officer came about. What's next?

Now, we'll define what certification is with regard to certifying vouchers for payment.

A Certifying Officer's certification attests to the legality, propriety, and correctness of a voucher for payment as defined in 31U.S.C. Section 3528Ca .

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Knowledge Review 2

Which best describes the Certifying Officer?

D Always under the direct supervision of the Disbursing Officer.

D Always a Defense Finance and Accounting Service employee.

D Responsible for the appointment of Payment Review

Officials.

Responsible for the legality, propriety,and

correctness of the certified voucher.

CjleckAn!iWer I

Responsible for the correctness, legality, and propriety of the certified voucher best describes the Certifying Officer.

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Lesson Objective 3

Easy to remember. The Certifying Officer's certification attests to the legality,propriety and correctness of a voucher for payment. What's our next topic?

I

Chris, in this third section of the lesson,we'll

explain the types of certification.

The types of certification that the Certifying

Officer needs to know are :

  • Voucher Certification
  • Voucher Awaiting Payment (VAP)

Certification

  • Successive Certification
  • Manual Certifications
  • Electronic Certifications

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Voucher Certification

Certificabon of a single onginal voucher attests to the propnety and lega6ty of the information contained on the voucher and is authorizabon for the Disbursing Officer to make payment as Klenbfied on the voucher. Cerbfy1ng Officers are accountable for the 1nformat1on contained on the voucher.

Certifying Officers certify the bank invoice, which

may contain multiple cardholder accounts .

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Successive Certification

Certifying Officers are accountable for aD informabon

contained on voochers they certify for payment.

If any infonnabon on the voucher is changed after the inibal ceroficabon, the voucher must be re­ certified by a property appointed Certifying Officer. This recertification 1s called a successive certification.

The Certifying Officer performing the successive certification becomes accountable for illegal, incorrect, or improper payments caused only by the changed information she/he certified.

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Manual Certiflcnllons

Certificat>on may be manual or electronic. Manual certificabon can be done directly on the voucher Of" sunvnary voocher. The cerbfication includes:

  • Certifying Officer's signature
  • Typed or pnnted name
  • Tttle
  • Date
  • Dollar amount

Once a Certifying Officer manually certifies a

voucher , It can be delivered to the disbursing office. Let's take a look at the electronic certification method.

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Electronic Certifications

The Certifying Officer may certify elec tronically 1f

the folowing cntena are met:

  • Adequate safeguards exist to prevent

unauthonzed use.

  • Access capab1hty (such as Common Access Card-CAC) remains under the sole control of the Cert1fy1ng Officer.
  • Elec tronic certification is invalidated by the system if the data it is linked to is changed or altered in any fashion.
  • Elec tronic certification is unique to the

Certifying Officer.

  • Electronic certification is verifiable by the Disbursing Officer.

Refer to the Deparbnent of Defense Charge card Guidebook for guidance on approved elec tronK systems .

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Knowledge Review 3

Manual certif\cat>ons are not aBowed.

True

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Lesson Objective 4

Next

Now that Iknow the types of certification, can you fill me in on all the players and their roles in their interactions with the Certifying Officer?

Sure Chris. In fact,we'll wrap up this lesson by identifying the key personnel involved and their responsibilities in the certification process.

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Centralized dlsbt.n1ng, automated systems, increased transacoon volume, and more complex business processes have reduced the indiv\duars ability to personally ensure the accuracy, lega6ty, and propnety of each payment.

Voucher certification must rely on information and expertise provided by several key players. Their efforts play significant roles in the certifier's ability to properly certify . Some are in managerial roles and others are in direc t support roles.

Let's find out who these key players are and what their roles and contributions are to the certification process.

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Key Personnel Levels of Authority

The key personnel tnvolved in the certificabon process from highest level to lowest evel are :

1. Under Secretary of Defense

2. Heads of DoD Components 3.Disbursing Officers 4.Supervisors

  1. Certifying Officers
  2. Departmental Acco untable Officials

We'll look at the responsibilities of each in the

certification process.

Next

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Under Secretary of Defense (Comptroller)

Overall responsibility for the integrity of the payment voucher certification process rests with the Under Secretary of Defense (Comptroller).

This individual also issues appropriate guidance for implementation,administration,and management of

voucher programs.

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Heads of DoD Components

The Heads of the DoD Components implement the specific requirements of DoD FMR 7000 .14R. These managers are responsible for day-to-day business operations, including guidance,oversight,design, modification, and maintenance of their respective components' business processes and systems.

The Heads of DoD Components,or their designees ,appoint and oversee Certifying Officers and

Departmental Accountable Officials.

The Heads of DoD Components may delegate the appointment authority as appropriate for the needs of the component. For example,the Head of Component for the Defense Finance and Accounting Service,is the Director,Defense Finance and Accounting Service (DFAS). The Director,DFAS specifically delegates the authority to appoint Certifying Officers and review officials to subordinate directors along with authority to redelegate to certain levels .

The Service Secretaries may delegate their authority to subordinate organizations either through general or specific delegations.

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Heads of OoD Components,Conte

The Heads of DoO Components also:

  • Provide al tralnlflQ for new and existing Cerbfylng Officers and Departmental Accountable Officials.
  • Conduct penod1c review and inspections of the actions taken by Certifying Officers and

Departmental Accounta ble Officials under their

control.

  • Convene or order an investigation when an illegal, improper or incorrect payment is discovered.

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Disbursing Officers

Disbursing Officers are responsible for disbursing money according to properly certified vouchers. They examine the voucher to determine proper form,certification,and approval by an authorized Certifying Officer.

They also ensure that the voucher was computed correctly for the facts certified. Disbursing Officers return vouchers that are not in the proper form, incomplete,or not properly certified to the Certifying Officer.

There are specific appointment rules that require a separation of duties for Disbursing Officers. For example,a Disbursing Officer may not normally be appointed as a Certifying Officer nor may they appoint a Certifying Officer.

Disbursing Officers are pecuniarily liable for erroneous payments made without or contrary to a certified

voucher.

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Supervisors

Supervisors are responsible for ensuring that both initial and refresher training is provided to new and existing Certifying Officers and Departmental Accountable Officials. Supervisors must also periodically review or inspect the actions taken by Certifying Officers and Departmental Accountable Officials under their control to ensure policies and procedures compliance .

It is critical for Supervisors to provide effective supervision of Certifying Officers to minimize the number of erroneous payments.

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Certifying Officers- Appointment and Termination

Certifying Officers are responsible for checking the accurac y of facts stated on a voucher and in supporting documents and records,and may rely on data received from reliable automated systems that have been certified as compliant with the Federal Financial Management Improvement Act {FFMIA). They determine the legality of a proposed payment using the cited appropriation or fund and are responsible for the computations on a certified voucher. Certifying Officers are pecuniarily liable for illegal, improper or incorrect payments resulting from improper certification.

The Heads of DoD Components appoint Certifying Officers with a DD Form 577, Appointment/Termination Record - Authorized Signature or approved electronic equivalent.

Certifying Officer must be terminated using the DD Form 577 showing the date and reason for the termination of duties as a CO. The original DD Form 577 must be provided to the servicing Disbursing Officer. A copy should be maintained in the Certifying Officer's personnel file.

The retention period for the appointment and termination DD Form 577 is 6 years, 3 months after

termination of appointment as a Certifying Officer .

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Departmental Accountable Officials

Departmental Accountable Officials are responsible for providing to a Certifying Officer information,data,or services that are directly relied upon by the Certifying Officer in the certification of vouchers for payment. Two examples of individuals who could be appointed as Departmental Accountable Officials are :

  • Receiving Officials
  • Contracting Officers
  • Card Holders

DAOs are not subject to the presumption of negligence,but may be held pecuniarily liable under 10 u.s.c. 2773a(c) for illegal,improper or incorrect payments resulting from information,data,or services they negligently provide to certifying officers ; and upon which the certifying officers relied to certify payment vouchers.

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Knowledge Review 4

DoD Component Heads or their desgnees are required by DoD FMR

7000.14R to do what?

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Appoint Certifying Officers,Departmental

Accountable Officials,and Review Officials

D Grant relief from liability to Departmental Accountable Officials based on lack of experience, supervision,or training

D Issue appropriate guidance to each of the

Services/Agencies for proper implementation of the

directive

n None of the above

CfleckAnswer I

OoD Component Heads are required to Appoint Certifying Officers, DepartmentalAccountable Officials, and Review Officials

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Lesson Summary

In this lesson,you learned:

  • Disbursing Officers and Certifying Officers play highly visible roles. They are pecuniarily liable for their

actions when an improper payment voucher certification results in an erroneous payment.

  • The legislation and regulations that lead to the appointment of an independent Certifying Officer for

payment vouchers.

  • Certification is the act of attesting to the legality,propriety, and correctness of a voucher for

payment.

  • The distinguishing features of manual and electronic payment certification.
  • The roles of individuals in the certification process and their responsibilities.

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Lesson Completion

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You have completed the content for this lesson.

To continue, selec t another lesson from the Table of Contents on the left.

If you have closed or hidden the Table of Contents,click the Show TOC button at the top in the Atlas navigation bar.

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Lesson Introduction

Now that you've learned about the Certifying Officer Legislation (COL),let's take a closer look at the role

of the Certifying Officer in the payment certification process .

This lesson identifies the qualifications of a Certifying Officer,describes the Certifying Officer appointment process,and describes the manual and electronic certification process .

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Lesson Objectives

Terminal Learning Objective: Recognize the role of the Certifying Officer in the payment certification process . At the end of this lesson you will be able to :

  • Identify the qualifications of a Certifying Officer .
  • Recognize Certifying Officer appointment and termination process .
  • Recognize the manual and electronic payment certification process .

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Hey Hector. What are the qualifications

required of the Certifying Officer?

Glad you asked, Chris . The Certifying Officer is expec ted to be knowledgeable in the area in which he or she performs certifications as well as having a background in preparing vouchers for payment. Here are some of the other aspects of being a Certifying Officer that you should become familiar with.

Try this warm up activity first to see how familiar you are with the roles of Certifying Officers. Some of what you

learnedin Lesson 1should help you

answer the question.

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Warm Up Activity

Which of the following personnel is not normally eligible for

appoin tment as a Certifying Officer?

Disbursing Officers

D Travel Authorizing Officials

D Resource Managers/Fund Holders

0 Commanders

I CheckAnswer I

Disbursing Officers are not normally eligible for appointment as a Certifying Officer.

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Required Knowledge

A Certifying Officer should :

  • Be knowledgeable of the area in which he or

she performs certifications .

  • Have background or experience in preparing

vouchers for payment.

  • Have knowledge of their servicing bank dispute process (contact the

Agency/Organization Program Coordinator­

A/ OPC to obtain process for their bank).

  • Have knowledge of the payment process (e.g. availability of funds and location of designated paying and accounting offices ).
  • Have knowledge of appropriations and other

funds and accounting classifications .

Certifying Officers and DAOs must be U.S. citizens if their duty stations are within the United States . If outside the U.S.,Certifying Officers must be U.S. citizens or direct hire foreign nationals (subject to certain exceptions ).

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Eligibility

Personnel eligible for Certifying Officer appointment include:

  • Commanders
  • Deputy commanders
  • Resource managers/fund holders
  • Travel authorizing officials
  • Purchase card approving officials
  • Other personnel in equivalent positions

Disbursing Officers are not eligible for Certifying Officer appointment. Also, individuals under a Disbursing Officer's supervision may not be appointed as Certifying Officers except under unusual circumstances. Exceptions as noted in Q.QJL FMR Volume 5. Chapter 33 (330201.A) are authorized. This separation of duties provides independence and strength to the internal control process.

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Knowledge Review 1

Which of the following would NOT be an expectation for a Certifying

Officer?

0 Background preparing vouchers for payment

Knowledge of military processes and procedures

D Knowledge of the payment process

0 Knowledge of appropriations funds and accounting

classifications

CheckAnswer I

Knowledge of military processes and procedures is not an expectation for a Certifying Officer for Purchase Card.

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Lesson Objective 2

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Good information on the qualifications of the

Certifying Officer . What's next?

Let's look at the Certifying Officer appointment and termination process .

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Form 577

Appo int and terminate the appointments of Certifying Officers and DAOs on DD Form 577 (Appo intment/Termination Record/Authorized

Signature ). Identify the specific types of payments, e.g.,vendor pay, purchase card,CBAs,travel, transportation,military,and civilian pay involved.

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Form 577, Cont.

Training must occur prior to appointment per Department of Defense Charge Card Guidebook .

For direct-hire non-U.S. citizens to whom,by agreement,a local law applies that does not subject the local national to the same pecuniary liability as other Department of Defense employees,make an appropriate comment in item 7 of the DD Form 577.

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Form 577, Cont.

Appointees acknowledge their appointment in Section III of the form . Appointing authorities review appointments annually as a minimum for validity and currency. Appointments remain in force until terminated by reassignment or for cause .

Certifying Officers terminate appointments as appropriate using Section JV of the form,and advise the agencies that received the original

appointments .

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Computation Functions

When a computation function is performed at an activity that is independent from the disbursing function, a Certifying Officer may be appointed to the first-line supervisor level,or higher within the computation function area .

Where computations for payment are performed under the direction of the Disbursing Officer during tactical operations (including afloat units,military training exercises,noncombatant evacuations ,and contingenc y operations ),Certifying Officers may be appointed from among personnel within the disbursing office .

These appointments must be accomplished either by direct written notification from the respective Head of

the DoD Component to the designated appointee or by delegation through command channels excluding

the Disbursing Officer . This special appointment would typically be for the duration of the deployment.

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Knowledge Review 2

Which Section of DD Form 577is used to terminate appointments?

Section I

Section II

LJ Sec tion Ill

SectionIV

ICheclc An swer I

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Section IVis the correct answer.

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Lesson Objective 3

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Great information on how the appointment and termination process works for the Certifying Officer .

We'll wrap up this lesson by describing the manual and electronic payment certification process .

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Payment Certification Process

The certification process is more than just the approval of a voucher for payment. It is a statement to the Disbursing Officer that the proposed payment is correct,legal,and proper in the use of appropriations or other funds designated on either the voucher or the supporting documents .

Certifying officers certify to,not "for" or "on behalf of," DOs or their agents that vouchers are correct and proper for payment from the appropriation (s ) or other funds cited on them or on supporting vouchers,and that the proposed payments are legal,proper,and correct.

Purchase Card purchases must meet these criteria:

1. Meets a bonafide need.

2. Acceptance has occurred (except where pay and confirm is in place in which case the activity has

a systemic process in place validated by independent audit to ensure performance occurs within the

dispute process authorized by the GSA contrac t/ task order ).

  1. Appropriation to be charged is current and available .
  2. Cardholder has provided assurance that property records have been updated if required .

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Certification Process Steps

The certification process has three steps :

  1. Review the supporting payment documents :

    • Review certified transactions by Cardholder against Purchase Log to ensure that they are in agreement . Reallocate to correct appropriation or dispute with GSA contract terms .
    • Dispute within GSA contract terms as required by Title 10 Section 2784.

  • Compute the entitlement .

  • Certify the voucher .

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Pecuniary Liability

Certifying Officers are automatically pecuniarily liable for the amount of illegal,improper or incorrect payments resulting from their certifications . Therefore ,it is essential for their defense that they can show evidence of following established certification procedures .

The certification process creates an audit trail. When performed correctly, the certification process provides protection for the Certifying Officer . n fact,following the correct procedures may provide a basis on which to grant relief of liability.

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Knowledge Review 3

The Purchase Card purchase must meet:

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Bonafide need

Audit trail criteria

LJ DoD expec tations

Your superviso r's personal needs

ICheclc Answer I

The Purchase Card purchase must meet Bonafide need.

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Lesson Summary

In Lesson 2, we learned that Certifying Officers must have a background in, and knowledge of, the payment process but cannot be Disbursing Officers. Appointment to this positionis accomplished on DD Form 577.

Certification is the process that indicates to the Disbursing Officer that the proposed payment is legal,proper, and correc t.

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Lesson Completion

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You have completed the content for this lesson.

To continue,selec t another lesson from the Table of Contents on the left.

If you have closed or hidden the Table of Contents,click the Show TOC button at the top in the A tlas navigation bar.

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Lesson Introduction

This lesson identifies the responsibilities of the Certifying Officer and the requirements for a valid payment. The lesson explains the concepts of reliable information and the audit trail relevant to the payment certification.

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Lesson Objectives

Terminal Learning Objective: Identify the specific responsibilities of the Certifying Officer. At the end of this lesson you will be able to :

  • Recognize accountability of the Certifying Officer.
  • Recognize the requirements for a valid payment of a voucher .
  • Explain the concepts of reliable information and the audit trail relevant to payment certification.

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Lesson Objective 1

So far we've looked at the topics of Certifying Officer legislation and the roles of the those involved in the Certifying Officer process . So what's next,Hector?

Since this lesson is about the responsibilities of the Certifying Officer,we'll start off with a look at accountability of the Certifying Officer .

See how much you may already know about this topic by doing the Warm Up Activity on the next slide.

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Warm Up Activity

Which of the following is the Certifying Officer NOT accountable for?

Next

ICheck Answer I

The Certifying Officer is not accountable for the design of the payment system.

The amount of any illegal, improper, or incorrect payment resulting from an inaccurate or misleading certification.

Any payment prohibited by law.

Any payment that does not represent a legal obligation under the appropriation or fund involved.

./ Design of the payment system.

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Accountability

The Certifying Officer is accountable for :

  • The amount of any illegal,improper,or incorrect payment resulting from an inaccurate or misleading

certification.

  • Any payment prohibited by law .
  • Any payment that does not represent a legal obligation under the appropriation or fund involved.

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Fact Checking

The Certifying Officer is responsible for the correctness of the facts stated in the voucher (bank invoice) and for ensuring the retention of supporting documentation and records in accordance with DoD policies. The Certifying Officer is also responsible for the accurac y of computations on the voucher and the legality of the proposed payment under the appropriation or fund involved.

Certifying Officer responsibilities are specified in 31 USC 3528(a), 10 USC 2784 and the DoD FMR.

Volume 5. Chapter 33.

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Knowledge Review 1

Valid Payments for purchase cards consists of three components.

Which of the following is NOT one of those components?

./ Certification that the payment is illegal

The correc tness of the facts stated in the voucher

{bank invoice)

The existence of supporting documentation and

records

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The accuracy of computations on the voucher

ICheclc Answer I

Certification that the payment is illegal is not a component of Valid Payments

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Lesson Objective 2

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Quite a lot to be accountable for. The Certifying Officer needs to have a pretty extensive background in the field. So what are the requirements for a valid payment of a voucher?

Well, let's discuss that, Chris!

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Payment Supporting Documents

Let's look at the supporting documents needed for valid payments.

Valid payments generally have three parts:

1. Valid requirement (bonafide need)

2. Bank invoice with all transactions reconciled to a Purchase Log and approved by the Cardholder

3. Reallocation of accounting classification (if necessary ). See DoD FMR.Volume 10. Chapter 23

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Payment Support no Documents,Cont.

At a ITllnllTIUm, entnes to the Purchase Log wil

include:

  • Date on which the item/service was ordered.
  • Name of the requestor and/or requesting organization.
  • Detailed descnpt1on of the item/service or general commodity code is required (if item is

$75.00 or less, the description may be at summary level; e.g., office supplies).

  • Merchant's name.
  • Number of items purchased.
  • Unit pnce.
  • Total dollar value of the transaction.
  • Name of the recipient/acceptor of the

item/sefVlCe, and date received.

  • Any addibonal data required by component· spec11\c 11\Sl:ruc:bons.

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Knowledge Review 2

What are the three parts of a valid payment?

D Payment voucher,supporting documentation,

determinations.

D Date service was ordered,name of requester,

description of the item.

Bank invoice, valid requirement,reallocation (if necessary).

D Merchants name,number of items purchased,unit price.

CfleckAnswer I

Bank invoice, valid requirement, and reallocation (if necessary) are the thre parts of a valid payment

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Lesson Objective 3

Now Iknow the requirements for a valid payment of a voucher .What else do Ineed to know about Certifying Officer responsibilities, Hector?

You are going to need to know about the concepts of reliable information and the audit trail relevant to payment certification. So that's what we'll discuss next.

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Aud it Trail

The payment voucher, all supporting documentabon,

and any detenruna bons made by or for the Certifying Officer (e.g. advance decisions) need to be accessible and retnevable .This coftection of documents forms an audit trail, which may form the

basis for reltef from ltabtflty for the Certifying Officer .

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Centralization of Disbursing Processes

The cent:rabzabofl of disbursing processes and

i-lcreased use of automa ted systems,coupled with the volume and compfeJOty of business processes, reduces the ability of Department of Defense officials to exercise dtrect personalcontrolover an aspects of each business transaction.

Because of these operation changes, it is extremely difficult for any single Department of Defense official to personally ensure the accuracy, propriety, and legality of every payment.A Certifying Officer must depend on other personnel (such as the cardholder) involved in the payment authorization process to provide accurate and timely documents so that they can provide quality servtce .

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Automated System Pnyments

In an automated system, evidenc e that the payments are acc1Kate andlegalis dependent on the system and not indMdual transactions. To ensure accuracy and legatity, Certifying Officers need assurance that the automated system was designed property and 1s functioning correctly .

One way to ensure system integrity is through annual reviews, with interim checks when there have been major system changes . Reviews allow Heads of Components (or designee) to certify that the system can be relied on to produce accurate and legal payments. Office of Management and Budget COMB) Circulars A-123 and A- 127,Title 7 of the General Accounbng Office (GAO) Poficy and Procedures Manual proVlde guidance for automated system use.

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Knowledge Review 3

True or false? It 1s extremely cifficult for any sing.le DoD off\c1al to personaOy ensure the accuracy,propriety,and lega ty of every payment.

[./ True

I False

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This statement is true .

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Lesson Summary

In this lesson we covered the Certifying Officer's responsibillbes .Srnce llabtity is automatic ,rt rs necessary to understand what an appointment to this poSlbon means.Knowing the various components of the payment process and how they interact 1s essenbal.

We discussed the requirements to ensure a valid payment. Reliability of the data provided by others is necessary. You also learned that a Certifying Officer does not have the capacity to personally oversee the breadth of work involved in a business process.

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Lesson Completion

You have completed the content for this lesson.

To continue,selec t another lesson from the Table of Contents on the left. If you have closed or hidden the Table of Contents,click the Show TOC

button at the top in the Atlas navigation bar.

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Lesson 4 Certifying Officer Pecuniary Liability TOC I RESOURCES I PRINT 1 HHP

Lesson Introduction

This lesson describes the pecuniary liability as defined by the Certifying Officer Legislation (COL) .

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Lesson Objectives

Terminal Learning Objective: Recognize the concept of pecuniary liability as defined by the Certifying

Officer Legislation {COL). At the end of this lesson you will be able to :

  • Define pecuniary liability.
  • Indicate how the Certifying Officer is held pecuniary liable for erroneous payments.

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Lesson 4 ·Certifylno Offlce r Pecun ary Liability TOC I RESOURCES 1 PRINT 1 HELP

Lesson Objective 1

What exac tly does 1t mean that a Certifying Officer is pecuniarily able7

Well Chris,improper payment by a Certifying Officer's certification of a payment voucher results in a presumption of negligence in the performance of duties . Pecuniary liability is the personal financial hab1hty of Certifying Officers for erroneous payments.

This Warm Up Acbvlty w1.ll give you an idea of how much you may already know about the concept of pecuruary kab!lity.

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Warm Up Activity

Drag the two correct answers to the Answer Box on the nght.

Pecl.Wliary &abdlty helps to protect the U.S. Government agatnSt Certityng Officer:

Corruption

·----------------- -------- ----------------

Theft

Burglary

Error

Dishonesty

Laundering

Embezzlement

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.

------------------------- ---------·--------

Che<..k Aw •vrr

The correc t answers are provided.

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Unauthorized Pnyments

Whenever an erroneous,illega ,or improper payment results from a Certifyng Officer's certification of a payment voocher ,the Certifying Officer is presumed to be negbgent in the performance of her or his duties .To rebut the presumption of negligence,a Certifying Officer must present sufficient evidence that he or she was not negrigent or his or her actions did not contribute to the erroneous

payment.

Investigators must determine whether or not an erroneous payment occurred and if evidence shows the absence of fault or negligence on the part of the Certifying Officer, debt collection procedures must be performed.See DoD FMR. Vol ume 5. Chaoter 6 for add1bonal guidanc e.'

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Knowledge Review 1

When 11wes1>gators attempt to determine whether or not an erroneous

payment occurred,they look for evidence of:

./ Errors or neg gence Errors and laundering Errors and burglary Corruption

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Investigators look for errors or negligence

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Lesson Objective 2

So pecuniary liability is defined as the

personal financial liability of Certifying Officers

for erroneous payments.

Yes,that's correct Chris. Next we'll look at describing how the Certifying Officer is held accountable for erroneous payments.

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Personal Fin11ncl11ILiability

Pecuniary kabtltty ts the personalfinancialliability of Certifying Officers for erroneous (i.e., illegal, improper, or tneorrec t) payments. This liabiity acts as an incenbVe to guard against errors and theft by others.It ult1matety helps protect the U.S. Government against Certifying Officer error and dishonesty.

Certifying Officers are automatically pecuniarily liable

when there is an erroneous payment.

Generally, the amount of pecuniary liability is determined during the investigation of the erroneous payment and 1s equal to the erroneous payment less any amounts recovered from the payee (bank).

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Knowledg e Review 2

Certifying Officers are automaticaBy pecunariy liable when there is

erroneous payment .True or false?

[./ True

I False

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This statement is true

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Lesson Summary

Pecuniary llab1hty ts the personal financial tiability that automabeally attaches to the Certifying Officer whenever an erroneous payment occlJS.

To gacn rebe f of babthty, Certifying Officers must prove that they were neither neglig ent nor the proximate cause of the irregularity.

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Lesson 4 Certifying Officer Pecuniary Liability

TOC I RESOURCES I PRINT 1 HHP

Lesson Completion

You have completed the content for this lesson.

To continue, selec t another lesson from the Table of Contents on the left.

If you have closed or hidden the Table of Contents,click the Show TOC button at the top in the Atlas navigation bar.

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Lesson Introduction

Certifying Officers have specific rights. In this lesson,we'll take a detailed look at the specific rights of Certifying Officers.

We'll also look at the process for requesting relief of pecuniary liability and the factors that bear on such a request.

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Lesson Objectives

Terminal Learning Objective: Determine the rights of the Certifying Officer to minimize their pecuniary liability. At the end of this lesson you will be able to :

  • Identify the rights of the Certifying Officer.
  • Recognize how a Certifying Officer can be relieved of pecuniary liability, including partial recovery of

a loss.

  • List outcomes if request for release of pecuniary liability is denied.
  • Identify factors that are not relevant to granting relief of pecuniary liability.

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Lesson Objective l

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The concept of the CertlfyWlg Officer being held financialy fiable is weighty stuff! As a Certifying Officer,what rights do Ihave to protect me?

Well Chris, there are rights that Certifying Officers can exercise in order to maintain the integrity of the certification process and minimize their pecuniary liability .

Let's do a quick Warm Up Activity to see how much you may already know about rights of a CerbfyWlg Officer.

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Lesson 5 Certifying Officer Rights

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Warm Up Activity

The Cerbfytng Officer has the right to not cerbfy a payment vouchef" if he or she quesbor\s the propriety or correctness of the voucher. True or false?

[./ True

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False

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This statement is true

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Fraud Types

In the Purchase Card program there are two distinct fraud types that may lead to an erroneous payment. They are :

1. Third-Party (merchant or external party with a compromised account). 2. Government (cardholder,billing official, or other).

Next we'll look at how the Certifying Officer can combat these types of fraud.

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Rights

There are ttvee nghts that Certifying Officers can exercise in 0<der to maintain the integrity of the certificabon process and minimize their pecun1ary fiability.These are:

1. Opbon to Not Certify a Payment

  1. Option to Seek an Advance Decision
  2. Option to Seek Additional Backup Materials

Any of these rights can result in postponing the certification of a payment.

Let's look at the details of each of these three rights.

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Option to Not Certify a Payment

The Certifying Officer has the option not to certify a payment voucher if the propriety or correctness of

the voucher is questionable.

During the voucher review process, the Certifying Officer has the right not to certify payment if,in his or her judgment ,the payment voucher certification package (Bank Invoice/Cardholder Certified Transactions ) does not properly support a valid and legal payment.

Certifying Officers are required to follow the terms of the GSA contract for the card issuing bank. The contract may require certifying and then disputing the transaction (see US Code .Title 10. Section 2784Cbl Q)). It is important to have all documentation that supports a position prior to certification. Disputing a transaction does not relieve the Certifying Officer of pecuniary liability. In the case of government or internal fraud,the Certifying Officer must contact the appropriate command representatives and/or criminal investigative activity department as soon as possible.

If the Cardholder processed an unauthorized purchase,the purchase cannot be disputed with the bank. The Cardholder will be required to reimburse the Government for the unauthorized purchase.

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Option to Seek an Advance Decision

Before certifying a questionable payment voucher,the Certifying Officer,by statute and regulation

(31 U.S.C. 3529 and 32 CFR Part 282 .Appendix F), has the right to seek an advance decision.

All advance decision requests must go through General Counsel of the Component concerned . What this means for a DFAS certifier is that an advance decision request must go through the chain of command to the DFAS Office of General Counsel.

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Option to Seek Additional Backup

The Cerl>fytng Officer has the right to seek additional back-up matenals to substantiate an otherwtse quesbonable payment.

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Knowledge Review 1

The Cerbfytng Officer does not have the right to deny cerbficabon of

a payment voucher 1r proper documentation accompar11es the request for payment. True or false?

True

l.J'.I False

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This statement is raise

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Lesson Objective 2

So pecuniary liability is defined as the personal financial liability of Certifying Officers for erroneous payments. What's next?

Next we'll describe how a Certifying Officer can be relieved of pecuniary liability, including partial recovery of a loss.

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Seeking Relief From Pecuniary Liabilty

Following the identification of an erroneous payment,diligent collection action will be taken. If collection action is unsuccessful,the Certifying Officer will remain pecuniarily liable for the uncollected balance,and may request relief of liability.

There are four possible outcomes to this request:

  • Partial recovery/pecuniary liability relief granted .
  • Partial recovery/pecuniary liability relief denied .
  • No recovery/pecuniary liability relief granted .
  • No recovery/pecuniary liability relief denied .

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Successful Recovery of Payment

A successful recovery of payment relieves the Certifying Officer of pecuniary liability. The Certifying Officer may request relief of liability for any unrecovered amount for which he or she is liable by submitting a statement explaining how the evidence shows a lack of negligence on his or her part.

The request is routed through the appropriate chain of command to DFAS Headquarters for consideration. Requests for relief may be delayed pending the outcome of collection efforts against the recipient. In all cases,the maximum delay is for one year following the attachment of liability against the Certifying Officer.

If no recovery is made,the same statement explaining that evidence shows a lack of negligence on the part of the Certifying Officer may be submitted. If relief is not requested, personal funds equal to the amount of the loss must be remitted.

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Granting Relief

Refief may be granted 1f the evX!ence shows that the erroneous payment was not the rest.tit of a Certifying Officer's negligence. EvX!ence that the Certifying Officer followed official Department of Defense regulabons, pol1c1es, and procedures including local standard operating procedures may support a finding that there was no negligence.

Following orders 1s not evidence of the absence of negligence or bad faith. No relief will be granted if the payment was not for a legal obligation or the payment violated a statute or law prohibiting payment.

If a request for rehef 1s granted, an ind.,vidual 1s not

pecunianly liable.

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Knowledge Review 2

The Certifying Officer will remain pecuniarily liable for an uncollected

balance but may request:

D Forgiveness because they were busy.

D Forgiveness because the commander wanted it.

D Relief of liability because they were sick.

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Relief of liability (accompanied with documentation showing no negligence ).

CfleckAn er I

The Certifying Officer may request Relief of liability accompanied with documentation showing not negligence

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Lesson Objective 3

So my rights include :

The option to Not Certify a Payment,the option to Seek an Advance Decision,and the option to Seek Additional Backup Materials.

Correct.

Now we'll describe outcomes if a request for

release of pecuniary liability is denied.

If a request for relief is denied,the individual must remit personal funds equal to the amount of the liability less any amounts collected. Alternatively, payment arrangements for settlement of the liability may be made between the individual and DFAS.

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Knowledge Review 3

If a request for rekef ts denied,what happens?

./ The Cerbfyng Officer must remit personal funds.

The Certifying Officer may appeal the dec1s1on to

their supervisor.

[ I The Certifying Officer may ask to have the judgm ent

deferred.

The Certifying Officer may request a jud1c1al hearing, because they were following orders .

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The Certifying Officer must remit personal funds if a request for relief is denied.

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Lesson Objective 4

Good information, Hector. Anything else I

should know about Certifying Officer rights?

We'll wrap up the lesson by identifying factors that are not relevant to granting relief of pecuniary liability.

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Factors That May Nol Be Used as a Basis for Relief

Factors that May Not Be Used as a Basis. for Rebef of PeCUfllary 1Jabd1ty:

  • Heavy Woridoad
  • Shortage of Personnel
  • Good Work Record
  • Length of Service
  • Lack of Supervision, Training,or Experience
  • Extra Duties
  • Financial Hardship
  • Following Orders

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Knowledge Review 4

Which of these factors may be used as a basis for rekef of pecuniary

iability?

Heavy wor1doad

1./J No negligence

Lack of supervision

Following orders

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No negligence may be used as a basis for relief.

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Lesson Summary

In this lesson,we discussed the Certifylng Officer's rights. Cerbfytng Officers have the right to request addibonal back- up tnfonnation or they can refuse to certify a voucher 1f they have questions or doubts . They also have a nght to request an advance decision.

This lesson also discussed relief of liability, including partial recovery of a loss and the role of negligence as it relates to relief of liability.

Several fac tors are not relevant to granting relief, including workload, lack or training or experience, and personal financial situation.

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Module Completion

Next

You have completed the content for this lesson.

At this point you should have completed all of the lessons in this module. Please take the Module Exam and complete the Module Survey so you may

receive credit for this course.

If you have closed or hidden the Table of Contents,click the Show TOC

button at the top in the A tlas navigation bar.

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