FINANCIAL GUIDANCE FOR INFORMATION TECHNOLOGY (IT) PURCHASES
Date Signed: 11/5/2018 | MARADMINS Number: 629/18
MARADMINS : 629/18
R 021720Z NOV 18
MARADMIN 629/18
MSGID/GENADMIN, USMTF, 2018/CMC PR WASHINGTON DC (UC)/F0002//
SUBJ/FINANCIAL GUIDANCE FOR INFORMATION TECHNOLOGY (IT) PURCHASES//
REF/A/MARADMIN 464/17, FINANCIAL GUIDANCE FOR INFORMATION TECHNOLOGY (IT) PURCHASES//
REF/B/MARADMIN 591/17, INTERIM FINANCIAL GUIDANCE FOR TABLET PURCHASES//
REF/C/MARADMIN 375/11, INFORMATION TECHNOLOGY (IT) FUNDING, APPROVAL, AND PROCUREMENT//
REF/D/IRM 5236-06A, INFORMATION TECHNOLOGY PROCUREMENT REVIEW AND APPROVAL SYSTEM (ITPRAS) LESS THAN 50K DOLLARS APPROVAL THRESHOLD EXECUTION GUIDELINES/15 MAR 2017//
REF/E/DOD FMR VOL 2A, CHAP 1//
REF/F/DOD FMR VOL 2B, CHAP 18//
REF/G/DON FMPM CHAP 3, DEPARTMENT OF THE NAVY FINANCIAL POLICY MANUAL//
REF/H/MCO 7300.21B, MARINE CORPS FINANCIAL MANAGEMENT STANDARD OPERATING PROCEDURE MANUAL//
REF/I/SECNAV 5400.15C CHANGE TRANSMITTAL 1, DEPARTMENT OF THE NAVY RESEARCH AND DEVELOPMENT, ACQUISITION, ASSOCIATED LIFE-CYCLE MANAGEMENT, AND LOGISTICS RESPONSIBILITIES AND ACCOUNTABILITY, 2 DEC 2011//
REF/J/MCO 11000.5, FACILITIES SUSTAINMENT, RESTORATION AND MODERNIZATION PROGRAM//
REF/K/MARADMIN 298/08, INFORMATION TECHNOLOGY (IT) PERIPHERALS ACQUISITION POLICY//
REF/L/MARADMIN 523/15, INFORMATION TECHNOLOGY (IT) CONSUMABLES POLICY//
REF/M/MARADMIN 056/14, MANAGEMENT OF COPIERS, PRINTERS, FAX MACHINES SCANNERS, AND MULTIFUNCTIONAL DEVICES//
REF/N/MARADMIN 331/15, OFFLINE AND INTERNET-BASED ORDERING POLICY REF/O/DODI 1015.15, PROCEDURES FOR ESTABLISHMENT, MANAGEMENT, AND CONTROL OF NONAPPROPRIATED FUND INSTRUMENTALITIES AND FINANCIAL MANAGEMENT OF SUPPORTING RESOURCES//
GENTEXT/REMARKS/1. This is a Headquarters Marine Corps (HQMC), Deputy Commandant for Programs and Resources (DC PR) message.
2. This MARADMIN significantly revises the guidance provided in MARADMINs 464/17 and 591/17 (References (a) and (b)). MARADMINs 464/17 and 591/17, and Para 10 of MARADMIN 375/11 (Reference (c)) are hereby cancelled.
3. Background. The Information Technology (IT) procurement process ensures IT requirements support Marine Corps IT vision and strategy. The Information Technology Procurement Review and Approval System (ITPRAS), managed by HQMC C4, is the mechanism used for inputting, routing, reviewing, adjudicating, and archiving Information Technology Procurement Requests (ITPRs). During FY 2017, the financial review for ITPRs was delegated from HQMC PR to designated G-8/Comptrollers.
4. Purpose. Provide financial management guidance to assist G-8/ Comptroller personnel in conducting ITPR financial reviews. This guidance will also aid G-6, Counsel, and Contracts personnel who are involved in the IT procurement process. The primary role of the financial review is to ensure the correct appropriation(s) are identified for each ITPR in order to mitigate potential Antideficiency Act (ADA) violations. Guidance specific to the ITPRAS process will be released by Director, C4. The guidance provided in this MARADMIN is not all-inclusive and should be used in conjunction with Department of Defense (DoD), Department of the Navy (DON), and Marine Corps guidance.
4.A. Designated G-8/Comptroller offices at the Major Resource Identifier (MRI) level, select Suballotment Resource Identifier (SRI) level, and several Work Center Identifier (WCI) levels within Headquarters, Marine Corps are delegated the responsibility to conduct a financial review of all ITPRs. This will better support the review and approval of the requirement (conducted by the G-6) with the appropriate resources (G-8/Comptroller) to ensure the correct appropriation has been identified. No further delegation is authorized.
HQMC            DMCS (AR)       MARCENT HQMC (C4)
DC (IL)         MARFORCYBER     HQMC (I) / MCIA
DC (MRA)        MARFOREUR/AF    MARFORSOUTH
DC (PR)         MARSOC          MCI EAST
DC (PPO)        MCICOM          MCI PAC
MARFORCOM       MARCORLOGCOM    MCI WEST
MARFORPAC       MCRC            MCSC
MARFORNORTH     TECOM           MCCS
MARFORRES                       HQMC (HH)
MCCDC                           MCI NCR
I MEF                           HQMC (TSO)
II MEF
III MEF
4.B. Requirements for Financial Management (FM) Reviewers. Each G-8/Comptroller office will identify and maintain at least two analysts to conduct the financial review as part of the ITPRAS workflow. These analysts will meet the following qualifications:
4.B.(1) All FM reviewers must complete the DON Principles of Appropriations Law course prior to reviewing any requests in ITPRAS. This course is located on the ASN(FMC) PBIS website: https:(slash- slash)fmbweb1.nmci.navy.mil/pbis/training/pbisweb_training.cfm. The website requires DoD PKI/CAC and must be accessed from a .MIL network.
4.B.(2) A fiscal/appropriations law refresher course must be taken at a minimum of every three years to ensure all parties are well versed in the laws and rules for spending federal appropriations. Fiscal/appropriation law courses are available in several sources including the DoD FM myLearn Web site https:(slash-slash)fmonline. ousdc.osd.mil/FMmyLearn/CourseDetails.aspx?id=2168, and PBISweb https:(slash-slash)fmbweb1.nmci.navy.mil/pbis/training/pbisweb_ training.cfm.  The source and content of the various appropriation law training options should be commensurate with the position held.
4.B.(3) FM Reviewers must obtain and maintain an ITPRAS Remedy account and complete all required training to work in the Remedy system. All required training certificates and documentation listed in 4.B.(1) and 4.B.(2) will be uploaded in Remedy when the user account is requested. Changes in personnel conducting the financial review will be submitted to the Unit Command Coordinator (UCC) in the local G-6 office who will coordinate the update with the HQMC C4 IT Procurement Branch.
4.B.(4) It is recommended that FM Reviewers be 0500 series civilian employees/34XX series Marines that hold a minimum Level 1 DoD Financial Management (FM) certification and/or worked in DoD financial management for a minimum of two years.
4.C. Financial Management guidance, per References (e) through (h), is clarified and updated by this MARADMIN, as it directly relates to the purchase of IT goods and services using Marine Corps appropriated funds. HQMC PR will provide periodic training on the IT funding rules to commands and the individuals identified in 4.A., as well as other individuals involved in the IT Procurement process.
5. Definitions.
5.A. Information Technology (IT): Any equipment or interconnected system or subsystem of equipment used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission or reception of data or information, including computers, ancillary equipment, software, firmware and similar services and related resources whether performed by in-house, contractor, other intra-agency or intergovernmental agency resources/personnel. Both system and non-system IT requirements (material, labor, and services) associated within the Marine Corps organizations assigned missions (plan, provide, conduct), activities (design, engineer, procure, acquire, build, install, service and sustain), and resources provided through support agreements for IT requirements at all levels are included in IT resource reporting. (Reference (f))
5.B. System: A system shall be considered to exist if a number of items are a part of and function within the context of a whole to satisfy a documented requirement. (References (e) and (g))
5.C. System unit cost: The aggregate cost of all components (e.g., equipment, integration, engineering support and software) that are part of, and function together, as a system to meet an approved documented requirement. (Reference (g))
5.C.(1) New system: a new system includes the items are a part of and function within the context of a whole to satisfy a documented requirement. In this case, “system unit cost” applies to the Aggregate cost of all equipment items and software being acquired as a new system.
5.C.(2) Additions to or replacements within an existing system: When requirements necessitate adding/replacing or modifying equipment/ software which is a component of, or supports the functioning of an existing system to address validated deficiencies, only the aggregate cost of the additional equipment/software procurement will be used to determine whether the purchase is an expense or an investment.  In this case, "system unit cost" applies only to the aggregate cost of all new system components acquired.
5.C.(3) Stand-alone items or minor additions: the costs for stand-alone items, minor additions that do not substantially improve performance or functionality, or replacements/repairs within an existing system, that are not themselves characteristic of a system, need not be aggregated and will be funded according to the current expense-investment threshold (250,000) unless the items are subject to centralized management and funding.
5.D. Technology Refreshment: The periodic replacement of Commercial Off-The-Shelf (COTS) components (e.g., processors, displays, operating systems), and/or commercially available software within larger DoD systems to assure continued supportability of that system through an indefinite service life. Tech Refresh is not intended as a means to increase the performance envelope of existing systems. The correct appropriation for budgeting and funding an IT refresh effort is dependent on the activity and the underlying tasks that make-up the effort. An IT refresh effort may require funding from more than one appropriation. The expense-investment criteria still applies to tech refresh requirements. (References (e) and (g))
5.E. Telecommunications Infrastructure: IT materials that are associated with real property assets, including accessory equipment and furnishings that are not intended to be movable, are required for operation, and are permanently affixed as a part of the real property facility. IT transport cabling (copper and fiber optic) installed in the ground or overhead that run between real property facilities is also considered Telecommunications Infrastructure. Procurement of these items are governed by Reference (j). Personal property/collateral equipment are also subject to this MARADMIN.
5.F. Program of Record (POR): A POR is a program, as recorded in the current Future Years Defense Program (FYDP) or as updated by the last FYDP by approved program documentation (e.g., Acquisition Program Baseline (APB), Acquisition Strategy, or Selected acquisition Report (SAR)). For purposes of this MARADMIN, these are officially designated acquisition programs or projects executed as a directed POR action. (Reference (i))
5.G. Centrally Managed: Items which are identified within the approved property accountability system are assigned to a centralized manager within a central supply system or a DoD-wide or Service-wide acquisition and control system. For assistance in determining if a requirement is centrally managed, please e-mail the Marine Corps Systems Command (MCSC) at Watchofficer@usmc.mil.
5.H. Centrally Procured: The alignment of materials, supplies, or services that have been designated by Headquarters, Marine Corps as an ‘enterprise solution’ and are centrally procured by a single organization. USMC, DON, DoD, or other federal agency funding for requirements that are centrally procured is provided by the requiring entity to the agency managing the enterprise contract.
6. Policy. The correct appropriation for an IT requirement is dependent on the activity and the underlying tasks that make up the IT requirement. Multiple appropriations may be required depending on the nature of the requirement. Requirements for a single system may not be fragmented in order to circumvent the investment threshold as defined in 6.A.(1).  There are two basic questions that need to be asked when funding any IT requirement: (1) is it centrally managed? And, (2) is the system unit cost greater than the expense-investment threshold? If the answer is yes to either question, the correct appropriation is generally PMC for both new procurements, as well as technology refreshment. HQMC PR updated the IT Funding Decision Matrix which will assist financial managers, as well as other personnel involved in the IT procurement process, with verifying the correct appropriation has been selected for a given IT purchase. The IT Funding Decision Matrix can be found at https:(slash-slash) ehqmc.usmc.mil/org/pr/ fiscalops/audit/ITFundingGuidance. The following is basic policy for making funding determinations, but should not be the sole reference for determining the correct appropriation:
6.A. Expense-Investment Criteria.
6.A.(1) Expense-Investment Threshold: The dollar threshold for expense and investment determinations for non-centrally managed programs is 250 thousand dollars per unit/system.
6.A.(1)(a) A “system unit cost” less than 250 thousand dollars is generally classified as an expense, while a system unit cost equal to or more than 250 thousand dollars is generally classified as an investment.
6.A.(1)(b) For operational requirements of a Combatant Command engaged in overseas contingency operations, the system unit cost not to exceed 500 thousand dollars can be classified as an expense. For the DON, this would include units in theater and assigned to NAVCENT and MARCENT. (Reference (g))
6.A.(2) Costs budgeted in the Operation and Maintenance appropriations are considered expenses. Costs budgeted in the Procurement appropriations (e.g., Procurement, Marine Corps (PMC)) are considered investments. Costs budgeted in the Research, Development, Test and Evaluation (RDTE) appropriation include both expenses and investments.
6.A.(3) For modification efforts, only the cost of the upgrade (e.g., new hardware, and associated technical assistance) is counted towards the expense-investment threshold. IT procured and fielded by a centrally managed program or POR must use PMC funding for all associated IT equipment refresh.
6.A.(4) Items procured from the Navy Working Capital Fund (NWCF) will be treated as expenses in all cases except when intended for use in weapon system outfitting, government furnished material (GFM) on new procurement contracts, or for installation as part of a weapon system modification, major reactivation, or major service life extension.
6.B. Expenses. The costs incurred to operate and maintain individual Marine Corps units or organizations. Expenses include personal services, supplies, and utilities. (Utilities include the operating and maintenance cost associated to real property telecommunications infrastructure and management systems.)
6.B.(1) Operation and Maintenance, Marine Corps (OMMC) and Operation and Maintenance, Marine Corps Reserves (OMMCR). IT Requirements with a system unit cost less than 250 thousand dollars, are generally classified as expenses. Expenses incurred for continuing operations, including repair parts and current services are budgeted in the Operation and Maintenance appropriations regardless of cost. Modernization/modification/improvement costs under 250 thousand dollars are considered expenses, as are one-time projects such as developing planning documents and studies. OMMC and OMMCR funding is also required to purchase licensing fees associated with COTS software requiring annual license renewals. Items that use OMMC and OMMCR funding for initial procurements must be sustained by the funding organization and should use the same Operation and Maintenance appropriation for all associated IT equipment refresh unless the refresh exceeds the investment/expense threshold or is classified as centrally managed within the property accountability system or aligned to a POR.
6.B.(2) Examples when an Operation and Maintenance appropriation is appropriate for purchasing IT requirements:
6.B.(2)(a) Annual fee software licenses, software-as-a-service, or annual software maintenance on existing perpetual licenses
6.B.(2)(b) Peripherals per Reference (k)
6.B.(2)(c) Consumables per Reference (l)
6.B.(2)(d) Support Services for operational and maintenance purposes (the expense threshold does not apply)
6.B.(2)(e) Website subscriptions
6.B.(2)(f) Minor Military Construction projects cover work to build a new facility, or alter an existing facility falling below the MILCON threshold, currently 1 million dollars.
6.B.(2)(g) IT procurements not centrally managed by a POR (e.g., desktops, laptops, tablets, switches, routers, repeaters, servers, software and software maintenance), but may be centrally procured at MCSC, and have a system unit cost below the expense-investment threshold of 250 thousand dollars. For assistance in determining whether an enterprise contract exists, please e-mail MCSC at Watchofficer@usmc.mil.  Example: Purchase of desktops, laptops, tablets, switches, routers, servers, etc. to support coalition requirements that are not part of the MCEN.
6.C. Investments. These costs benefit future periods and generally are of long-term character such as real property and personal property equipment. Investments generally provide new or additional military capabilities or modernize existing capabilities.
6.C.(1) Procurement, Marine Corps (PMC). PMC funds personal property equipment with a system unit cost greater than or equal to the expense-investment threshold of 250 thousand dollars, as well as centrally managed items or PORs.
6.C.(2) Proprietary software is an investment, subject to the expense-investment criteria, unless it is financed on an annual fee basis which is an expense.
6.C.(3) Examples when PMC is required for purchasing IT requirement/s:
6.C.(3)(a) Centrally managed IT desktops, laptops, tablets, switches, routers, repeaters, servers, and software, etc. For assistance in determining if a requirement is centrally managed, please email MCSC at Watchofficer@usmc.mil.
6.C.(3)(b) The Initial purchase of a new system will include the initial basic items to include: laptop/desktop CPU and necessary peripherals (mouse, keyboard, docking station and monitor).
6.C.(4) Research, Development, Test, and Evaluation (RDTE). In general, all developmental activities involved in bringing a program to its objective system are funded with RDTE. Major upgrades increasing the performance envelope of existing systems, purchase of test articles, and conduct developmental testing and/or initial operational test and evaluation prior to system acceptance should be funded with RDTE. Reaching the objective system, as defined in the requirements documents, is a critical determinate for funding. Some software programs, particularly those following a spiral or Incremental development pattern, may be approved for initial fielding even though the early capability is below the objective system requirements. The follow-on development and test activities required to reach the objective system performance will be budgeted in RDTE. The acquisition, operation and maintenance of IT systems that are used exclusively to support RDTE activities will be budgeted and funded within the RDTE appropriation.
6.C.(5) In order to meet a new policy or directive which is outside the normal Program Objective Memorandum (POM), organizations requiring investment funding must coordinate their requirements with the appropriate HQMC or MCSC Program Manager (PM) to ensure requirements are vetted through the POM process to obtain PMC funds for future year requirements. Units with a requirement for PMC funding in the current year of execution must submit a current year deficiency via the appropriate HQMC or MCSC PM to the Director -  Financial Management at MCSC.
6.D. Navy Working Capital Funds (NWCF). Marine Corps Logistics Command is responsible for the execution of the Marine Corps portion of the NWCF. IT systems developed and acquired using NWCF are funded through the Capital Investment Program if the system is 250 thousand dollars or more. Systems costing less than 250 thousand dollars are funded through the operating budget.
6.E. Non-appropriated Funds (NAF). NAF is the primary funding mechanism for Marine Corps Community Services (MCCS) activities. Command Comptrollers must abide by financial policies outlined in this MARADMIN, Reference (n) paragraph E4.T1.15.4., Reference (g) paragraphs 03243, and all other financial management regulations when authorizing payments through the Uniform Funding Management (UFM) process.
6.F. Non-Marine Corps Appropriated Funds (i.e., Navy, Joint, National Intelligence Program, etc.). IT hardware, software, and support services connected to Marine Corps systems, but procured using other service or department appropriated funds must be accomplished in accordance with financial management policies/ regulations.
7. Roles and Responsibilities.
7.A. Deputy Commandant, Programs and Resources (DC PR). Provides financial management subject matter expertise, on an as-needed basis, to ensure the correct appropriation is identified. HQMC PR promulgates financial management policy for the Marine Corps.
7.B. Director, Command, Control, Communications and Computers (C4)/ Department of the Navy Deputy Chief Information Officer, Marine Corps (DDCIO(MC)). The Director C4/DDCIO(MC) is the ITPR process owner. The Director develops and promulgates IT procurement policy and guidance, as well as provides ITPRAS training for submitters, reviewers and UCCs.
7.C. Marine Corps System Command (MCSC). As the programmatic review authority for ITPRAS requests, MCSC determines if the requested technologies or services are aligned to existing enterprise contracts managed by MCSC. Marine Corps acquisition PORs, operating forces, and supporting establishment organizations must procure the requested IT through existing MCSC enterprise contracts. MCSC manages enterprise purchasing vehicle(s) for IT hardware, software, and MCEN services and support. In coordination with C4, MCSC maintains the USMC Enterprise Service Catalog that provides a list of IT assets that can be centrally procured.
7.D. Deputy Commandant, Installations and Logistics (DC IL). As the property classification (Equipment/Real Property) and system accountability authority, IL validates that IT is correctly accounted for within the approved accountable property systems of record (APSR).
7.E. Designated G-8/Comptrollers. The designated G-8/Comptroller office validates the correct appropriation used to procure the required hardware, software, or support services, in accordance with financial management policies/regulations.
7.F. The below POCs are available to assist with questions that arise with the procurement process. Budget Policy: Shari Ritter, HQMC PR RFC, Pentagon, 703-614-0710, shari.ritter@usmc.mil Procurement Analyst: Sarah Geist, HQMC PR RFI, Pentagon, 703-692-4771, sarah.geist@usmc.mil Investment Appropriations: Charlene Romero, MCSC DFM, Quantico, 703-432-3293, charlene.romero@usmc.mil NGEN: Michael Berry, MCSC PM NI, Quantico, 703-784-4807,michael.s.berry@usmc.mil ITPRAS Policy/Process: Maj David Nowlin, C4 CIO, Pentagon, 703-695-0995, david.nowlin@usmc.mill ITPRAS Policy/Process: GySgt Jose Garcia, C4 CIO, Pentagon, 703-693-9940, jose.u.garcia1@usmc.mil Non Programmatic Tactical Systems: Michael McGraw, C4, Strategic Planning, Pentagon, 703-614-6530, michael.p.mcgraw1@usmc.mil Enterprise Services: LtCol Justin Lamorie, CDI CDD, Quantico, 703-784-3194, justin.lamorie@usmc.mil
8. Release authorized by LtGen John M. Jansen, Deputy Commandant for Programs and Resources.//