R 111638Z JUN 25
MARADMIN 272/25
MSGID/GENADMIN/CMC L LP WASHINGTON DC//
SUBJ/REQUISITION ACCOUNTING REQUIREMENTS//
REF/A/DOC/DOD 7000.14-R FMR VOLUME 3/AUG 2023//
REF/B/DOC/MCO 7300.21B/MAY/2015//
REF/C/DOC/DODM 4140.01-V5, FEB 2014//
REF/D/DOC/FAR 52.232-25/JAN 2025//
REF/E/DOC/FAR 32.904/JAN 2025//
REF/F/DOC/MCO 4400.150/JAN 2014//
REF/G/DOC/NFR 2021-0068-FIN-GFMC/1 NOV 21//INEFFECTIVE CONTROLS OVER
EXPENSES AND ACCOUNTS PAYABLE//
REF/H/DOC/NFR 2021-0069-FIN-GFMC/1 NOV 21//INEFFECTIVE CONTROLS OVER
OBLIGATIONS//
REF/I/DOC/NFR 2021-0091-FIN-GFMC/28 OCT 21//INEFFECTIVE PROCESS TO
RECORD AP BALANCES//
REF/J/DOC/CMC R 150029 JUN 23//
REF/K/DOC/MCO 4400.201/2016//
REF/L/DOC/NAVSUPINST 4200.99D/FEB 2024//
POC/KIMBER/LTCOL/AUDIT SUSTAINMENT OFFICER/DC I&L, LPS-F/
TEL: 571-256-2760/EMAIL/CHRISTOPHER.KIMBER(AT)USMC.MIL//
POC/KANTNER/MAJ/SUPPLY OPERATIONS OFFICER/DC I&L, LPS-1/
TEL: 571-256-7111/EMAIL/PAUL.KANTNER(AT)USMC.MIL//
NARR/REF A IS THE DEPARTMENT OF DEFENSE (DOD) FINANCIAL MANAGEMENT
REGULATION, WHICH ARTICULATES FEDERAL REGULATIONS THAT PERTAIN TO
THE DOD. REFERENCE B IS THE MARINE CORPS FINANCIAL MANAGEMENT
REGULATION. REFERENCE C IS DOD SUPPLY CHAIN MATERIEL MANAGEMENT
PROCEDURES: DELIVERY OF MATERIEL. REFERENCE D IS A CLAUSE IN FEDERAL
CONTRACTS THAT RELATES TO PROMPT PAYMENT. REFERENCE E IS FEDERAL
REGULATION ON DETERMINING PAYMENT DUE DATES. REFERENCE F PROVIDES
USMC REQUISITIONING PROCEDURES. REFERENCES G-I IDENTIFY INDEPENDENT
PUBLIC AUDITOR (IPA) NOTICE OF FINDINGS & RECOMMENDATIONS. REFERENCE
J IS THE DAILY TRANSACTION REPORT RECONCILIATION PROCEDURES FOR
PROCURE-TO-PAY. REFERENCE K IS THE MARINE CORPS ORDER FOR MANAGEMENT
OF PROPERTY IN THE POSSESSION OF THE MARINE CORPS. REFERENCE L IS
DEPARTMENT OF THE NAVY GOVERNMENT-WIDE COMMERCIAL PURCHASE CARD
PROGRAM POLICY.
GENTEXT/REMARKS/1. Situation. This message amplifies existing policy
for recording financial transactions throughout the requisition
process and posting to appropriate general ledgers.
2. Background. In 2021 the IPA issued references (g-i) asserting
that the Marine Corps does not accurately and timely record
financial transactions required across the respective general ledger
accounts. Specifically, the Marine Corps does not record obligations
to reflect agreements with vendors or perform receipt and acceptance
to approve vendor payment (liquidation) in accordance with federal
regulations, resulting in an inaccurate status of funds and late
vendor payments.
3. Mission. All requisitioning activities shall ensure valid
obligations are correctly recorded in Defense Agencies Initiative
(DAI) within 10 calendar days per reference (a), and all vendor
requests for payment are processed within the prescribed timeframes
per reference (b).
4. Execution.
4.a. Intent.
4.a.1. Ensure all obligations incurred on behalf of the government
are accurately recorded against the appropriate United States
Standard General Ledger (USSGL) account and tracked to completion
within the financial management system.
4.a.2. Promulgate timely payment expectations in accordance with
established regulations by processing vendor requests for payment
upon submission from vendors.
4.a.3. Promote unit proficiency in Wide Area Workflow (WAWF), the
primary system for processing vendor requests for payment.
4.b. Concept of Operations.
4.b.1. Induct, maintain, and reconcile all valid obligations for
supplies or services throughout the financial transaction process.
Each requisition method has distinct considerations for posting
obligations and expenses in DAI. Due to existing interface or feeder
system capabilities, obligations can post within a shorter timeframe
(i.e. fuel purchase obligations may post within 3-5 days). The
maximum timeframe to post valid obligations is 10 calendar days. All
transactions shall be verified on the Daily Transaction Report (DTR)
per reference (j).
4.b.2 Timely Posting of Obligations (4801 or 4802 USSGL). If an
obligation is incurred without an automatic interface (e.g.,
"offline orders"), commands must manually record the obligation in
DAI to match the requisition requirement. The over-recording and
under-recording of obligated amounts have negative consequences;
both scenarios can misrepresent the actual status of funds and may
lead to violations of financial regulations.
4.b.2.a. Exceptions. Government-wide Commercial Purchase Card (GCPC)
and freight SYNCADA interface with DAI upon certification of the
monthly invoice. Commands are not required to manually post
obligations for these particular interfaces. GCPC transactions are
exempt from the "10 day rule" and shall follow established policy
per reference (l). Source documentation reflecting the vendor
agreement signed by the authorized government official is required
to substantiate obligation transactions and shall be retained in
accordance with reference (k).
4.b.3. Timely Posting of Expenses (4901 USSGL). Receipt constitutes
acknowledgment that supplies or services have been delivered.
Acceptance constitutes acknowledgment that supplies or services
conform to applicable quality and quantity requirements. In some
instances (FOB origin), electronic acceptance may be necessary
before delivery with physical receipt and acceptance occurring after
delivery.
4.b.3.a. Electronic Acceptance and Requests for Payment. While
physical receipt actions begin upon delivery, timelines for
electronic acceptance and requests for payment are initiated upon
vendor submission in WAWF (excepting GCPC, which processes requests
for payment by communicating directly with the vendor). Receiving
activities will accept or reject requests for payment within 7
calendar days of vendor submission (before constructive acceptance
triggers Prompt Payment Act interest clock). Transactions that
require 3-way match (i.e. WAWF 2-in-1 invoices) also require a
receipt in DAI to facilitate a prompt payment.
4.b.3.a.1. Manual Entry of Receipts in DAI. Receipts only need to be
inducted into DAI for a receipt requirement that is not satisfied by
a feeder system or in the event of a system interface error.
4.b.3.b. In accordance with reference (c), receiving activities
shall document physical receipt for the proof of delivery file no
later than 5 business days from the date supplies are received. The
application of 5 business days supersedes the current 2 business
days authorized in Volume 4 of reference (k) and identifies what
will be published in Volume 5 of reference (k). Additionally, in
accordance with reference (d) and (e), when in receipt of supplies
or services from a vendor, the government has 7 calendar days
following the date of delivery (excluding MILSTRIP, i.e. GCSS-MC,
ServMart, and fuels) to raise any issues with quality or quantity
with the vendor. If the government does not object within 7 calendar
days, delivery is considered accepted. This is referred to as
"constructive acceptance".
4.b.3.c. All requisitioning activities will maintain access to and
monitor WAWF. The designated activity will review invoices within
WAWF and accept or reject as appropriate within 7 calendar days of
vendor submission (excluding MILSTRIP). This ensures vendors receive
prompt payment and the Marine Corps avoids late payment penalties.
WAWF is the primary system for recording receipt and acceptance and
approving vendor requests for payment; it must be actively monitored
to ensure vendor requests for payment are processed within required
timeframes.
4.c. Tasks.
4.c.1. Fleet Marine Force and Supporting Establishment
(MARCORLOGCOM, MARCORSYSCOM and affiliated PEO-Ls, TECOM, MCWL,
MCCDC, MCICOM).
4.c.1.a. Ensure compliance with this directive among subordinate
commands and provide additional guidance as necessary.
4.c.1.b. Ensure all requisitioning activities have properly
appointed personnel in accordance with reference (k) to process
vendor requests for payment. Special attention must be paid to WAWF
acceptors to ensure duty station changes and operational
requirements do not create a gap in government acceptance capability.
4.d. Coordinating Instructions.
4.d.1. Receipt and acceptance in WAWF generates a receiving report
and distributes acceptance to financial systems. However, it is
imperative that government acceptors conduct and document physical
acceptance to confirm the government has received supplies or
services in accordance with the vendor agreement approved by
authorized government official. Example key supporting documentation
to confirm receipt includes DD Form 250, DD Form 1149, or annotated
shipping manifest from a thorough inventory or inspection that will
verify vendor performance meets quality and quantity requirements.
4.d.2. A copy of this policy shall be posted as appropriate to local
command directives sites.
5. Administration and Logistics.
5.a. Per reference (k), financial documentation will be retained for
a period of ten years (three years active and seven years archived)
and be readily available for audit purposes.
5.b. HQMC (DC, I&L) will test for compliance of this policy via
Field Supply Maintenance Analysis Office (FSMAO) internal control
process reviews.
6. Command and Signal. Questions concerning the contents of this
message will be directed to the POCs listed above.
7. Release authorized by James L. Rubino (Acting), Assistant Deputy
Commandant for Installations and Logistics.//