MARADMINS : 350/11
R 202033Z JUN 11
UNCLASSIFIED//
MARADMIN 350/11
MSGID/GENADMIN/CMC WASHINGTON DC PR//
SUBJ/FUND CONTROL PERSONNEL TRAINING REQUIREMENT//
REF/A/MSGID:DOC/GAO-08-1063/YMD:SEP08//
REF/B/MSGID:DOC/DOD FINANCIAL MANAGEMENT REGULATION 7000.14-R//
REF/C/MSGID:OASN(FMC) MEMO 5NOV08//
REF/D/MSGID:OASN(FMC) MEMO 8JUL09//
REF/E/MSGID:OASN(FMC) MEMO 28MAY10//
REF/F/MSGID:OASN(FMC) MEMO 2JUN10//
NARR/REF (A) IS GOVERNMENT ACCOUNTABILITY OFFICE (GAO) REPORT ON IMPROVEMENTS NEEDED IN ANTIDEFICIENCY ACT (ADA) CONTROLS AND INVESTIGATIONS. REF (B) VOLUME 14, CHAPTER 2 REQUIRES DEPARTMENT OF NAVY (DON) FUND CONTROL PERSONNEL TO RECEIVE APPROPRIATIONS LAW TRAINING, INCLUDING REFRESHER TRAINING, AT LEAST EVERY THREE YEARS. REF (C) ESTABLISHES TRAINING AND REPORTING REQUIREMENTS FOR THE DON. REF (D) ANNOUNCES ADDITIONAL ONLINE BUDGET EXECUTION COURSE DEVELOPED TO PROVIDE A BROAD OVERVIEW OF EXECUTION PROCESSES, INCLUDING INSTRUCTION ON THE PROPER ISSUANCE AND ACCEPTANCE OF FUNDING DOCUMENTS. REF (E) SETS SUBMISSION DATES AND INSTITUTES A TRAINING METRIC TO CAPTURE THE NUMBER OF FUND CONTROL PERSONNEL TRAINED. REF (F) PROVIDES CLARIFICATION TO REF (E) WITH RESPECT TO THE REFERENCES CITED AND REPORTING DATES.//
POC/SHARI RITTER/RFR/-/-/TEL: 703-614-0710//
GENTEXT/REMARKS/1. PER REF (A), GAO FOUND THE DEPARTMENT OF DEFENSE'S (DOD) COMPLEX AND INEFFICIENT PAYMENT PROCESSES, NONINTEGRATED BUSINESS SYSTEMS, AND WEAK INTERNAL CONTROLS IMPAIR ITS ABILITY TO MAINTAIN PROPER FUNDS CONTROL, LEAVING THE DEPARTMENT AT RISK OF INAPPROPRIATELY OBLIGATING AND/OR SPENDING ITS APPROPRIATIONS IN VIOLATION OF THE ADA. GAO MADE SIX RECOMMENDATIONS RELATED TO TRAINING AND IMPROVING COMPLIANCE WITH DEPARTMENT OF DEFENSE (DOD) REGULATIONS PERTAINING TO ADA INVESTIGATIONS. DOD CONCURRED WITH THE RECOMMENDATIONS AND IDENTIFIED SPECIFIC ACTIONS BETAKEN TO IMPLEMENT THEM. THIS MARADMIN ADDRESSES ONE OF THE SIX RECOMMENDATIONS.
2. PER REFS (B) AND (C), THE DOD AND THE MILITARY SERVICES MUST ENSURE KEY FUND CONTROL PERSONNEL RECEIVE FISCAL/APPROPRIATIONS LAW TRAINING OR REFRESHER TRAINING AT LEAST EVERY THREE YEARS. THIS TRAINING MUST BE DOCUMENTED WITHIN THE RESPECTIVE COMMAND. A STATUS REPORT HIGHLIGHTING THE NUMBER OF FUND CONTROL PERSONNEL ON-HAND AND THE NUMBER IN COMPLIANCE WITH TRAINING POLICY WITHIN THE MARINE CORPS WILL BE INCLUDED IN THE DON'S ANNUAL ADA REPORT TO THE OFFICE OF THE SECRETARY OF DEFENSE (OSD). IN ADDITION TO THE FISCAL/APPROPRIATIONS LAW TRAINING, PER REF (D), FUND CONTROL PERSONNEL ARE REQUIRED TO COMPLETE THE ONLINE BUDGET EXECUTION COURSE FOUND ON THE ASN(FMC) WEBSITE. COMPLETION INFORMATION FOR THIS TRAINING SHOULD BE MAINTAINED AT THE COMMAND LEVEL.
3. WITHIN THE MARINE CORPS, ALL INDIVIDUALS WHO RECEIVE OR ISSUE APPROPRIATED FUNDS (APF) OR GENERATE REQUESTS FOR APF (E.G. SUPPLY, CONTRACTING, ETC.) MUST COMPLY WITH THESE TRAINING REQUIREMENTS. THESE PERSONNEL WILL BE CLASSIFIED IN 2 TIERS.
A. TIER 1 PERSONNEL MEET THE ASSISTANT SECRETARY OF THE NAVY (FINANCIAL MANAGEMENT AND COMPTROLLER) (ASN(FMC)) DEFINITION FOR FUND CONTROL PERSONNEL AND MUST BE REPORTED TO THE DON. FUND CONTROL PERSONNEL ARE DEFINED, PER REF (C), AS INDIVIDUALS WHO ISSUE AND/OR ACCEPT FUNDING ALLOCATIONS AND FUNDING DOCUMENTS (E.G. WORK REQUESTS, PROJECT ORDERS, ETC.). ALL FUND CONTROL PERSONNEL MUST BE DELEGATED AUTHORITY IN WRITING FROM THE COMPTROLLER, BY AUTHORITY PROVIDED BY THE COMMANDING GENERAL/COMMANDING OFFICER (CG/CO). ACCORDINGLY, KEY FUND CONTROL PERSONNEL INCLUDE THE CG/CO, COMPTROLLER, AND DELEGATED STAFF.
B. TIER 2 PERSONNEL ARE THOSE INDIVIDUALS WHO ISSUE ROUTINE, SMALL DOLLAR DOCUMENTS SUCH AS TRAVEL ORDERS, REQUESTS FOR TRAINING OR SUPPLIES, AND PURCHASES MADE VIA GOVERNMENT PURCHASE CARDS. TIER 2 PERSONNEL ARE NOT REQUIRED TO BE REPORTED TO THE DON, BUT MUST MAINTAIN COPIES OF THEIR CERTIFICATES LOCALLY.
4. CG/COS MUST BE TRAINED IN FISCAL/APPROPRIATIONS LAW AND THE ONLINE BUDGET EXECUTION COURSE. HOWEVER, INSTEAD OF TAKING AN EXTENDED FISCAL/APPROPRIATIONS LAW COURSE, THESE INDIVIDUALS MAY ELECT TO HAVE THEIR COMPTROLLER PROVIDE THEM WITH A BRIEFING. A FISCAL/APPROPRIATONS LAW BRIEFING HAS BEEN PREPARED TO BE USED SPECIFICALLY FOR THIS PURPOSE. THIS BRIEFING IS POSTED ON THE PR (RFR) SHAREPOINT SITE.
5. MULTIPLE MEANS EXIST FOR COMPTROLLERS AND DELEGATED STAFF TO OBTAIN THE REQUISITE TRAINING. THE FOLLOWING LIST IS REPRESENTATIVE, BUT NOT ALL INCLUSIVE.
A. ONLINE FISCAL LAW COURSE SPONSORED BY ASN(FMC): HTTPS:SLASH SLASH FMBWEB1.NMCI.NAVY.MIL/POLICY/FIN UNDERSCORE MGMT UNDERSCORE TRAINING.HTM (A DOD CAC/PKI CERTIFICATE IS REQUIRED).
B. ON-SITE FISCAL LAW COURSE CONDUCTED BY ASN(FMC) OFFICE OF COUNSEL. REFERENCE THE WEBSITE ABOVE FOR INSTRUCTIONS ON SCHEDULING ON-SITE TRAINING.
C. THIRD PARTY FISCAL LAW COURSES:
(1) MARINE CORPS PRACTICAL COMPTROLLERSHIP COURSE.
(2) GAO PRINCIPLES OF APPROPRIATIONS LAW COURSE.
(3) DEPARTMENT OF AGRICULTURE (USDA), PRINCIPLES OF FEDERAL APPROPRIATIONS LAW COURSE.
(4) THE JUDGE ADVOCATE GENERAL'S LEGAL CENTER AND SCHOOL, CONTRACT AND FISCAL LAW DEPARTMENT MANAGED COURSES.
(5) ASMC CERTIFIED DEFENSE FINANCIAL MANAGEMENT (CDFM) TRAINING COURSE.
6. PER REFS (E) AND (F), MAJOR COMMAND (MRI LEVEL) COMPTROLLERS AND HQMC FINANCIAL MANAGERS MUST CONSOLIDATE AND PROVIDE THE FOLLOWING INFORMATION TO DC, PR (RFR) SEMIANNUALLY WITH DATA CURRENT AS OF 30 MARCH AND 30 SEPTEMBER:
A. NUMBER OF FUND CONTROL PERSONNEL (TO INCLUDE PERSONNEL AT THE SUBORDINATE COMMAND RECIPIENT INDICATOR (SRI) AND WORK CENTER IDENTIFIER (WCI) LEVEL).
B. NUMBER OF PERSONNEL WHO HAVE RECEIVED FISCAL/APPROPRIATIONS LAW OR REFRESHER TRAINING WITHIN THE LAST 3 YEARS.
C. IF 100 PERCENT OF FUND CONTROL PERSONNEL HAVE NOT MET THIS MANDATORY TRAINING REQUIREMENT, PROVIDE AN EXPLANATION WHY AND EXPECTED TIMEFRAME FOR MEETING THIS REQUIREMENT.
D. SUBMISSIONS ARE DUE TO DC, PR (RFR) NLT 7 APRIL AND 7 OCTOBER OF EACH YEAR.
7. POINT OF CONTACT FOR THIS MATTER IS MS. SHARI RITTER, 703-614-0710, SHARI.RITTER@USMC.MIL.
8. RELEASE AUTHORIZED BY LTGEN J. E. WISSLER, DEPUTY COMMANDANT FOR PROGRAMS AND RESOURCES DEPARTMENT.//