R 291602Z DEC 09
UNCLASSIFIED//
MARADMIN 0741/09
MSGID/GENADMIN,USMTF,2007/CMC WASHINGTON DC PR RFA(UC)//
SUBJ/PREVALIDATION OF MARINE CORPS PAYMENTS//
REF/A/MSGID:P.L. 103-335/DOD APPROPRIATIONS ACT 1995/YMD:19940930//
REF/B/MSGID:10 U.S.C. 113//
REF/C/MSGID:DODFMR-VOL 3/CHAP 8//
NARR/REF A IS THE INITIAL STATUTE REQUIRING DOD TO MATCH PROPOSED DISBURSEMENTS WITH CORRESPONDING OBLIGATIONS BEFORE MAKING ANY PAYMENTS.  REF B, AS AMENDED, CODIFIES THE REQUIREMENT FOR DISBURSING OFFICIALS OF THE DOD TO MATCH DISBURSEMENTS TO PARTICULAR OBLIGATIONS.  THE REQUIREMENT IS REPEATED ANNUALLY IN DOD APPROPRIATIONS ACTS. REF C IS THE DOD FINANCIAL MANAGEMENT REGULATION (DODFMR) STIPULATING THAT OBLIGATIONS SHALL BE RECORDED IN THE OFFICIAL ACCOUNTING RECORDS AT THE TIME A LEGAL OBLIGATION IS INCURRED, OR AS CLOSE TO THE TIME OF INCURRENCE AS IS FEASIBLE, WHICH SHALL OCCUR NO LATER THAN 10 CALENDAR DAYS FOLLOWING THE DAY THAT AN OBLIGATION IS INCURRED.//
GENTEXT/REMARKS/1.  SITUATION.  IN 1994, DOD OFFICIALS AND CONGRESS RECOGNIZED THAT PROBLEMS EXISTED IN PROPERLY MATCHING DISBURSEMENTS WITH CORRESPONDING OBLIGATIONS.  AS A RESULT, PREVALIDATION OF PAYMENTS WAS ENACTED INTO LAW VIA REF A.  AS PROVISIONED IN REF B, EVERY YEAR SINCE THEN, THE ANNUAL DOD APPROPRIATIONS ACT HAS INCLUDED THE PREVALIDATION REQUIREMENT.  AT THE END OF AUG 2009, THE MARINE CORPS HAD APPROXIMATELY 20,000 TRANSACTIONS TOTALING 213 MILLION IN PROBLEM DISBURSEMENTS.  THE MOST SIGNIFICANT PORTION OF OUR DFAS BILL IS ATTRIBUTED TO RE-WORK COSTS ASSOCIATED WITH RESOLVING PROBLEM DISBURSEMENTS.  PROPER PREVALIDATION OF PAYMENTS ELIMINATES PROBLEM DISBURSEMENTS, REDUCES THE RISK THAT FRAUDULENT OR ERRONEOUS PAYMENTS MAY OCCUR WITHOUT DETECTION, VALIDATES THAT CUMULATIVE AMOUNTS OF DISBURSEMENTS MAY NOT EXCEED APPROPRIATED AMOUNTS AND OTHER LEGAL LIMITS, REDUCES THE DFAS BILL, STRENGTHENS INTERNAL CONTROLS OVER FINANCIAL REPORTING AND ENSURES THAT ACCURATE AND TIMELY FINANCIAL INFORMATION IS PRODUCED TO ENHANCE BETTER DECISION MAKING BY MARINE CORPS LEADERS.  WHILE REF B STIPULATES THAT THE PREVALIDATION REQUIREMENT APPLIES TO PAYMENTS EXCEEDING 500,000, DOD ACTIVITIES HAVE APPLIED MORE STRINGENT STANDARDS BY LOWERING THIS THRESHOLD TO ZERO.  WHAT REF B DOES NOT STIPULATE IS AN EXEMPTION TO THE PREVALIDATION REQUIREMENT.  PREVALIDATION IS THE MOST SIGNIFICANT POSITIVE CONTROL THAT THE MARINE CORPS CAN TAKE TO PREVENT THE LONG-STANDING CHALLENGES AND COSTLY PROCESS ASSOCIATED WITH PROBLEM DISBURSEMENTS AND ULTIMATELY INCREASE THE INTEGRITY OF FINANCIAL INFORMATION AVAILABLE TO COMMANDERS AND WARFIGHTERS.  AS THE PREVALIDATION PROCESS MAY DELAY PAYMENTS, OUR CHALLENGE AS MARINE CORPS LEADERS IS TO MINIMIZE THE FINANCIAL IMPACT TO MARINES, CIVILIANS AND VENDORS AWAITING THEIR PAYMENT.
2.  MISSION.  TO PUBLISH A REQUIREMENT TO PREVALIDATE ALL DISBURSEMENTS CHARGEABLE TO MARINE CORPS CONTROLLED APROPRIATIONS IN ORDER TO ENSURE THE ADEQUACY OF AVAILABLE FUNDS AND THE VALIDITY, ACCURACY AND TIMELINESS OF ALL PAYMENTS.
3.  EXECUTION.
3.A.  COMMANDERS INTENT.  USMC FINANCIAL MANAGERS WILL IMMEDIATELY IMPLEMENT AND MAINTAIN USMC ENTERPRISE-WIDE PREVALIDATION PROCEDURES FOR ALL DISBURSEMENTS TO ENSURE SOUND MANAGEMENT OF FINANCIAL RESOURCES AND COMPLIANCE WITH CONGRESSIONAL DIRECTION.  APPROPRIATE INTERNAL CONTROLS SHALL BE ESTABLISHED TO MITIGATE RISK WHEN OPERATING CONSTRAINTS, SUCH AS CONNECTIVITY LIMITATIONS DURING DEPLOYED OPERATIONS, PRECLUDE ACCESS TO SABRS AND RELATED FINANCIAL TOOLS.  THE PREVALIDATION REQUIREMENTS IDENTIFIED IN THE MESSAGE APPLY TO DEPLOYED FINANCIAL OPERATIONS.
3.B.  CONCEPT OF OPERATION.
3.B.1.  PREVALIDATION OF DISBURSEMENTS IS ESSENTIAL TO ENSURE COMPLIANCE WITH TWO STANDARDS:
3.B.1.A.  THE STANDARD DOCUMENT NUMBER (SDN) CITED ON THE PENDING DISBURSEMENT DOCUMENT MUST MATCH THE OBLIGATION SDN POSTED IN THE STANDARD ACCOUNTING AND BUDGET REPORTING SYSTEM (SABRS).  FOR CONTRACT PAYMENTS, THE CONTRACT NUMBER SHALL BE INCLUDED IN THE MATCHING CRITERIA.  THE LINE OF ACCOUNTING (FISCAL YEAR, DEPARTMENT CODE, BASIC SYMBOL, SUBHEAD, BUREAU CONTROL NUMBER AND AUTHORIZED ACCOUNTING ACTIVITY) CITED ON THE DISBURSEMENT DOCUMENT ALSO MUST MATCH THE LINE OF ACCOUNTING CITED IN SABRS.
3.B.1.B.  THE AMOUNT OF THE UNLIQUIDATED OBLIGATION RECORDED IN SABRS BY SDN AND CONTRACT NUMBER, IF APPLICABLE, MUST BE SUFFICIENT TO SUPPORT THE AMOUNT DISBURSED BY SDN.
3.C.  SCHEME OF MANEUVER.
3.C.1.  DELAYS IN PREVALIDATION OF TRANSACTIONS MAY RESULT IN INCREASED INTEREST CHARGES TO THE MARINE CORPS FOR LATE PAYMENTS.  COMMANDERS' OPERATING BUDGETS WILL BE SUBJECT TO REDUCTIONS TO OFFSET INTEREST CHARGES INCURRED AS A RESULT OF PREVALIDATION DELAYS.
3.C.2.  FAILURE TO PROPERLY RECORD OBLIGATIONS IN A TIMELY MANNER.  THE OPERATING BUDGETS OF COMMANDERS WHOSE ORGANIZATIONS ARE RESPONSIBLE FOR PROPERLY RECORDING OBLIGATIONS IN A TIMELY MANNER SHALL BE SUBJECT TO BUDGET REDUCTIONS IF ACTIONS ATTRIBUTED TO FUND MANAGERS CAUSE PREVALIDATION DELAYS OR PROBLEM DISBURSEMENTS.
3.C.3.  FAILURE TO PROPERLY PROCESS DISBURSEMENTS ACCURATELY.  THE OPERATING BUDGETS OF COMMANDERS WITH COGNIZANCE OVER DISBURSING AND FINANCE OFFICES SHALL ALSO BE SUBJECT TO BUDGET REDUCTIONS IF ACTIONS ATTRIBUTED TO THE DISBURSING AND FINANCE OFFICE CAUSE PREVALIDATION DELAYS OR PROBLEM DISBURSEMENTS RESULT DUE TO IMPROPER PREVALIDATION.
3.D. TASKS.
3.D.1.  COMPTROLLERS.
3.D.1.A.  ENSURE THAT OBLIGATIONS ARE CORRECTLY POSTED TO SABRS IN A TIMELY MANNER IAW REF C.
3.D.1.B.  ENFORCE DAILY VALIDATION OF UNMATCHED DISBURSMENTS (UMD'S) TO ADDRESS PROBLEM DISBURSEMENTS CAUSED BY IMPROPER RECORDING OF OBLIGATIONS IN SABRS OR PRICING ADJUSTMENTS THAT REQUIRE REVISION OF THE OBLIGATIONS RECORDED IN SABRS.
3.D.1.C.  CONTACT THE SERVICING DISBURSING/FINANCE OFFICE IMMEDIATELY TO IDENTIFY ALL UMD'S RESULTING FROM IMPROPER PROCESSING OF DISBURSEMENTS (I.E., FAILURE TO CORRECTLY CITE ACCOUNTING AND CONTRACT DATA, AS APPROPRIATE).  IDENTIFY ERRORS FOR CORRECTION AND DOCUMENT TRENDS TO ENABLE IMMEDIATE INITIATION OF APPROPRIATE REMEDIAL ACTIONS.
3.D.1.D.  ADJUST TRANSACTIONS IN SABRS, AS APPROPRIATE, TO CORRECT OBLIGATION AMOUNTS NLT 2 BUSINESS DAYS AFTER IDENTIFICATION OF UMD'S.
3.D.1.E. ESTABLISH AND MAINTAIN AN UPDATED POINT OF CONTACT LIST THAT IDENTIFIES PERSONNEL RESPONSIBLE FOR PROCESSING PREVALIDATION FAILURES.  POST THE PREVALIDATION CONTACT LIST TO AN ORGANIZATIONAL MAILBOX AND VALIDATE THE ACCURACY OF THE CONTACT LIST MONTHLY TO ENSURE IT REFLECTS CURRENT E-MAIL ADDRESSES AND PHONE NUMBERS.  PROVIDE THIS LIST TO YOUR SERVICING DISBURSING/FINANCE OFFICE EACH MONTH.
3.D.2.  DISBURSING AND FINANCE OFFICERS.
3.D.2.A.  VERIFY THE ACCURACY AND COMPLETENESS OF ACCOUNTING DATA AND CONTRACTING DATA PRIOR TO PROCESSING PAYMENTS.
3.D.2.B.  VERIFY THE SUFFICIENCY OF UNOBLIGATED FUNDS PRIOR TO PROCESSING VENDOR PAYMENTS. DISBURSING/FINANCE OFFICES WILL REQUIRE A SABRS SCREEN SHOT SHOWING THE OBLIGATION AND ASSOCIATED LOA/SDN PRIOR TO DISBURSING FUNDS.  THERE IS NO REQUIREMENT TO PREVALIDATE THE SUFFICIENCY OF FUNDS FOR MILITARY PAYROLLS AND TRAVEL VOUCHERS.
3.D.2.C.  NLT 31 JAN 2010, DEVELOP AND PRODUCE A DAILY PREVALIDATION FAILURE REPORT THAT IDENTIFIES PROBLEM TRANSACTIONS AND ASSOCIATED ACCOUNTING DATA ELEMENTS AS WELL AS THE RESPONSIBLE COMMAND.
TRANSMIT THIS REPORT TO FUND HOLDERS ON A DAILY BASIS.
3.D.2.D.  ESTABLISH AND MAINTAIN AN UPDATED POINT OF CONTACT LIST THAT IDENTIFIES PERSONNEL RESPONSIBLE FOR PROCESSING PREVALIDATION FAILURES.  POST THE PREVALIDATION CONTACT LIST TO AN ORGANIZATIONAL MAILBOX AND VALIDATE THE ACCURACY OF THE CONTACT LIST MONTHLY TO ENSURE IT REFLECTS CURRENT E-MAIL ADDRESSES AND PHONE NUMBERS.  PROVIDE THIS LIST TO ALL OF YOUR CORRESPONDING FUND HOLDERS EACH MONTH.
3.D.3.  TRANSPORTATION MANAGEMENT OFFICES.
3.D.3.A.  IMPLEMENT EFFECTIVE INTERNAL CONTROLS TO ENSURE THAT MARINE CORPS PAYMENTS ARE ISOLATED FROM PAYMENTS TO NON-MARINE CORPS ENTITIES.  DOING SO WILL PREVENT PAYMENT DELAYS DUE TO LENGTHY COORDINATION REQUIRED WITH OTHER ACCOUNTING OFFICES SUPPORTING NON-MARINE CORPS LINES OF ACCOUNTING.
3.D.3.B.  NLT 1 MAR 2010, THE TRANSPORTATION MANAGEMENT SYSTEM (TMS) ENTITLEMENT OFFICE SHALL INITIATE DAILY PREVALIDATION OF ALL PAYMENTS.
3.D.4.  HQMC-RFA.
3.D.4.A.  COORDINATE WITH MANAGERS OF AUTOMATED INFORMATION SYSTEMS THAT PROCESS MARINE CORPS PAYMENTS TO ENSURE TIMELY AND ACCURATE INTERFACE OF SABRS OBLIGATION DATA.
3.D.4.B.  COORDINATE WITH DFAS TO ENSURE THAT PREVALIDATION OF ALL OTHER DISBURSEMENT-RELATED TRANSACTIONS BEGINS NLT 1 FEB 2010.  SUCH TRANSACTIONS INCLUDE BUT ARE NOT LIMITED TO INTRAGOVERNMENTAL PAYMENTS, ACCOUNTING ADJUSTMENTS, MILITARY AND CIVILIAN PAY DISBURSEMENTS, AND ANY OTHER PAYMENTS TO A GOVERNMENT OR NON-GOVERNMENT ENTITY.
3.D.4.C.  IN CONJUNCTION WITH HQMC-RFF AND NLT 1 FEB 2010, PROVIDE DRAFT PERFORMANCE METRICS TO USE TO EVALUATE EFFECTIVENESS AND DETERMINE THE BASIS UPON WHICH A COMMAND'S OPERATING BUDGET MAY BE REDUCED IAW PARA 3.C. OF THIS MSG.
3.D.5.  HQMC-RFF.
3.D.5.A.  IN CONJUNCTION WITH HQMC-RFA AND NLT 1 FEB 2010, DEVELOP AND PUBLISH PERFORMANCE METRICS UPON WHICH A COMMAND'S OPERATING BUDGET MAY BE REDUCED IAW PARA 3.C. OF THIS MSG.
3.D.5.B.  PUBLISH DETAILED PROCEDURES TO SATISFY THE PREVALIDATION REQUIREMENT AT MARINE CORPS DISBURSING AND FINANCE OFFICES NLT 15 JAN 2010.
4.  COMMAND AND SIGNAL. THIS MESSAGE APPLIES TO ALL MARINE CORPS DISBURSING AND FINANCE OFFICES, AND ALL COMMANDS EXECUTING MARINE CORPS GENERAL FUNDS OR WORKING CAPITAL FUNDS PROCESSED IN SABRS.  IN ADDITION, THE PROVISIONS OUTLINED IN THIS MSG APPLY TO ALL APPROPRIATIONS PASSED TO THE MARINE CORPS AND ACCOUNTED FOR IN SABRS.  THIS IS A COORDINATED P AND R (RF/RP), I AND L (LP), AND MARCORLOGCOM MESSAGE.
5. RELEASE AUTHORIZED BY (SES) CARAL SPANGLER, ASST. DEPUTY COMMANDANT, PROGRAMS AND RESOURCES DEPARTMENT, FISCAL DIVISION//