MARADMINS : 300/07
UNCLAS 101418Z MAY 07
CMC WASHINGTON DC(UC)
AL MARADMIN(UC)
MARADMIN
MARADMIN 300/07
MSGID/GENADMIN/CMC WASHINGTON DC PR RFA//
SUBJ/REVIEW OF INTRAGOVERNMENTAL TRANSACTIONS//
REF/A/DOD/DODFMR VOL 11A//
REF/B/MSG/MARADMIN 276-06//
REF/C/MSG/MARADMIN 409-06//
REF/D/DOD/MCO P7300.21//
REF/E/MSG/MARADMIN 025-07//
REF/F/DOC/USD(C) MEMO/31JAN2007//
REF/G/DOC/USD(C) MEMO/14OCT2003//
REF/H/DOC/USC(C) MEMO/13APR2007//
NARR/REF A IS DOD FINANCIAL MANAGEMENT REGULATION (DODMFR), VOLUME
11A. REF B IS GUIDANCE ON ISSUING REQUESTS FOR REIMBURSABLE WORK.
REF C IS GUIDANCE ON ESTIMATING SEPTEMBER REIMBURSABLE BILLINGS AND
CLOSING ACCEPTED REIMBURSABLE ORDERS. REF D IS MARINE CORPS
FINANCIAL EXECUTION STANDARD OPERATING PROCEDURE MANUAL. REF E IS
MARINE CORPS POLICY ON PROPER USE OF NON-ECONOMY ACT ORDERS. REF F
IS OUSD(C) MEMO PRESCRIBING POLICIES OF PROCURING GOODS AND SERVICES
FROM NON-DOD AGENCIES UNDER STATUTORY AUTHORITY OTHER THAN ECONOMY
ACT. REF G IS OUSD(C) MEMO IS THE IMPLEMENTATION OF THE DOD TRADING
PARTNER NUMBER (TPN) FOR INTRAGOVERNMENTAL TRANSATIONS. REF H IS
OUSD(C) MEMO ROVIDING REVISED INTRAGOVERNMENTAL TRANSACTION BUSINESS
RULES.//
GENTEXT/REMARKS/1. SITUATION. AN INTRAGOVERNMENTAL TRANSACTION IS
ANY TRANSACTION INVOLVING SALES, SERVICES OR TRANSFERS WITHIN TWO
ENTITIES OF THE FEDERAL GOVERNMENT. WHETHER DIRECT OR INDIRECT
(REIMBURSABLE), THE NATURE OF AN INTRAGOVERNMENTAL TRANSACTION
REQUIRES THAT THE INTEGRITY OF THE BUYER (PARTY REQUESTING GOODS
OR SERVICES) AND SELLER (PARTY PROVIDING THE REQUESTED GOODS OR
SERVICES) RELATIONSHIP IS ESTABLISHED, MAINTAINED, RECONCILED AND
APPROPRIATELY CLOSED WHEN THE RELATIONSHIP ENDS. GENERALLY
ACCEPTED ACCOUNTING PRINCIPLES REQUIRE THE PROPER ELIMINATION OF
INTRAGOVERNMENTAL TRANSACTIONS FROM CONSOLIDATED FINANCIAL
STATEMENTS TO PREVENT UNDERSTATING OR OVERSTATING ACCOUNTS FOR
EITHER BUYER OR SELLER ACTIVITY. SEVERAL GAO AND DODIG AUDIT
REPORTS CLASSIFY INTRAGOVERNMENTAL ELIMINATIONS THROUGHOUT THE
DOD AS A MATERIAL WEAKNESS.
2. MISSION. IN ORDER FOR THE MARINE CORPS TO COMPLY WITH
REQUIREMENTS DIRECTED IN REF H AND TO ASSERT ITS READINESS FOR A
CLEAN AUDIT OPINION IN FY08, PUBLISH SPECIFIC GUIDANCE AND TASKS
FOR REVIEWING ALL INTRAGOVERNMENTAL TRANSACTIONS.
3. EXECUTION.
3.A. COMMANDERS INTENT. EFFECTIVE IMMEDIATELY, CLOSE ALL AGED
INTRAGOVERNMENTAL TRANSACTIONS AND PROPERLY VALIDATE AND ANNOTATE
ALL OUSTANDING INTRAGOVERNMENTAL TRANSACTIONS WITH TRADING PARTNER
INFORMATION.
3.B. CONCEPT OF OPERATION. THE MARINE CORPS FINANCIAL EVALUATION
AND ANALYSIS TEAM (MCFEAT) IS TASKED WITH OVERSEEING THE TASKS
OUTLINED BELOW AND PROVIDING ASSISTANCE TO EACH COMMAND WITH AGED
OR OUTSTANDING INTRAGOVERNMENTAL TRANSACTIONS.
4. TASKS.
4.A. TASKS REQUIRED BY BUYER ACTIVITIES:
4.A.1. HQMC-RFA PRODUCE AND PUBLISH TO HQMC-RFA WEB PORTAL A
REPORT OF ALL AGED (NO LIQUIDATION GREATER THAN 180 DAYS)
MILITARY INTERDEPARTMENTAL PURCHASE REQUESTS AND WORK REQUESTS
WHERE THE MARINE CORPS IS THE BUYER.
4.A.2. BUYERS FUNDING AN ECONOMY ACT ORDER MUST RECORD ALL
APPROPRIATE ACCOUNTING TRANSACTIONS SUPPORTED BY DOCUMENTARY
EVIDENCE OF WORK PERFORMED BY THE SELLER. IF THE LIQUIDATION
EXCEEDS THE EXPENSE RECORDED IN THE ACCOUNTING SYSTEM, OBTAIN
SUPPORTING DOCUMENTATION TO RECORD EXPENSE AS EVIDENCE THAT WORK
WAS PERFORMED.
4.A.3. IAW REF A, BUYERS MUST VALIDATE THE OBLIGATION STATUS OF
ALL ECONOMY ACT ORDERS AND DEOBLIGATE UNUSED FUNDS BEFORE THE
EXPIRATION OF FUNDS AVAILABILITY. FOR SEVERABLE SERVICES ON
ORDERS WHERE FUNDS HAVE ALREADY EXPIRED, COMMANDER/COMPTROLLERS
MUST REVIEW THE PERIOD OF PERFORMANCE TO ENSURE THE PERIOD OF
PERFORMANCE DOES NOT EXCEED ONE FULL YEAR FROM THE PERFORMANCE
START DATE. ONCE THE PERFORMANCE PERIOD EXCEEDS ONE YEAR,
IMMEDIATELY DEOBLIGATE ALL ECONOMY ACT UNFILLED ORDERS. IF THE
ECONOMY ACT ORDER IS FOR NON-SEVERABLE SERVICES, VALIDATE THE
BONA-FIDE NEED OF REMAINING OBLIGATIONS IN EXPIRED
APPROPRIATIONS. IF A BONA FIDE NEED IS NOT ESTABLISHED,
DEOBLIGATE IMMEDIATELY.
4.A.4. WHERE BUYERS ENTERED INTO A NON-ECONOMY ACT ORDER PRIOR
TO GUIDANCE PUBLISHED VIA REF E, VALIDATE OBLIGATIONS ESTABLISHED
BY A BONA FIDE NEED ARISING, OR EXISTING, IN THE FISCAL YEARS OR
YEARS FOR WHICH THE APPROPRIATIONS ARE AVAILABLE FOR OBLIGATION.
4.A.5. COMMANDERS MUST DEOBLIGATE ALL UNLIQUIDATED BALANCES
MEETING THE DEOBLIGATION CRITERIA OUTLINED IN PARA D.2.,
ENCLOSURE (1) OF REF F.
4.B. TASKS REQUIRED TO ESTABLISH INTEGRITY OF TRADING PARTNER
INFORMATION:
4.B.1. REF G PRESCRIBED POLICIES TO IMPLEMENT THE DOD TRADING
PARTNER INFORMATION FOR ALL INTRAGOVERNMENTAL TRANSACTIONS. THE
GOAL IS TO IDENTIFY THE TRUE TRADING PARTNERS IN ORDER TO
FACILITATE RECONCILIATION OF INTRAGOVERNMENTAL TRANSACTIONS AND
TO PROVIDE VISIBILITY TO SELLING ORGANIZATIONS THROUGH THE
BUSINESS PARTNER NETWORK (BPN). SABRS WAS RECENTLY MODIFIED TO
ALLOW THE INDUCTION OF SELLER TRADING PARTNER INFORMATION UPON
THE OBLIGATION OF INTRAGOVERNMENTAL TRANSACTIONS. BUYER TRADING
PARTNER INFORMATION DATA IS IMBEDDED IN THE MARINE CORPS
ACCOUNTING SYSTEM (SABRS).
4.B.2. COMPLETELY RECORD SELLER TRADING PARTNER INFORMATION IN
EVERY OUSTANDING INTRAGOVERNMENTAL TRANSACTION OBLIGATED IN
SABRS.
4.B.3. HQMC-RFA TO PUBLISH A LIST OF ALL OUTSTANDING
INTRAGOVERNMENTAL TRANSACTIONS TO ANNOTATE MISSING SELLER
TRADING PARTNER INFORMATION. COMPLETE INFORMATION SHOULD INCLUDE
THE SELLERS TPN OR DUNS NUMBER, DEPARTMENT CODE, BASIC SYMBOL AND
SUBHEAD.
4.B.4. COMMANDERS/COMPTROLLERS ENGAGE SELLERS OF EVERY
OUTSTANDING INTRA-GOVERNMENTAL TRANSACTION TO OBTAIN TRADING
PARTNER INFORMATION IAW REF G.
4.B.5. COMMANDERS/COMPTROLLERS RECORD COMPLETE SELLER TRADING
PARTNER INFORMATION IN EVERY OUSTANDING INTRAGOVERNMENTAL
TRANSACTIONS RESIDENT IN SABRS. WRITE SABRSHELP@USMC.MIL TO
RESOLVE ANY OCCURENCES WHERE USERS CANNOT ADD OR MODIFY TRADING
PARTNER INFORMATION RESIDENT IN SABRS.
4.C. TO COMPLY WITH REQUIREMENTS DIRECTED IN REF H, THE TASKS
CITED ABOVE MUST BE COMPLETED NLT 30 JUNE 2007.
5. ADMINISTRATION AND LOGISTICS. THE ASSISTANT CHIEF OF STAFF,
COMPTROLLER IS RESPONSIBLE FOR ACCOMPLISHING A REVIEW OF ALL
INTRAGOVERNMENTAL TRANSACTIONS AND COMPLETING ALL BUYERS ACTIONS
ANNOTATED ABOVE. MCFEAT WILL ASSIST AND VISIT ALL APPROPRIATE
COMMANDS TO EVALUATE AND ASSESS THE INTRAGOVERNMENTAL TRANSACTIONS
SUBJECT TO THIS REVIEW.
6. COMMAND AND SIGNAL. THE POINT OF CONTACT FOR THIS REVIEW IS
MR. DAVE GARZA, DIRECTOR, MCFEAT, 816-916-1418, DSN 465,
DAVID.R.GARZA@USMC.MIL.//