Propriety of U.S. Fish and Wildlife Service Procedures for Recording and Reporting Obligations Against Fiscal Year 1983 Resources Management Appropriations Account

GAO's Accounting Systems Audit Group sought clarification from General Counsel on a number of issues raised as a result of a review of the accounting practices followed by the Fish and Wildlife Service (FWS) Finance Center when recording and reporting obligations against the fiscal year 1983 Resources Management appropriation account.

The Comptroller General found that: (1) the Department of the Interior's Office on Inspector General's premise was not sufficient to determine that the Anti-Deficiency Act had been violated; (2) there was nothing in FWS Standards indicating that the FWC considered failure to remain within the authorized suballotment of obligations to be a reportable violation; (3) responsibility should rest with a person who has some actual control over actions which may result in reporting deficiencies; (4) for a person to be held criminally liable for violating the Anti-Deficiency Act, he or she must be found to have knowingly and willfully made or authorized an expenditure or obligation exceeding the amount available in an appropriation or fund, an apportionment, or an administrative allotment; (5) attempts to deobligate funds in potential anti-deficiency situations in order to avoid violations are encouraged; (6) it is within an agency's discretion to determine the appropriate administrative discipline for the employee who made or authorized an overobligation; and (7) a reconciliation period can not go on indefinitely, but a specific time limit can not be determined.