Views on a Proposed Amendment to an Administrative Agreement

Under a proposed amendment to a service agreement between the General Services Administration (GSA) and the Federal Mine Safety and Health Review Commission, the Commission would assume authority for certification of its own vouchers from GSA. Currently, GSA provides the Commission with support services including audit, certification, and other processing of the Commission's expenditure vouchers. While the Commission wishes to assume certification responsibility for its vouchers, it wishes GSA to continue to provide the other services necessary to effect payment. The change would significantly alter the Commission's relationship with GSA. In a similar arrangement between GSA and another Commission,it was held that GSA officers performing administrative functions relating to final processing of expenditure vouchers would not be regarded as certifying officers for liability defined in law to the extent that the serviced Commission retains responsibility concerning basic vouchers. This principle would apply to the present situation if the proposed changes are adopted.