[Request for Advance Decision Regarding Payment for Training Course]

An advance decision was requested concerning the payment for a training course on labor relations which was conducted at an Army Reserve component's personnel and administrative center. A finance and accounting officer has denied payment to the contractor because the course was approved and requested by the civilian personnel officer at the center rather than by a contracting officer. The civilian personnel officer did not submit the matter to the contracting officer for consideration under regular contracting procedures because he believed that the approval of such training constituted an exception to the procurement process. GAO agreed with the belief of the finance and accounting officer that the course failed to meet the criteria for the exception because it was not regularly scheduled and open to the public. Therefore, regular procurement procedures should have been followed. Although no formally executed contract existed between the Army and the contractor, GAO held that, if payment for the training course is recommended by an authorized contracting official, payment on a quantum meruit basis may be allowed, if otherwise proper.