[Query Concerning Advance Payment for Interlaboratory Comparison Survey Program]

An Army finance and accounting officer requested a decision to resolve an internal staff dispute concerning whether the Army can properly pay in advance for subscriptions to the college Interlaboratory Comparison survey program to satisfy quality control and accreditation requirements. The program provides subscribers with printed evaluations based upon participant input and survey kits that can be used to perform tests to obtain input data. The issue in question is whether the inclusion of the laboratory kits taints the evaluation reports so as to preclude advance payment under 31 U.S.C. 3324(d)(2). GAO determined that: (1) the kits appear to be nothing more than data-gathering instruments and, thus, are a part of the publication process; and (2) analysis of data obtained by use of the survey kits is a prerequisite to publication of the results of the analysis. Accordingly, GAO concluded that subscriptions to the reports may be paid in advance pursuant to 31 U.S.C. 3324(d)(2).