B-61937, AUG 6, 1974, 54 COMP GEN 92

B-61937, AUG 6, 1974, 54 COMP GEN 92

MILITARY PERSONNEL - DEPENDENTS - CERTIFICATES OF DEPENDENCY - FILING REQUIREMENTS IN VIEW OF PROPOSED JOINT UNIFORM MILITARY PAY SYSTEM - ARMY PROCEDURES FOR RECERTIFYING AND VERIFYING DEPENDENCY FOR PAYMENT OF BASIC ALLOWANCE FOR QUARTERS, THE ANNUAL RECERTIFICATION OF DEPENDENCY CERTIFICATES PRESCRIBED BY 51 COMP. GEN. 231, AS THEY RELATE TO ARMY MEMBERS' PRIMARY DEPENDENTS, NO LONGER WILL BE REQUIRED.

IN THE MATTER OF RECERTIFICATION OF DEPENDENCY CERTIFICATES, AUGUST 6, 1974:

THIS ACTION IS IN RESPONSE TO LETTER DATED JANUARY 9, 1974, FROM THE ASSISTANT SECRETARY OF DEFENSE, COMPTROLLER, REQUESTING THE RECONSIDERATION OF DECISION 51 COMP. GEN. 231 (1971), SO AS TO AUTHORIZE THE DISCONTINUANCE OF THE REQUIREMENT FOR ANNUAL RECERTIFICATION OF DEPENDENCY CERTIFICATES BY ARMY MEMBERS RECEIVING BASIC ALLOWANCE FOR QUARTERS WITH DEPENDENTS. THE REQUEST WAS ASSIGNED DEPARTMENT OF DEFENSE MILITARY PAY AND ALLOWANCE COMMITTEE ACTION NO. 499, A COPY OF WHICH WAS ENCLOSED WITH THE ASSISTANT SECRETARY'S LETTER.

THE DISCUSSION INCLUDED IN THE COMMITTEE ACTION INDICATES THAT IN THE ABOVE-CITED DECISION IT WAS HELD THAT ANNUAL RECERTIFICATION SHOULD BE CONTINUED BECAUSE IT PROVIDES SOME ASSURANCE THAT CHANGES IN DEPENDENCY WHICH HAVE BEEN OVERLOOKED, OR ARE UNREPORTED FOR OTHER REASONS, WILL NOT GO UNDETECTED INDEFINITELY. THE COMMITTEE ACTION DISCUSSION INDICATES THAT NOW UNDER THE JOINT UNIFORM MILITARY PAY SYSTEM - ARMY, THIS ASSURANCE IS AVAILABLE WITHOUT THE NECESSITY OF ANNUAL RECERTIFICATION OF DEPENDENCY CERTIFICATES. AND, IT IS INDICATED THAT THE DISCONTINUANCE OF THE REQUIREMENT FOR ANNUAL RECERTIFICATION OF DEPENDENCY CERTIFICATES FOR ARMY MEMBERS WOULD RESULT IN SUBSTANTIAL COST SAVINGS.

UNDER THE PROPOSED SYSTEM RECERTIFICATION WOULD BE REQUIRED DURING IN PROCESSING PROCEDURES EACH TIME AN ARMY MEMBER ARRIVES AT A NEW PERMANENT DUTY STATION, RATHER THAN ANNUALLY. THE COMMITTEE ACTION INDICATES THAT THIS PROCEDURE WOULD PROVIDE A RECERTIFICATION APPROXIMATELY EVERY 18 TO 24 MONTHS, WHICH IS THE AVERAGE LENGTH OF CURRENT TOURS OF DUTY. ADDITION, THE SYSTEM INCLUDES A "SHRED-OUT" PROGRAM WHEREBY A COMPUTER- GENERATED LISTING OF ALL MEMBERS RECEIVING BASIC ALLOWANCE FOR QUARTERS IS PREPARED BY THE ARMY FINANCE SUPPORT AGENCY AND SENT TO EACH MILITARY INSTALLATION FOR PERIODIC VERIFICATION OF ENTITLEMENT.

IT APPEARS THAT THIS PROPOSAL APPLIES TO PRIMARY DEPENDENTS (I.E., SPOUSE AND UNMARRIED MINOR CHILDREN) AND DOES NOT APPLY TO SECONDARY DEPENDENTS (I.E., PARENTS) AS THE "SHRED-OUT" PROGRAM APPARENTLY DOES NOT INCLUDE VERIFICATION OF SECONDARY DEPENDENTS.

IN 51 COMP. GEN. 231, SUPRA, IT WAS STATED THAT THE IMPORTANCE OF THESE CERTIFICATIONS LIES IN THE SUPPORT THEY PROVIDE FOR THE CREDIT CLAIMED BY DISBURSING OFFICERS FOR DEPENDENCY PAYMENTS MADE DURING THE PERIODS INVOLVED AND, IT WAS INDICATED THAT THIS SUPPORT COVERS THE CONTINUED EXISTENCE OF THE DEPENDENT AND THE DEPENDENCY STATUS. CONSEQUENTLY, IT WAS HELD THAT RECERTIFICATIONS ARE IMPORTANT TO THE PROPER AUDIT OF DISBURSING OFFICERS' ACCOUNTS. SEE ALSO 32 COMP. GEN. 232 (1952) AND 38 ID. 369 (1958).

IT APPEARS THAT THE PROPOSED ARMY SYSTEM TO REQUIRE RECERTIFICATION EACH TIME THE MEMBER MAKES A PERMANENT CHANGE OF STATION IN CONJUNCTION WITH USING THE "SHRED-OUT" PROGRAM TO VERIFY ENTITLEMENTS WOULD PROVIDE REASONABLE ASSURANCE THAT CHANGES IN STATUS DO NOT GO UNDETECTED.

ACCORDINGLY, WE HAVE NO OBJECTION TO A MODIFICATION OF THE REQUIREMENTS STATED IN 51 COMP. GEN. 231, SUPRA, AS THEY RELATE TO RECERTIFICATION OF THE ARMY MEMBERS' PRIMARY DEPENDENTS ONLY, UNDER THE SYSTEM OUTLINED IN COMMITTEE ACTION NO. 499.