B-61937, OCT 26, 1971, 51 COMP GEN 231

B-61937, OCT 26, 1971, 51 COMP GEN 231

MILITARY PERSONNEL - DEPENDENTS - CERTIFICATES OF DEPENDENCY - FILING REQUIREMENTS THE REQUIREMENTS FOR THE ANNUAL SUBMISSION OF DEPENDENCY CERTIFICATES BY MEMBERS OF THE ARMED FORCES IN PAY GRADE E-4 AND ABOVE AND THE ANNUAL RECERTIFICATION OF DEPENDENCY CERTIFICATES BY ACTIVE DUTY MEMBERS IN THOSE PAY GRADES SHOULD BE CONTINUED AS THE CERTIFICATIONS ARE IMPORTANT TO THE PROPER AUDIT OF A DISBURSING OFFICER'S ACCOUNT TO SUPPORT THE CREDIT CLAIMED FOR DEPENDENCY PAYMENTS AND TO EVIDENCE THE CONTINUED EXISTENCE OF A DEPENDENT AND THE DEPENDENCY STATUS. HOWEVER, AS METHODS AND PROCEDURES FOR RECERTIFICATION DIFFER SUBSTANTIALLY AMONG THE SERVICES, MORE UNIFORM METHODS, INCORPORATING THE BEST FEATURES OF THE PROCEDURE OF EACH SERVICE IS DESIRABLE TO ACCOMPLISH SAVINGS IN PAPERWORK, TIME, AND MANPOWER.

TO THE SECRETARY OF DEFENSE, OCTOBER 26, 1971:

FURTHER REFERENCE IS MADE TO LETTER DATED JUNE 9, 1971, FROM THE DEPUTY ASSISTANT SECRETARY OF DEFENSE (COMPTROLLER) REQUESTING DECISION AS TO WHETHER THE REQUIREMENT FOR ANNUAL SUBMISSIONS OF DEPENDENCY CERTIFICATES BY MEMBERS IN PAY GRADES F-4 (OVER 4 YEARS' SERVICE) AND ABOVE AND THE ANNUAL RECERTIFICATION OF DEPENDENCY CERTIFICATES BY ACTIVE DUTY MEMBERS OF THE ARMED FORCES IN THOSE PAY GRADES MAY BE DISCONTINUED. THE REQUEST WAS ASSIGNED DEPARTMENT OF DEFENSE MILITARY PAY AND ALLOWANCE COMMITTEE ACTION NO. 452, A COPY OF WHICH WAS ENCLOSED.

WE HAVE FOUND THAT THE METHODS OF ANNUALLY RECERTIFYING DEPENDENCY BY MEMBERS IN PAY GRADES E-4 (OVER - MEMBERS IN PAY GRADES E-4 (OVER YEARS' SERVICE) AND ABOVE VARY AMONG THE SERVICES. FOR EXAMPLE, IT APPEARS THAT IN THE AIR FORCE ANNUAL RECERTIFICATION OF PRIMARY DEPENDENTS (WIVES AND CHILDREN) IS GENERALLY ACCOMPLISHED AT THE LOCAL LEVEL AT THE TIME OF THE ANNUAL PERSONNEL RECORDS REVIEW BY THE MEMBER RECERTIFYING ON THE REVERSE OF A COPY OF DD FORM 137-1 WHICH IS RETAINED IN HIS FINANCIAL DATA FILE. SEE AFM 177-105, PAR. 6.11. ANNUAL REDETERMINATION OF PARENTAL DEPENDENCY IS ACCOMPLISHED BY THE LOCAL CONSOLIDATED BASE PERSONNEL OFFICE OR GENERAL SUPPORT UNIT COMPLETING DD FORM 137 WHICH IS SIGNED BY THE MEMBER AND FORWARDED TO THE AIR FORCE ACCOUNTING AND FINANCE CENTER, DENVER, COLORADO, WHERE THE REDETERMINATION OF PARENTAL DEPENDENCY TAKES PLACE. SEE AFM 177 105, PAR. 6-10.

IN THE ARMY ANNUAL RECERTIFICATION OF PRIMARY DEPENDENCY BY MEMBERS IN THESE PAY GRADES IS GENERALLY ACCOMPLISHED BY THE MEMBER CERTIFYING ON DA FORM 3298 WHICH IS RETAINED IN HIS FINANCIAL RECORDS FOLDER. SEE AR 37- 104-2, PAR. 2-50.1B. ANNUAL RECERTIFICATION OF PARENTAL DEPENDENCY IS ACCOMPLISHED BY COMPLETING AN ORIGINAL AND THREE COPIES OF DD FORM 137. THE ORIGINAL OF THIS FORM IS ATTACHED TO COPY 1 OF THE MEMBER'S MILITARY PAY VOUCHER WHICH IS SUBMITTED TO THE FINANCE CENTER, U.S. ARMY, INDIANAPOLIS, INDIANA. ONE COPY IS FILED IN THE MEMBER'S FINANCIAL DATA RECORDS FOLDER, ONE COPY IS FILED WITH THE FINANCE AND ACCOUNTING OFFICE'S RETAINED COPY OF THE RELATED PAYROLL, AND ONE COPY IS GIVEN TO THE MEMBER. SEE ARMY REGULATIONS 37-104-2, PAR. 2-50.1C.

THE ANNUAL RECERTIFICATION OF PRIMARY DEPENDENTS FOR NAVY MEMBERS IN PAY GRADES E-4 (OVER 4 YEARS' SERVICE) AND ABOVE AND THE RECERTIFICATION OF PRIMARY DEPENDENTS AND PARENTAL DEPENDENTS OF MARINE CORPS MEMBERS IN THESE PAY GRADES IS ACCOMPLISHED BY SUBMITTING A NAVCOMP FORM 2040 TO THE MEMBER'S DISBURSING OFFICER WHO RETAINS IT. SEE NAVY AND MARINE CORPS MILITARY PAY PROCEDURES MANUAL, PARS. 30226, 30242 AND 30245. NAVY MEMBERS WITH DEPENDENT PARENTS ANNUALLY RECERTIFY BY SUBMITTING NAVCOMP FORM 2040 IN DUPLICATE TO THEIR DISBURSING OFFICERS WHO RETAIN ONE COPY AND FORWARD THE OTHER COPY TO THE NAVY FAMILY ALLOWANCE ACTIVITY, CLEVELAND, OHIO, WHERE PARENTAL DEPENDENCY IS DETERMINED.

AS WAS POINTED OUT IN THE DISCUSSION CONTAINED IN COMMITTEE ACTION NO. 452, THE IMPORTANCE OF THESE CERTIFICATIONS LIES IN THE SUPPORT THEY PROVIDE FOR THE CREDIT CLAIMED BY THE DISBURSING OFFICERS FOR DEPENDENCY PAYMENTS MADE DURING THE PERIODS INVOLVED. CONSEQUENTLY, THEY ARE IMPORTANT TO THE PROPER AUDIT OF THE DISBURSING OFFICER'S ACCOUNTS. SEE 32 COMP. GEN. 232 (1952) AND 38 COMP. GEN. 369 (1958). THIS SUPPORT COVERS THE CONTINUED EXISTENCE OF THE DEPENDENT AND THE DEPENDENCY STATUS.

WE RECOGNIZE THAT MEMBERS GENERALLY ARE REQUIRED TO PROMPTLY REPORT ANY CHANGE THAT MAY OCCUR IN THEIR DEPENDENCY STATUS; HOWEVER THE ANNUAL REDETERMINATION OF SECONDARY DEPENDENCY AND THE ANNUAL RECERTIFICATION OF PRIMARY DEPENDENCY GIVES SOME ASSURANCE THAT CHANGES WHICH HAVE BEEN OVERLOOKED, OR ARE UNREPORTED FOR OTHER REASONS, WILL NOT GO UNDETECTED INDEFINITELY. THE IMPORTANCE OF THE ANNUAL SUBMISSION OF PARENTAL DEPENDENCY CERTIFICATES IS DEMONSTRATED BY THE FACT THAT OF THE 2,598 CASES IN WHICH SUCH CERTIFICATES WERE SUBMITTED TO THE AIR FORCE ACCOUNTING AND FINANCE CENTER IN FISCAL YEAR 1971, 551 OR 21 PERCENT WERE DISAPPROVED.

ACCORDINGLY, IT IS OUR VIEW THAT THE ANNUAL RECERTIFICATION OF DEPENDENCY SERVES AN IMPORTANT PURPOSE AND SHOULD BE CONTINUED. HOWEVER, IT APPEARS THAT THE METHODS AND PROCEDURES FOR RECERTIFICATION MAY DIFFER SUBSTANTIALLY AMONG THE SERVICES AND THAT MORE UNIFORM METHODS, INCORPORATING THE BEST FEATURES OF THE PROCEDURE OF EACH SERVICE, MIGHT ACCOMPLISH SOME OF THE DESIRED SAVINGS IN PAPERWORK, TIME AND MANPOWER MENTIONED IN COMMITTEE ACTION NO. 452.