A-24222, A-49009, SEP. 25, 1959

A-24222,A-49009: Sep 25, 1959

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IS IN PART AS FOLLOWS: "EFFECTIVE MARCH 11. OR PERSONS FURNISHING TRANSPORTATION AND ACCESSORIAL SERVICES TO THE GOVERNMENT MUST CONTINUE TO EXECUTE THE CERTIFICATES FOR TRANSPORTATION BILLS. "* * * OVER THE PAST TWO AND ONE-HALF YEARS THERE HAVE BEEN A NUMBER OF INSTANCES WHERE INVOICES HAVE BEEN RETURNED WITH THE REQUEST THAT THE BILLS BE CERTIFIED. IT HAS BEEN OUR CONTENTION THAT SUCH INVOICES DO NOT HAVE TO BE CERTIFIED BECAUSE WE ARE NOT FURNISHING TRANSPORTATION SERVICES TO THE GOVERNMENT AS SUCH. THE CHARGES WHICH APPEAR ON OUR BILLS ARE IN THE NATURE OF A CLAIM FOR REIMBURSEMENT OF TRANSPORTATION EXPENSE NOT INCLUDED IN THE CONTRACT PRICES. * * *.'. YOUR INTERPRETATION OF YOUR REQUIREMENTS IS CORRECT.

A-24222, A-49009, SEP. 25, 1959

TO MR. G. A. DOMSER:

YOUR LETTER OF SEPTEMBER 18, 1959, IS IN PART AS FOLLOWS:

"EFFECTIVE MARCH 11, 1957, YOUR OFFICE RESCINDED THE REQUIREMENTS ORDINARY INVOICES BE CERTIFIED AS TO CORRECTNESS, JUSTNESS AND NONPAYMENT. THIS ELIMINATION DID NOT DISPENSE WITH THE REQUIREMENTS FOR SPECIFIC CERTIFICATIONS OF FACTS, NOR DID IT DISPENSE WITH THE REQUIREMENTS THAT CARRIERS, OTHER CORPORATIONS OR AGENCIES, OR PERSONS FURNISHING TRANSPORTATION AND ACCESSORIAL SERVICES TO THE GOVERNMENT MUST CONTINUE TO EXECUTE THE CERTIFICATES FOR TRANSPORTATION BILLS.

"* * * OVER THE PAST TWO AND ONE-HALF YEARS THERE HAVE BEEN A NUMBER OF INSTANCES WHERE INVOICES HAVE BEEN RETURNED WITH THE REQUEST THAT THE BILLS BE CERTIFIED. THIS HAS HAPPENED PRIMARILY IN CASES WHERE OUR INVOICES INCLUDE AS A SEPARATE ITEM A CHARGE FOR TRANSPORTATION. IT HAS BEEN OUR CONTENTION THAT SUCH INVOICES DO NOT HAVE TO BE CERTIFIED BECAUSE WE ARE NOT FURNISHING TRANSPORTATION SERVICES TO THE GOVERNMENT AS SUCH. THE CHARGES WHICH APPEAR ON OUR BILLS ARE IN THE NATURE OF A CLAIM FOR REIMBURSEMENT OF TRANSPORTATION EXPENSE NOT INCLUDED IN THE CONTRACT PRICES. * * *.'

YOUR INTERPRETATION OF YOUR REQUIREMENTS IS CORRECT. THE CERTIFICATION REQUIREMENTS APPLY WHEN THE CARRIER RENDERS THE TRANSPORTATION SERVICE AND BILLS THE GOVERNMENT DIRECT.