A-44014, FEB. 20, 1970

A-44014: Feb 20, 1970

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RETENTION AT OVERSEAS SITES DECISION TO SECRETARY OF STATE CONCERNING RETENTION OF VOUCHERS AND CONTRACTS AT SITES WHERE THE STATE DEPARTMENT DISBURSING FUNCTION IS PERFORMED. IF PROCEDURES AND STAFFING CAPABILITY AT OVERSEAS POSTS CAN BE WORKED OUT THEN APPROVAL FOR THE RETENTION OF VOUCHERS AND CONTRACTS AT THE LOCATION OF THE DISBURSING FUNCTION WILL BE APPROVED. SECRETARY: FURTHER REFERENCE IS MADE TO THE LETTER OF DECEMBER 12. THE LETTER POINTS OUT THAT RECENT DEVELOPMENTS AS OUTLINED THEREIN NECESSITATE THE PROPOSED CHANGE IN PROCEDURE AND PROVIDES ASSURANCES THAT UPON REQUEST RECORDS WILL BE MADE AVAILABLE PROMPTLY TO THE GENERAL ACCOUNTING OFFICE IN WASHINGTON TO FACILITATE OUR CONTINUING REVIEW.

A-44014, FEB. 20, 1970

MISCELLANEOUS--VOUCHERS--RETENTION AT OVERSEAS SITES DECISION TO SECRETARY OF STATE CONCERNING RETENTION OF VOUCHERS AND CONTRACTS AT SITES WHERE THE STATE DEPARTMENT DISBURSING FUNCTION IS PERFORMED. IF PROCEDURES AND STAFFING CAPABILITY AT OVERSEAS POSTS CAN BE WORKED OUT THEN APPROVAL FOR THE RETENTION OF VOUCHERS AND CONTRACTS AT THE LOCATION OF THE DISBURSING FUNCTION WILL BE APPROVED.

TO MR. SECRETARY:

FURTHER REFERENCE IS MADE TO THE LETTER OF DECEMBER 12, 1969, FROM THE ASSISTANT SECRETARY FOR ADMINISTRATION, REQUESTING RECISION OF THE PORTION OF PARAGRAPH FOUR OF OUR LETTER OF APRIL 30, 1951, A-44014, PERTAINING TO ACCOUNTS OF THE FOREIGN SERVICE, AND APPROVAL OF THE PROVISIONS OF A PROPOSED CIRCULAR AIRGRAM INSTRUCTING UNITED STATES DISBURSING OFFICERS TO RETAIN THE ORIGINAL DOCUMENTATION OF THEIR ACCOUNTS AT THE POST.

THE LETTER POINTS OUT THAT RECENT DEVELOPMENTS AS OUTLINED THEREIN NECESSITATE THE PROPOSED CHANGE IN PROCEDURE AND PROVIDES ASSURANCES THAT UPON REQUEST RECORDS WILL BE MADE AVAILABLE PROMPTLY TO THE GENERAL ACCOUNTING OFFICE IN WASHINGTON TO FACILITATE OUR CONTINUING REVIEW.

UNDER THE REVISED PROCEDURE WE UNDERSTAND THAT VOUCHERS AND CONTRACTS WILL BE RETAINED AT THE LOCATION WHERE THE DISBURSING FUNCTION IS PERFORMED AND THAT THE REVISED PROCEDURE WILL PERMIT THE DEPARTMENT OF STATE'S INTERNAL AUDIT STAFF TO REFER TO THE ORIGINAL DOCUMENTATION IN MAKING AN EXAMINATION AT THE DISBURSING LOCATION. AT THOSE POSTS THAT ARE SERVICED BY REGIONAL FINANCE CENTERS, THE INTERNAL AUDIT STAFF WILL CONTINUE TO EXAMINE COPIES OF VOUCHERS WHICH IN SOME INSTANCES MAY NOT BE SUPPORTED BY COMPLETE DATA RELATING TO THE DISBURSEMENT; HOWEVER, THE AUDITOR MAY UPON REQUEST OR BY VISITING THE FINANCE CENTER OBTAIN THE ORIGINAL VOUCHER WITH SUPPORTING DOCUMENTATION.

ALSO, THE LETTER STATES THAT RETENTION OF ORIGINAL DOCUMENTATION AT THE POST WILL ENABLE THE DEPARTMENT TO PROVIDE FOR ADEQUATE ADMINISTRATIVE AUDIT AT EACH POST. IN THIS CONNECTION, CURRENT INSTRUCTIONS OF THE DEPARTMENT PROVIDE THAT THE POST MAKE AN ADMINISTRATIVE EXAMINATION AND APPROVAL OF THE SF-1221, STATEMENT OF TRANSACTIONS, CONSISTING PRIMARILY OF AN ADMINISTRATIVE REVIEW TO ENSURE THAT THE STATEMENT IS PROPERLY PREPARED AND IS ACCOMPANIED BY THE APPROPRIATE SUPPORTING DOCUMENTS. PROVISION IS MADE IN THE REVISED PROCEDURE FOR ADMINISTRATIVE AUDIT OF THE SUPPORTING DOCUMENTS SUBSEQUENT TO PAYMENT. BECAUSE OF THE WIDE DIVERSITY OF PERSONNEL ASSIGNED TO PREPARE AND PROCESS VOUCHERS AND THE POSSIBLE MISINTERPRETATION THAT MAY BE GIVEN TO REGULATIONS BY SUCH PERSONNEL, WE BELIEVE THERE IS A NEED FOR THE DEPARTMENT TO PROVIDE INSTRUCTIONS AND PROCEDURES FOR THE SYSTEMATIC EXAMINATION OF DISBURSEMENT AND COLLECTION TRANSACTIONS TO VERIFY THEIR LEGALITY, PROPRIETY, AND CORRECTNESS AT THE POINT IN TIME WHEN ANY NEEDED PREVENTIVE OR CORRECTIVE ACTION CAN BE EFFECTIVELY TAKEN.

CONSIDERABLE PREPARATORY WORK REMAINS TO BE DONE IN THE DEPARTMENT AND IN THE OVERSEAS POSTS BEFORE THE PROPOSED CHANGE MAY BE IMPLEMENTED. FURTHER CAPABILITY MUST BE GENERATED, FIELD PROCEDURES BE WORKED OUT, AND THE REQUIRED MANPOWER BE AVAILABLE IN THE POSTS IN ORDER TO APPLY SUCH ADMINISTRATIVE AUDIT AT THE APPLICABLE POSTS. WE UNDERSTAND THAT THE PROPOSED CYCLE OF INTERNAL AUDIT IS YET TO BE IMPLEMENTED. THESE SHOULD BE ACCOMPLISHED, AND THERE SHOULD BE A REASONABLE AVAILABILITY OF STAFF CAPABILITY AND PROCEDURES FOR SUCH AUDITS IN BEING AT THE POSTS BEFORE THE REQUESTS IN THE LETTER OF DECEMBER 12, 1969, MAY BE APPROVED. IN SOME CASES SUCH STAFF AVAILABILITY MAY BE HIGHLY DIFFICULT IF NOT IMPOSSIBLE TO REALIZE IN THE LIGHT OF CONTEMPLATED REDUCTIONS IN OVERSEAS POSTS WHICH WE UNDERSTAND ARE NOW IN PROCESS.

WE SUGGEST THAT THE DEPARTMENT TAKE THE FURTHER ACTION NEEDED TO ASSURE THAT THE PROCEDURES AND STAFFING CAPABILITY ARE IN BEING AT THE POSTS CONCERNED, AND ADVISE US WHEN IT HAS BEEN ACCOMPLISHED. AT THAT TIME WE WILL APPROVE THE RETENTION ARRANGEMENT. HAVING AN EFFECTIVE DATE COINCIDE WITH THE END OF THE FISCAL YEAR WOULD HAVE SOME ADVANTAGES. ACCORDINGLY, WE SUGGEST THAT THE PREPARATORY WORK BE DONE NOW IN ANTICIPATION OF HAVING THE CHANGE MADE EFFECTIVE JULY 1, 1970.