A-51215, DECEMBER 22, 1933, 13 COMP. GEN. 176

A-51215: Dec 22, 1933

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ACCOUNTING - EMERGENCY FUNDS ALLOTTED TO REGULAR GOVERNMENT AGENCIES WHERE EMERGENCY FUNDS ARE ALLOTTED FOR EXPENDITURE BY REGULAR ACTIVITIES OF THE GOVERNMENT THAT ARE EXPENDING REGULAR APPROPRIATIONS AND POSSIBLY AT THE SAME PLACE AND FOR THE SAME OR SIMILAR OBJECTS. A PROPER SHOWING SHOULD BE MADE AS TO EACH ITEM OF EXPENDITURE CHARGED TO EMERGENCY FUNDS TO ENABLE A DETERMINATION THAT THE OBLIGATIONS DISCHARGED WERE IN FACT INCURRED INCIDENT TO CARRYING OUT THE PURPOSE OR PURPOSES FOR WHICH THE FUNDS WERE MADE AVAILABLE. OF YOUR DEPARTMENT AS FOLLOWS: I HAVE DEFERRED ACKNOWLEDGEMENT OF YOUR LETTER OF NOVEMBER 21. I HAVE RECEIVED SUCH REPORT AND FIND MYSELF IN ENTIRE AGREEMENT WITH THE VIEW EXPRESSED THAT YOUR OFFICE BE URGED TO RECONSIDER THE INSTRUCTIONS.

A-51215, DECEMBER 22, 1933, 13 COMP. GEN. 176

ACCOUNTING - EMERGENCY FUNDS ALLOTTED TO REGULAR GOVERNMENT AGENCIES WHERE EMERGENCY FUNDS ARE ALLOTTED FOR EXPENDITURE BY REGULAR ACTIVITIES OF THE GOVERNMENT THAT ARE EXPENDING REGULAR APPROPRIATIONS AND POSSIBLY AT THE SAME PLACE AND FOR THE SAME OR SIMILAR OBJECTS, A PROPER SHOWING SHOULD BE MADE AS TO EACH ITEM OF EXPENDITURE CHARGED TO EMERGENCY FUNDS TO ENABLE A DETERMINATION THAT THE OBLIGATIONS DISCHARGED WERE IN FACT INCURRED INCIDENT TO CARRYING OUT THE PURPOSE OR PURPOSES FOR WHICH THE FUNDS WERE MADE AVAILABLE.

COMPTROLLER GENERAL MCCARL TO THE SECRETARY OF AGRICULTURE, DECEMBER 22, 1933:

THERE HAS BEEN RECEIVED A LETTER DATED DECEMBER 5, 1933, FROM THE DIRECTOR, OFFICE OF PERSONNEL AND BUSINESS ADMINISTRATION, OF YOUR DEPARTMENT AS FOLLOWS:

I HAVE DEFERRED ACKNOWLEDGEMENT OF YOUR LETTER OF NOVEMBER 21, A HLJ-114, PENDING ITS SUBMISSION TO THE FOREST SERVICE FOR CONSIDERATION AND REPORT. I HAVE RECEIVED SUCH REPORT AND FIND MYSELF IN ENTIRE AGREEMENT WITH THE VIEW EXPRESSED THAT YOUR OFFICE BE URGED TO RECONSIDER THE INSTRUCTIONS.

WHAT IS ASKED IS THAT ON ALL VOUCHERS FOR PAYMENT FROM THE EMERGENCY CONSTRUCTION FUND THERE BE "AN ADMINISTRATIVE STATEMENT OR CERTIFICATE, BY AN OFFICER ACQUAINTED WITH THE FACTS, TO THE EFFECT THAT THE EXPENSE WAS INCURRED IN CONNECTION WITH CONSERVATION WORK.' A LITTLE BEFORE YOUR LETTER MENTIONS, APPARENTLY AS A CRITICISM, THAT "THE ONLY INDICATION IN MANY CASES THAT CONSERVATION WORK IS INVOLVED IS THE FACT THAT THE PAYMENT WAS FROM THE FUND MADE AVAILABLE FOR SUCH WORK.'

THIS IS TRUE, AND IT IS LIKEWISE TRUE THAT MILLIONS OF VOUCHERS PAID EVERY YEAR FROM THE FEDERAL APPROPRIATIONS CONTAIN NO OTHER EVIDENCE THAN THE TITLE OF THE APPROPRIATION THAT THE EXPENSES WERE INCURRED FOR PURPOSES WITHIN THE APPROPRIATION. IN THE VERY GREAT MAJORITY OF CASES THERE IS NO INTERNAL EVIDENCE. IT HAS BEEN AT ALL TIMES, SO FAR AS WE ARE ADVISED, UNIVERSALLY ACCEPTED IN FEDERAL ACCOUNTING THAT THE DESIGNATION OF APPROPRIATION ON VOUCHERS CERTIFIED BY ADMINISTRATIVE OFFICERS--- AND SUCH DESIGNATION PRECEDES CERTIFICATION FOR PAYMENT--- COMMITTED THE CERTIFYING OFFICER TO KNOWLEDGE THAT THE EXPENSE WAS BEING CHARGED TO THE INDICATED FUND; AND WITH SUCH KNOWLEDGE THE CERTIFICATION NECESSARILY MEANS THAT THE SERVICES, ARTICLES, OR SUPPLIES ARE PROCURED IN FURTHERANCE OF THE OBJECTS OF SUCH APPROPRIATION.

SINCE THIS ASSUMPTION HAS ALWAYS BEEN ACCEPTED AS TO THE THOUSANDS OF APPROPRIATIONS ANNUALLY MADE BY CONGRESS, WE FIND IT DIFFICULT TO UNDERSTAND ON WHAT THEORY AN EXCEPTION IS PROPOSED IN THIS INSTANCE. THE EMERGENCY CONSERVATION FUND SEEMS TO OFFER NO SPECIAL TEMPTATION TO MISUSE, NO SPECIAL SUSCEPTIBILITY TO ERROR IN ADMINISTRATION OR EXPENDITURE. HEAVY ALLOTMENTS OF OTHER EMERGENCY FUNDS, NOTABLY THOSE FOR GENERAL AND ROAD CONSTRUCTION, HAVE BEEN MADE TO THE DEPARTMENT FROM THE N.R.A. APPROPRIATION. THESE ARE HANDLED BY THE REGULAR BUREAU ORGANIZATIONS AND CERTIFIED BY PERMANENT ADMINISTRATIVE OFFICERS AND ARE THUS IN EVERY RESPECT ANALOGOUS TO THE EMERGENCY CONSERVATION FUND. THERE HAS, HOWEVER, BEEN NO SUGGESTION OF SPECIAL CERTIFICATION IN THESE CASES.

OUR LEAST OBJECTION TO THE PROPOSAL IS THAT THE CERTIFICATION WOULD BE PERFUNCTORY. A TEXT WOULD BE PREPARED FOR STAMPING AND THE CERTIFYING OFFICER WOULD SIGN TWICE INSTEAD OF ONCE UNLESS SOME MEANS COULD BE FOUND TO COMBINE THE NEW AND OLD CERTIFICATES. THE GREAT OBJECTION TO WHICH WE SOLICIT YOUR PARTICULAR ATTENTION IS THAT THE PROPOSAL IS AN EXCEPTION TO GENERAL PRACTICE BASED ON NO OBVIOUS REASON. WE DO NOT THINK YOU WILL WISH TO INSIST UPON A RADICAL DEPARTURE FROM STANDARD PROCEDURE WITHOUT SOME EXPLANATION OF THE INFLUENCING CONSIDERATIONS.

MAY WE NOT, THEREFORE, ASK YOU TO CAREFULLY RE-EXAMINE THE SITUATION, HAVING ESPECIALLY IN MIND THE GREAT STRAIN UNDER WHICH THE FISCAL ACCOUNTING AND ADMINISTRATIVE STAFF OF THE FOREST SERVICE ARE NOW WORKING AND THE GRAVITY OF NEW STEPS IN ROUTINE, NO MATTER HOW SLIGHT THE TIME CONSUMED IN THE INDIVIDUAL OPERATION.

ORDINARILY, THE VERY NATURE OF AN EXPENDITURE, THE PLACE WHERE THE ARTICLES ARE TO BE DELIVERED OR THE SERVICES RENDERED, AND THE OFFICIAL TITLE OF PROCURING OR CERTIFYING OFFICER AS SHOWN BY A VOUCHER WILL INDICATE WHETHER THE APPROPRIATION STATED ON THE VOUCHER IS THE PROPER APPROPRIATION TO BE CHARGED THEREWITH. BUT WHERE, AS IN THE CASE OF THESE CONSERVATION FUNDS, EMERGENCY FUNDS ARE ALLOTTED FOR EXPENDITURE BY THE SAME ADMINISTRATIVE ORGANIZATION THAT IS EXPENDING REGULAR APPROPRIATIONS AND POSSIBLY AT THE SAME PLACE AND FOR THE SAME OR SIMILAR OBJECTS, IT BECOMES NECESSARY THAT THERE BE MADE A PROPER SHOWING IN CONNECTION WITH EACH ITEM OF EXPENDITURE CHARGED TO THE EMERGENCY FUND TO ENABLE A DETERMINATION THAT THE OBLIGATION DISCHARGED WAS IN FACT INCURRED INCIDENT TO CARRYING OUT THE PURPOSE FOR WHICH THE FUNDS WERE MADE AVAILABLE.

IN THIS CONNECTION IT MAY BE STATED THAT THE SHOWING REQUIRED IS NOT A PERFUNCTORY CERTIFICATE THAT THE EXPENDITURE IS INCIDENT TO THE WORK OF THE CIVILIAN CONSERVATION CORPS AS SEEMS TO BE ASSUMED BY THE LETTER QUOTED HEREIN, BUT A STATEMENT OF FACTS SHOWING IN EACH INSTANCE THAT THE EXPENDITURES WERE IN FACT EXPENDITURES LEGALLY CHARGEABLE TO THE EMERGENCY CONSERVATION FUND. THE SAME SHOWING SHOULD BE MADE, ALSO, WITH RESPECT TO OTHER EMERGENCY FUNDS ALLOTTED TO YOUR DEPARTMENT.