A-54128, MARCH 24, 1934, 13 COMP. GEN. 249

A-54128: Mar 24, 1934

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ALLOTTED FUNDS - ACCOUNTING FOR EMERGENCY FUNDS ALLOTTED TO REGULAR GOVERNMENT AGENCIES SINCE EMERGENCY FUNDS ARE ALLOTTED BY THE FEDERAL EMERGENCY ADMINISTRATOR OF PUBLIC WORKS TO REGULAR GOVERNMENT AGENCIES FOR EXPENDITURE ON SPECIFIC PROJECTS. IN MOST CASES THIS INFORMATION CAN BE FURNISHED AND EVERY EFFORT WILL BE MADE TO HAVE THE PROJECT NUMBER PROPERLY INDICATED ON ALL PAPERS BEFORE THEY EVER REACH THE ACCOUNTING OFFICE. THERE ARE A FEW CASES IN WHICH DELEGATION OF ANY SPECIFIC PROJECT NUMBER IS IMPOSSIBLE. IF FOR INSTANCE AN INDIAN SERVICE ENGINEER IS TAKEN ON SOLELY TO ASSIST IN HANDLING THE ADDITIONAL WORK INCIDENT TO THE PUBLIC WORKS PROGRAM. HIS SALARY AND TRAVEL AND OTHER EXPENSES ARE PROPERLY CHARGEABLE TO THE PUBLIC WORKS FUND.

A-54128, MARCH 24, 1934, 13 COMP. GEN. 249

ALLOTTED FUNDS - ACCOUNTING FOR EMERGENCY FUNDS ALLOTTED TO REGULAR GOVERNMENT AGENCIES SINCE EMERGENCY FUNDS ARE ALLOTTED BY THE FEDERAL EMERGENCY ADMINISTRATOR OF PUBLIC WORKS TO REGULAR GOVERNMENT AGENCIES FOR EXPENDITURE ON SPECIFIC PROJECTS, THE ACCOUNTING TO THE GENERAL ACCOUNTING OFFICE SHOULD BE AS TO THE PARTICULAR PROJECT OR PROJECTS INVOLVED, EITHER ON AN ACTUAL BASIS, OR ON AN ESTIMATED PRO RATA COST DISTRIBUTION OR ALLOCATION TO EACH PROJECT.

COMPTROLLER GENERAL MCCARL TO THE SECRETARY OF THE INTERIOR, MARCH 24, 1934:

THERE HAS BEEN RECEIVED A LETTER DATED FEBRUARY 19, 1934, FROM THE ASSISTANT COMMISSIONER OF INDIAN AFFAIRS AS FOLLOWS:

MY ATTENTION HAS BEEN CALLED TO THE FACT THAT THE GENERAL ACCOUNTING OFFICE HAS BEEN RETURNING A NUMBER OF FREIGHT AND PASSENGER TRANSPORTATION BILLS PAYABLE FROM "NATIONAL INDUSTRIAL RECOVERY, INTERIOR, INDIANS, 1933- 35," WITH THE REQUEST THAT THE FEDERAL PROJECT NUMBERS BE SPECIFIED IN EACH CASE. IN MOST CASES THIS INFORMATION CAN BE FURNISHED AND EVERY EFFORT WILL BE MADE TO HAVE THE PROJECT NUMBER PROPERLY INDICATED ON ALL PAPERS BEFORE THEY EVER REACH THE ACCOUNTING OFFICE. HOWEVER, THERE ARE A FEW CASES IN WHICH DELEGATION OF ANY SPECIFIC PROJECT NUMBER IS IMPOSSIBLE.

TO DATE THE INDIAN SERVICE HAS RECEIVED ALLOTMENTS OF PUBLIC WORKS MONEY FOR SOME 416 SEPARATE PROJECTS. THE INITIATION OF THESE PROJECTS AND THE EXPENDITURE OF THE LARGE AMOUNT OF MONEY INVOLVED (ALMOST $19,000,000) OF COURSE NECESSITATES SOME ADDITIONAL TECHNICAL AND CLERICAL ASSISTANCE IN THE WASHINGTON OFFICE AND IN SOME POINTS IN THE FIELD, WITH DUTIES OF A GENERAL CHARACTER NOT SUSCEPTIBLE OF SEGREGATION AGAINST INDIVIDUAL PROJECTS. IF FOR INSTANCE AN INDIAN SERVICE ENGINEER IS TAKEN ON SOLELY TO ASSIST IN HANDLING THE ADDITIONAL WORK INCIDENT TO THE PUBLIC WORKS PROGRAM, HIS SALARY AND TRAVEL AND OTHER EXPENSES ARE PROPERLY CHARGEABLE TO THE PUBLIC WORKS FUND. THIS SAME ENGINEER MAY MAKE A TRIP THROUGH A DOZEN OR MORE STATES IN THE INTEREST OF A LARGE NUMBER OF PROJECTS BUT WE CANNOT CONCEIVE OF ANY PRACTICABLE WAY OF ATTEMPTING TO SEGREGATE HIS TRAVEL EXPENSES AND CHARGE SUCH EXPENSE IN VARYING FRACTIONS AGAINST THE DIFFERENT PROJECTS CONCERNED.

LIKEWISE WE HAVE FOUND IT NECESSARY TO PURCHASE A FEW ADDING MACHINES, TYPEWRITERS AND OTHER OFFICE EQUIPMENT FOR FIELD WORK IN CONNECTION WITH PUBLIC WORKS PROJECTS, BUT CANNOT SEE HOW WE COULD ATTEMPT TO SEPARATE THE COST OF SUCH EQUIPMENT AMONG THE 400 OR MORE PROJECTS BENEFITTED.

CONSIDERING THE TOTAL AMOUNT OF MONEY ALLOCATED THE INDIAN SERVICE FROM PUBLIC WORKS FUNDS WE FEEL THAT THE AMOUNT SET ASIDE FOR ADMINISTRATIVE, TECHNICAL, CLERICAL, AND OFFICE EXPENSES IS EXTREMELY SMALL, AND REQUEST THAT IN CASES WHERE IT IS OBVIOUSLY IMPRACTICABLE TO GIVE A PROJECT DESIGNATION WE BE RELIEVED OF THAT REQUIREMENT, WITH THE UNDERSTANDING, OF COURSE, THAT AN APPROPRIATE NOTATION WILL BE MADE IN EACH SUCH CASE TO ACQUAINT THE ACCOUNTING OFFICE WITH THE FACT THAT THE SERVICE FOR WHICH PAYMENT IS PROPOSED IS OF A GENERAL NATURE NOT SUSCEPTIBLE OF SEGREGATION ON A PROJECT BASIS.

AN EARLY REPLY WILL BE APPRECIATED AS WE ARE NOW HOLDING UP A NUMBER OF FREIGHT AND TRANSPORTATION PASSENGER BILLS PENDING DECISION WITH REGARD TO THE MATTER DISCUSSED HEREIN.

IN CONNECTION WITH THE MATTER OF ACCOUNTING FOR EMERGENCY FUNDS GENERALLY ATTENTION IS INVITED TO DECISION IN 13 COMP. GEN. 176, IN WHICH IT IS HELD THAT THE PROPER DATA SHOULD BE FURNISHED TO SHOW THAT THE ITEMS OF EXPENDITURE ARE PROPERLY FOR CHARGING TO THE EMERGENCY FUNDS.

WITH RESPECT TO THE PARTICULAR MATTER PRESENTED IN THE ABOVE-QUOTED LETTER, IN WHICH IT IS ALLEGED THAT IT IS IMPOSSIBLE TO ALLOCATE CERTAIN ADMINISTRATIVE AND OTHER EXPENSES IN CARRYING OUT EMERGENCY PROJECTS GENERALLY UNDER THE INDIAN SERVICE, IT MAY BE STATED THAT THE EMERGENCY FUNDS MADE AVAILABLE TO THE INDIAN SERVICE ARE SO MADE AVAILABLE UNDER AND FOR USE ONLY WITH RESPECT TO SPECIFIC PROJECTS AS ADOPTED AND ALLOTTED FOR BY THE FEDERAL INDUSTRIAL RECOVERY ACT. IN THIS CONNECTION ATTENTION IS INVITED IN PARTICULAR TO SECTION 203 (B) OF THE ACT IN WHICH IT IS PROVIDED THAT ALL EXPENDITURES FOR AUTHORIZED TRAVEL BY OFFICERS AND EMPLOYEES, INCLUDING SUBSISTENCE, REQUIRED ON ACCOUNT OF ANY FEDERAL PUBLIC WORKS PROJECTS, SHALL BE CHARGED TO THE AMOUNT ALLOCATED TO SUCH PROJECTS NOTWITHSTANDING ANY OTHER PROVISIONS OF LAW.

IT SHOULD BE READILY APPARENT FROM THE FOREGOING THAT THE AUDIT BY THIS OFFICE OF EXPENDITURES UNDER THE EMERGENCY FUNDS MADE AVAILABLE UNDER THE NATIONAL INDUSTRIAL RECOVERY ACT MUST BE AS TO THE PARTICULAR PROJECTS ADOPTED AND ALLOTTED FOR UNDER THE ACT. IT FOLLOWS, OF NECESSITY, THAT TO ENABLE THIS OFFICE TO ALLOW CREDIT FOR SUCH PAYMENTS THE PROPER DATA AND INFORMATION MUST BE FURNISHED BY THE SPENDING AGENCIES SHOWING THE RELATION BETWEEN THE EXPENDITURES AND THE PROJECTS INVOLVED. IT MAY BE, AS YOU STATE, THAT AS TO SOME EXPENSES, SUCH AS EXPENDITURES FOR TRAVEL, ADMINISTRATION, AND OTHERS, IT MAY NOT BE POSSIBLE TO SHOW ACCURATELY ON THE VOUCHER WHEN PAID OR WHEN SUBMITTED FOR THE PREAUDIT WHAT PARTICULAR PROJECT OR PROJECTS ARE INVOLVED, BUT THE ADMINISTRATIVE ACCOUNTING SET UP SHOULD BE SUCH AS TO PROVIDE THAT EVERY EXPENDITURE MADE FROM EMERGENCY FUNDS IS CHARGEABLE EVENTUALLY TO A PARTICULAR PROJECT OR SEVERAL PROJECTS, AS THE CASE MAY BE, EITHER ON AN ACTUAL BASIS OR, WHERE THAT IS NOT POSSIBLE, ON A PRO RATA COST DISTRIBUTION OR ALLOCATION. WHENEVER POSSIBLE, SUCH DATA AND INFORMATION SHOULD BE SUBMITTED WHEN THE BILL OR VOUCHER IS TRANSMITTED TO THIS OFFICE FOR AUDIT. WHEN THAT IS NOT POSSIBLE, PROPER NOTATION SHOULD BE MADE ON THE VOUCHER TO THAT EFFECT AND THAT SAID INFORMATION WILL BE SUBMITTED HERE AS SOON AS IT BECOMES AVAILABLE IN THE ADMINISTRATIVE OFFICE.

THE QUESTION SUBMITTED IN THE LETTER HEREIN QUOTED IS ANSWERED ACCORDINGLY.