A-56935, AUGUST 8, 1934, 14 COMP. GEN. 103

A-56935: Aug 8, 1934

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WHERE THE WRONG APPROPRIATION HAS BEEN CHARGED IT IS THE DUTY OF THE GENERAL ACCOUNTING OFFICE IN AUDITING THE ACCOUNTS TO QUESTION THE EXPENDITURE AND REQUIRE A SATISFACTORY EXPLANATION OR ADJUSTMENT OF THE MATTER BEFORE CREDIT MAY BE ALLOWED THEREFOR. A VOUCHER HAS BEEN CHARGED TO THE WRONG APPROPRIATION AND IT CLEARLY APPEARS THAT ANOTHER APPROPRIATION IS AVAILABLE. WHEN AN OBLIGATION IS PROPERLY CHARGEABLE TO MORE THAN ONE APPROPRIATION IT IS PROPER TO SHOW ON THE VOUCHER IN THE SPACE PROVIDED THEREFOR. AS FOLLOWS: I AM ENCLOSING A SCHEDULE OF AMOUNTS WHICH HAVE BEEN GRANTED BY THE FEDERAL EMERGENCY RELIEF ADMINISTRATION FOR DROUGHT RELIEF SUBSEQUENT TO THE EXECUTIVE ORDER OF JUNE 23RD.

A-56935, AUGUST 8, 1934, 14 COMP. GEN. 103

FEDERAL EMERGENCY RELIEF ADMINISTRATION - VOUCHERS - APPROPRIATION AND ADJUSTMENT THEREOF - OBLIGATIONS CHARGEABLE TO MULTIPLE APPROPRIATION AND THE VOUCHERING THEREOF VOUCHERS SUBMITTED IN SUPPORT OF DISBURSING OFFICERS' ACCOUNTS MUST SHOW THE ACTUAL APPROPRIATION OR APPROPRIATIONS PROPERLY CHARGEABLE WITH THE EXPENDITURE REPRESENTED BY THE VOUCHERS, AND WHERE THE WRONG APPROPRIATION HAS BEEN CHARGED IT IS THE DUTY OF THE GENERAL ACCOUNTING OFFICE IN AUDITING THE ACCOUNTS TO QUESTION THE EXPENDITURE AND REQUIRE A SATISFACTORY EXPLANATION OR ADJUSTMENT OF THE MATTER BEFORE CREDIT MAY BE ALLOWED THEREFOR. WHILE THE GENERAL ACCOUNTING OFFICE MAY EFFECT ADJUSTMENTS BETWEEN APPROPRIATIONS WHEN, UNDER A MISTAKE OF LAW OR FACT, A VOUCHER HAS BEEN CHARGED TO THE WRONG APPROPRIATION AND IT CLEARLY APPEARS THAT ANOTHER APPROPRIATION IS AVAILABLE, AN ADMINISTRATIVE OFFICER MAY NOT, FOR THE SAKE OF AN ADMINISTRATIVE EXPEDIENCY, DELIBERATELY CHARGE THE WRONG APPROPRIATION WITH THE EXPECTATION OF OBTAINING SUBSEQUENTLY AN ADJUSTMENT THEREOF BY TRANSFER OF APPLICABLE APPROPRIATIONS--- SUCH PRACTICE RESULTING IN THE RENDITION OF FALSE ACCOUNTS AND BEING VIOLATIVE OF THE PROVISION OF SECTION 3678 REVISED STATUTES. WHEN AN OBLIGATION IS PROPERLY CHARGEABLE TO MORE THAN ONE APPROPRIATION IT IS PROPER TO SHOW ON THE VOUCHER IN THE SPACE PROVIDED THEREFOR, ALL OF THE APPLICABLE APPROPRIATIONS AND TO DRAW ONE CHECK TO THE PAYEE IN PAYMENT OF THE OBLIGATION REPRESENTED BY THE VOUCHER.

COMPTROLLER GENERAL MCCARL TO THE ADMINISTRATOR, FEDERAL EMERGENCY RELIEF ADMINISTRATION, AUGUST 8, 1934:

THERE HAS BEEN REFERRED HERE FOR CONSIDERATION THE LETTER OF THE ACTING ADMINISTRATOR DATED JULY 24, 1934, ADDRESSED TO THE SECRETARY OF THE TREASURY, AS FOLLOWS:

I AM ENCLOSING A SCHEDULE OF AMOUNTS WHICH HAVE BEEN GRANTED BY THE FEDERAL EMERGENCY RELIEF ADMINISTRATION FOR DROUGHT RELIEF SUBSEQUENT TO THE EXECUTIVE ORDER OF JUNE 23RD.

THESE AMOUNTS, ALTHOUGH FALLING WITHIN THE SCOPE OF THE APPROPRIATION TO MEET THE EMERGENCY AND NECESSITY FOR RELIEF IN STRICKEN AGRICULTURAL AREAS, HAVE, FOR REASONS OF ADMINISTRATIVE CONVENIENCE, BEEN GRANTED OUT OF FUNDS OTHERWISE APPROPRIATED TO THE FEDERAL EMERGENCY RELIEF ADMINISTRATION. I NOW REQUEST THAT A TRANSFER TO THE GENERAL FUNDS OF THE FEDERAL EMERGENCY RELIEF ADMINISTRATION BE MADE FROM THE SUM OF $56,250,000 ALLOCATED FOR GRANTS TO THE STATES BY EXECUTIVE ORDER OF JUNE 23RD.

THE AMOUNT REQUESTED TO BE TRANSFERRED REPRESENTS SUMS GRANTED FOR DROUGHT RELIEF OPERATIONS DURING THE MONTH OF JULY. A SIMILAR REQUEST WILL BE SUBMITTED LATER THIS MONTH COVERING SUMS GRANTED OUT OF THE GENERAL FUNDS OF THE FEDERAL EMERGENCY RELIEF ADMINISTRATION FOR DROUGHT RELIEF FOR AUGUST.

THE PRACTICE OF MAKING DROUGHT-RELIEF GRANTS FROM GENERAL FUNDS OF THE FEDERAL EMERGENCY RELIEF ADMINISTRATION IN THE EXPECTATION OF A SUBSEQUENT TRANSFER COVERING THESE AMOUNTS DEVELOPED WHEN IMMEDIATELY AFTER JUNE 23RD IT BECAME NECESSARY TO RELEASE FUNDS TO THE STATES BEFORE ARRANGEMENTS COULD BE EFFECTED TO CHARGE THESE AMOUNTS AGAINST THE SEPARATE APPROPRIATION. THERE ARE, HOWEVER, SUBSTANTIAL ADMINISTRATIVE ADVANTAGES IN CONTINUING THIS PRACTICE.

THE VARIOUS STATES ARE ACCUSTOMED TO RECEIPT OF A SINGLE REMITTANCE PRIOR TO THE BEGINNING OF EACH MONTH COVERING THAT MONTH'S RELIEF ACTIVITIES. IN THUS FORWARDING A SINGLE REMITTANCE CONSIDERABLE CONFUSION IN THE STATES IS PREVENTED. FURTHERMORE, IF REMITTANCES WERE FORWARDED FOR SEPARATE FUNDS IT WOULD BE NECESSARY TO DOUBLE THE NUMBER OF TRANSACTIONS TO BE CLEARED MONTHLY THROUGH THE TREASURY. WITHIN THE SINGLE REMITTANCE MADE TO THE STATES SPECIFIC SUMS ARE EARMARKED FOR VARIOUS SPECIFIC PROGRAMS SUCH AS THE DROUGHT RELIEF PROGRAM. LETTERS OF INSTRUCTION ARE GIVEN TO THE STATES CONCERNING THE EARMARKING OF THESE ITEMS AND THE STATES ARE REQUIRED TO MAINTAIN SEPARATE ACCOUNTS FOR EACH OF THE FUNDS THUS EARMARKED, AND TRANSFERS BETWEEN THESE FUNDS ARE NOT PERMITTED EXCEPT WITH THE APPROVAL OF THE FEDERAL EMERGENCY RELIEF ADMINISTRATION. TRANSFERS BETWEEN DROUGHT RELIEF AND OTHER FUNDS ARE NOT CONTEMPLATED.

IT WILL BE NOTED THAT THE ATTACHED SCHEDULE COVERS TWO TYPES OF ACTIVITIES. PART OF THE FUNDS WHICH HAVE BEEN GRANTED ARE FOR THE PROCESSING AND FEEDING OF CATTLE SHIPPED FROM THE DROUGHT AREA INTO OTHER STATES. THE BALANCE REPRESENTS RELIEF IN THE DROUGHT AREA IN ACCORDANCE WITH THE POLICY CONTEMPLATED BY THE ADMINISTRATION IN CONNECTION WITH THE ENACTMENT OF THE "EMERGENCY APPROPRIATION ACT, FISCAL YEAR 1935.'

THE SCHEDULE REFERRED TO IN THE LETTER, SUPRA, SHOWS THAT DURING THE MONTH OF JULY 1934, GRANTS AMOUNTING TO $21,965,721 WERE MADE BY YOUR ADMINISTRATION TO A NUMBER OF STATES ON ACCOUNT OF ,CARE OF CATTLE FROM DROUGHT AREA" AND "RELIEF IN DROUGHT AREA," THE FORMER TOTALING $1,385,000, AND THE LATTER, $20,580,721. THE "GENERAL FUNDS" REFERRED TO IN THE LETTER ARE UNDERSTOOD TO BE SET UP ON THE BOOKS OF THE TREASURY UNDER THE APPROPRIATION TITLE DENOMINATED "FEDERAL EMERGENCY RELIEF ADMINISTRATION, 1935.' PURSUANT TO THE ACT OF CONGRESS APPROVED JUNE 19, 1934, 48 STAT. 1021, APPROPRIATING $525,000,000 TO MEET EMERGENCY AND NECESSITY FOR RELIEF IN STRICKEN AGRICULTURAL AREAS, THE PRESIDENT BY EXECUTIVE ORDER NO. 6747, DATED JUNE 23, 1934, ALLOTTED FROM THE AMOUNT THUS APPROPRIATED, THE SUM OF $56,250,000 TO THE FEDERAL EMERGENCY RELIEF ADMINISTRATION FOR THE PURPOSE OF MAKING GRANTS TO STATES. THIS ALLOCATION HAS BEEN SET UP ON THE BOOKS OF THE TREASURY UNDER THE APPROPRIATION TITLE DENOMINATED "LOANS AND RELIEF IN STRICKEN AGRICULTURAL AREAS (TRANSFER TO FEDERAL EMERGENCY RELIEF ADMINISTRATION) 1934, MAY 12, 1935.' THE FORMER APPROPRIATION IS AVAILABLE, PRIMARILY, FOR RELIEF IN THE CASE OF UNEMPLOYMENT, WHEREAS THE LATTER IS AVAILABLE, AS THE TITLE SUGGESTS, FOR RELIEF IN STRICKEN AGRICULTURAL AREAS ON ACCOUNT OF DROUGHT.

IT APPEARS FROM THE LETTER, SUPRA, THAT, DUE TO AN ALLEGED ADMINISTRATIVE EXPEDIENCY, THE APPROPRIATION FIRST MENTIONED IS CHARGED ON VOUCHERS COVERING GRANTS TO STATES NOTWITHSTANDING THAT A PART OF THE GRANT COVERS DROUGHT RELIEF SPECIFICALLY PROVIDED FOR UNDER AND CHARGEABLE TO THE LAST- NAMED APPROPRIATION, AND THAT AN ADJUSTMENT OF THE MATTER IS NOW SOUGHT BY REQUESTING A TRANSFER OF APPROPRIATIONS. IT IS STATED, ALSO, THAT A SIMILAR REQUEST WILL BE MADE FOR GRANTS MADE DURING THE MONTH OF AUGUST 1934, AND THERE IS SUGGESTED, ALSO, THAT THERE IS A "SUBSTANTIAL ADMINISTRATIVE ADVANTAGE IN CONTINUING THE PRACTICE.'

THE ADMINISTRATIVE EXPEDIENCY AND/OR ADVANTAGES ALLUDED TO IN THE LETTER HAVE NOT BEEN FULLY DISCLOSED. WHATEVER BE THE UNDERLYING BASIS FOR THE PROCEDURE REFERRED TO, IT IS FUNDAMENTAL IN GOVERNMENTAL ACCOUNTING THAT VOUCHERS SUBMITTED IN SUPPORT OF DISBURSING OFFICERS' ACCOUNTS MUST SHOW THE ACTUAL APPROPRIATION OR APPROPRIATIONS PROPERLY CHARGEABLE WITH THE EXPENDITURE REPRESENTED BY THE VOUCHERS. IF THE WRONG APPROPRIATION HAS BEEN CHARGED ON A VOUCHER IT IS THE DUTY OF THIS OFFICE IN AUDITING ACCOUNTS, AS REQUIRED BY LAW, TO QUESTION THE EXPENDITURE AND REQUIRE A SATISFACTORY EXPLANATION OR ADJUSTMENT OF THE MATTER BEFORE CREDIT MAY BE ALLOWED THEREFOR IN THE DISBURSING OFFICERS' ACCOUNTS. WHILE THIS OFFICE MAY EFFECT ADJUSTMENTS BETWEEN APPROPRIATIONS, IN PARTICULAR CASES WHERE, UNDER A MISTAKE OF LAW OR FACT, A VOUCHER HAS BEEN CHARGED TO THE WRONG APPROPRIATION, AND IT IS CLEARLY APPARENT THAT ANOTHER APPROPRIATION IS AVAILABLE TO COVER THE OBLIGATION, THAT SHOULD NOT BE TAKEN AS A BASIS FOR AUTHORIZING OR JUSTIFYING AN ADMINISTRATIVE OFFICER DELIBERATELY CHARGING AN APPROPRIATION NOT AVAILABLE FOR THE PAYMENT OF A PARTICULAR EXPENSE IN THE FIRST INSTANCE, AND LATER EXPECT AN ADJUSTMENT THEREOF BY TRANSFER OF APPLICABLE APPROPRIATIONS. SUCH PRACTICE RESULTS IN THE RENDITION OF FALSE ACCOUNTS AND OBVIOUSLY SHOULD NOT BE INDULGED IN MERELY ON THE BASIS OF ALLEGED ADMINISTRATIVE EXPEDIENCIES. FURTHERMORE, THE RENDITION OF ACCOUNTS IN THE MANNER STATED IS IN CONTRAVENTION OF SECTION 3678, REVISED STATUTES, WHICH PROVIDES THAT ALL SUMS FOR THE VARIOUS BRANCHES OF EXPENDITURE IN THE PUBLIC SERVICE SHALL BE APPLIED SOLELY TO THE OBJECTS FOR WHICH THEY ARE RESPECTIVELY MADE, AND FOR NO OTHER.

IN THE PENULTIMATE PARAGRAPH OF YOUR LETTER, SUPRA, IT IS STATED IN EFFECT THAT THE VARIOUS STATES ARE ACCUSTOMED TO RECEIVING A SINGLE REMITTANCE, THAT IN THUS FORWARDING A SINGLE REMITTANCE CONSIDERABLE CONFUSION IN THE STATES IS PREVENTED, AND THAT IF REMITTANCES WERE FORWARDED FOR SEPARATE FUNDS IT WOULD BE NECESSARY TO DOUBLE THE NUMBER OF TRANSACTIONS TO BE CLEARED MONTHLY THROUGH THE TREASURY. IN ORDER TO ACCOMPLISH THAT END IT IS NOT NECESSARY TO RESORT TO THE PRACTICE FOLLOWED. SUCH PURPOSE MAY BE ACCOMPLISHED BY THE EXECUTION OF A SINGLE VOUCHER SHOWING, IN THE SPACE PROVIDED THEREFOR AT THE TOP OF THE VOUCHER, THE APPROPRIATIONS PROPERLY CHARGEABLE WITH THE GRANTS MADE IN ANY PARTICULAR CASE, INDICATING THE AMOUNT CHARGEABLE TO EACH, WHEREUPON ONE CHECK MAY BE DRAWN IN PAYMENT OF THE TOTAL GRANTS. THE CHARGING OF MORE THAN ONE APPROPRIATION ON ONE VOUCHER WHERE THE OBLIGATION REPRESENTED THEREBY IS CHARGEABLE TO MORE THAN ONE APPROPRIATION AND THE DRAWING OF ONLY ONE CHECK TO THE PAYEE IN PAYMENT OF THE OBLIGATION SIMPLIFIES GOVERNMENTAL ACCOUNTING AND THAT PRACTICE HAS BEEN IN EXISTENCE FOR MANY YEARS. IF DIFFICULTIES SHOULD BE ENCOUNTERED IN FOLLOWING THIS ESTABLISHED PROCEDURE IN MAKING GRANTS TO THE SEVERAL STATES AS AUTHORIZED BY LAW, I SHALL BE GLAD TO HAVE REPRESENTATIVES OF THIS OFFICE COOPERATE WITH SUCH OFFICER OR OFFICERS OF YOUR ADMINISTRATION AS YOU MAY DESIGNATE WITH A VIEW TO WORKING OUT A SATISFACTORY PROCEDURE CONSISTENT WITH EXISTING LAWS AND REGULATIONS RELATING TO THE AUDIT AND ACCOUNTING OF EXPENDITURES INVOLVING PUBLIC MONEYS.

FOR THE REASONS HEREINBEFORE STATED THE PRACTICE OF CHARGING THE WRONG APPROPRIATION ON A VOUCHER WITH THE INTENTION TO THEREAFTER SECURE AN ADJUSTMENT OF APPROPRIATIONS SHOULD BE DISCONTINUED IMMEDIATELY.

WITH RESPECT TO ADJUSTMENT REQUESTED IN ORDER THAT THIS OFFICE MAY GIVE CONSIDERATION TO THE MATTER WITH RESPECT TO PAYMENTS ALREADY MADE, IT IS REQUESTED THAT THERE BE FURNISHED A LIST OR SCHEDULE SHOWING THE DISBURSING OFFICER'S VOUCHER NUMBER, DATE OF PAYMENT OF THE VOUCHER, THE AMOUNT INVOLVED IN EACH INSTANCE, THE APPLICABLE APPROPRIATION INVOLVED IN EACH AMOUNT, AND ANY OTHER PERTINENT DATA. UPON RECEIPT OF SUCH INFORMATION THIS OFFICE WILL GIVE PROMPT CONSIDERATION TO THE REQUEST MADE FOR AN ADJUSTMENT OF APPROPRIATIONS.