B-200309.OM, APR 3, 1981

B-200309.OM: Apr 3, 1981

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WE HAVE REVIEWED THE EDUCATION DEPARTMENT'S PROPOSAL FOR CARRYING OUT THE SUBJECT TRANSFER. DEFENSE AND EDUCATION CAN LEGALLY DO ESSENTIALLY WHAT IS PROPOSED. WE HAVE NO LEGAL OBJECTION IF DOD ASSUMES THIS RESPONSIBILITY AND LIABILITY. THE DEPARTMENT OF DEFENSE (DOD) OVERSEAS DEPENDENTS' SCHOOLS WERE CREATED ADMINISTRATIVELY IN 1946 TO PROVIDE ELEMENTARY AND SECONDARY EDUCATION FOR CHILDREN OF MILITARY PERSONNEL STATIONED OUTSIDE THE CONTINENTAL UNITED STATES AND PUERTO RICO. THE SCHOOL SYSTEM WAS LATER STATUTORILY AUTHORIZED. ALL FUNCTIONS OF THE SECRETARY OF DEFENSE RELATING TO THE OPERATION OF THESE SCHOOLS ARE (BY SECTION 302(A) OF THE DEPARTMENT OF EDUCATION ORGANIZATION ACT. (THE FOLLOWING DISCUSSION DEALS WITH WHAT WILL HAPPEN AFTER THE TRANSFER TAKES PLACE.

B-200309.OM, APR 3, 1981

SUBJECT: TRANSFER OF DEFENSE OVERSEAS DEPENDENTS' SCHOOLS FROM DEPARTMENT OF DEFENSE TO DEPARTMENT OF EDUCATION - B-200309-O.M.

DIRECTOR, AFMD:

AT THE REQUEST OF MR. DONLON OF YOUR DIVISION, WE HAVE REVIEWED THE EDUCATION DEPARTMENT'S PROPOSAL FOR CARRYING OUT THE SUBJECT TRANSFER. SPECIFICALLY, EDUCATION HAS ASKED ABOUT ITS PROPOSAL TO ALLOW DEFENSE TO CONTINUE DISBURSING FUNDS FOR THE SCHOOLS ON EDUCATION'S BEHALF ON A REIMBURSABLE BASIS AFTER THE TRANSFER AND TO CERTIFY VOUCHERS FOR PAYMENT. WITH THE APPROVAL OF THE TREASURY DEPARTMENT, DEFENSE AND EDUCATION CAN LEGALLY DO ESSENTIALLY WHAT IS PROPOSED, NOT BY A DELEGATION BUT BY AN INTERAGENCY AGREEMENT. RESPONSIBILITY FOR DISBURSEMENT AND CERTIFICATION, AND FOR CERTIFYING OFFICERS'LIABILITY, MAY BE THE SUBJECT OF SUCH AN AGREEMENT; WE HAVE NO LEGAL OBJECTION IF DOD ASSUMES THIS RESPONSIBILITY AND LIABILITY.

THE DEPARTMENT OF DEFENSE (DOD) OVERSEAS DEPENDENTS' SCHOOLS WERE CREATED ADMINISTRATIVELY IN 1946 TO PROVIDE ELEMENTARY AND SECONDARY EDUCATION FOR CHILDREN OF MILITARY PERSONNEL STATIONED OUTSIDE THE CONTINENTAL UNITED STATES AND PUERTO RICO. THE SCHOOL SYSTEM WAS LATER STATUTORILY AUTHORIZED, UNDER THE CONTROL OF THE SECRETARY OF DEFENSE, BY THE DEFENSE DEPENDENTS' EDUCATION ACT (TITLE XIV OF THE EDUCATION AMENDMENTS OF 1978 (92 STAT. 2365, 20 U.S.C. SEC. 921 ET SEG).

ALL FUNCTIONS OF THE SECRETARY OF DEFENSE RELATING TO THE OPERATION OF THESE SCHOOLS ARE (BY SECTION 302(A) OF THE DEPARTMENT OF EDUCATION ORGANIZATION ACT, PUBLIC LAW NO. 96-88, 93 STAT. 679, OCTOBER 17, 1979) TO BE TRANSFERRED TO THE SECRETARY OF EDUCATION NOT LATER THAN MAY 4, 1983. (THE FOLLOWING DISCUSSION DEALS WITH WHAT WILL HAPPEN AFTER THE TRANSFER TAKES PLACE, SINCE AT PRESENT, DEFENSE CONTINUES TO OPERATE THE SCHOOL SYSTEM.)

THE 273 SCHOOLS IN THE SYSTEM ARE LOCATED IN 22 COUNTRIES AND MANAGED THROUGH SIX REGIONAL OFFICES OF THE DEPARTMENT OF DEFENSE. EMPLOYING AT LEAST 9,200 PERSONS, THE SYSTEM REQUIRES PAYMENT OF APPROXIMATELY 4,900 VOUCHERS PER MONTH WORLD-WIDE, INCLUDING PAYROLL AND HEADQUARTERS ACTIVITIES. INASMUCH AS THE SCHOOLS HAVE BEEN UNDER THE JURISDICTION OF DOD, IT HAS PROVIDED DISBURSEMENT SUPPORT FOR THE SMALL FINACIAL STAFF OF THE OFFICE OF DEPENDENT SCHOOLS (ODS) IN WASHINGTON, D. C. DETAILED ACCOUNTINGS, PAYROLLING AND DISBURSING HAVE BEEN PROVIDED BY THE ARMY, AIR FORCE, AND NAVY FINANCE AND ACCOUNTING OFFICES (F&AO) WHICH SERVE THE GEOGRAPHICAL AREAS OF THE REGIONAL OFFICES. DISBURSEMENT FOR LOCAL PROCUREMENT, TRAVEL ADVANCES, VOUCHERS, AND RELATED ITEMS HAVE BEEN MADE BY FINANCE OFFICES OF THE MILITARY BASES WHERE SCHOOLS ARE LOCATED. HAS BEEN THE FUNCTION OF THE FINANCIAL STAFF OF ODS TO ISSUE ALLOTMENTS AND SUBALLOTMENTS TO THE REGIONAL OFFICES, MONITOR EXPENDITURES AND TREASURY RECONCILLATION, COLLECT DATA FROM FIELD OPERATIONS, CONTROL HEADQUARTERS FUNDING, AND MAKE REQUIRED FINANCIAL REPORTS TO THE DOD COMPTROLLER. THE STAFF HAS ALSO SERVED TO IMPLEMENT DOD DIRECTIVES AND REQUIREMENTS TO THE FIELD STRUCTURE; NEGOTIATE, MONITOR AND PAY FOR REIMBURSABLE SERVICES FROM THE COMPONENTS OF THE THREE BRANCHES; AND SETTLE BILLS FOR SERVICES AND MATERIALS PROVIDED BY THE CONTINENTAL UNITED STATES ARMY COMMAND.

THE ESTABLISHMENT BY THE DEPARTMENT OF EDUCTION OF ITS OWN FINANCIAL SYSTEM FOR THE OVERSEAS OPERATION OF THE SCHOOL SYSTEM WOULD REQUIRE ADDITIONAL STAFF, FACILITIES, AND EQUIPMENT. DOD HAS DEVELOPED, OVER THE YEARS OF ITS SUPPORT TO THE SYSTEM, ALL ASPECTS OF THE KIND OF OPERATION NEEDED TO PROVIDE THIS SERVICE. THEREFORE, IN THE INTERESTS OF ECONOMY AND EFFICIENCY AND TO LESSEN FINANCIAL DISRUPTION OF THE SYSTEM, EDUCATION WISHES TO RETAIN DOD SUPPORT IN THE ADMINISTRATION OF ACCOUNTING, DISBURSING, AND PAYROLL SERVICES FOR THE SCHOOL SYSTEM.

UNDER THE TERMS OF ITS PROPOSAL, THE DEPARTMENT OF EDUCATION WILL PROVIDE DOD WITH FUNDING IN ADVANCE OR BY REIMBURSEMENT, FOR THE ENTIRE PROGRAM OF THE SCHOOL SYSTEM, FOR THE SOLE PURPOSE OF MAKING PAYMENTS AUTHORIZED BY EDUCATION. THE DEPARTMENT OF EDUCATION WILL MAKE ALL POLICY DECISIONS REGARDING THE SCHOOLS, ADMINISTER ALL EDUCATIONAL PROGRAMS, MAKE PERSONNEL DECISIONS, ESTABLISH BUDGETS, SALARIES, AND WAGES, AND GENERALLY PERFORM ALL ADMINISTRATIVE FUNCTIONS WITH THE EXCEPTION OF THE DISBURSING AND PAYROLL FUNCTION. WHILE IT IS CONTEMPLATED THAT DOD WILL ACTUALLY PERFORM THIS LATTER FUNCTION, EDUCATION PLANS TO RETAIN RESPONSIBILITY FOR IT. EDUCATION STATES, IN THIS REGARD, THAT IT WILL AUDIT DOD'S ACCOUNTING OF DISBURSEMENTS MADE FOR THE SCHOOL SYSTEM AND RECONCILE DISCREPANCIES BETWEEN CLAIMS AND PAYMENTS BEFORE FORWARDING ITS REPORT TO THE GENERAL ACCOUNTING OFFICE, AND IT WILL ACCOUNT FOR ALL APPROPRIATIONS MADE FOR THE SCHOOL SYSTEM. DOD WILL MAKE DISBURSEMENTS, PROVIDE PAYROLL SERVICES, AND ACCOUNT TO EDUCATION FOR ALL DISBURSEMENTS MADE ON BEHALF OF THE SCHOOL SYSTEM.

NEITHER THE DEFENSE DEPENDENTS' EDUCATION ACT NOR THE DEPARTMENT OF EDUCATION ORGANIZATION ACT GIVES THE SECRETARY OF EDUCATION AUTHORITY TO DELEGATE AN ADMINISTRATIVE FUNCTION TO ANY OTHER FEDERAL AGENCY. WITH RESPECT TO DELEGATIONS OF AUTHORITY BY THE SECRETARY OF EDUCATION, SECTION 412 OF THE DEPARTMENT OF EDUCATION ORGANIZATION ACT PROVIDES THE SECRETARY AUTHORITY TO DELEGATE FUNCTIONS ONLY WITHIN THE DEPARTMENT. NO OTHER PROVISION IN THE ACT AND NOTHING IN THE LEGISLATIVE HISTORY INDICATES THAT CONGRESS INTENDED TO AUTHORIZE THE DELEGATION OF ANY ADMINISTRATIVE FUNCTION TO ANOTHER AGENCY OR DEPARTMENT. (SEE 57 COMP.GEN. 622 AND 51 COMP.GEN. 457).

THERE IS, HOWEVER, AUTHORITY IN THE DEPARTMENT OF EDUCATION ORGANIZATION ACT (EDUCATION ACT) BY WHICH THE DEPARTMENT MAY PROCURE FINANCE SERVICES FOR THE SCHOOL SYSTEM FROM DOD, WITH ITS CONSENT. IN COMMENTING ON THE TRANSFER, THE LEGISLATIVE COMMITTEES RECOGNIZED THAT THE SCHOOLS DEPEND ON A "NETWORK OF SUPPORT SERVICES PROVIDED BY THE DEPARTMENT OF DEFENSE." THE HOUSE GOVERNMENT OPERATIONS COMMITTEE REPORT (NO.96-143, MAY 14, 1979) AND THE SENATE COMMITTEE ON GOVERNMENTAL AFFAIRS REPORT (NO. 96-49, MARCH 27, 1979) EXPLICITLY STATE THE EXPECTATION THAT THE SECRETARIES OF EDUCATION AND DEFENSE WOULD WORK CLOSELY TO EFFECT A SMOOTH TRANSITION AND THAT THE SECRETARY OF EDUCATION WOULD NEGOTIATE NECESSARY SUPPORT AGREEMENTS WITH THE DEPARTMENT OF DEFENSE. SECTION 511 OF THE EDUCATION ACT PROVIDES, IN THIS REGARD, AS FOLLOWS:

"WITH THE CONSENT OF THE APPROPRIATE DEPARTMENT OR AGENCY HEAD CONCERNED, THE SECRETARY OF EDUCATION IS AUTHORIZED TO UTILIZE THE SERVICES OF SUCH OFFICERS, EMPLOYEES, AND OTHER PERSONNEL OF THE DEPARTMENTS AND AGENCIES FROM WHICH FUNCTIONS OR OFFICES HAVE BEEN TRANSFERRED TO THE SECRETARY OR THE DEPARTMENT, AND FUNDS APPROPRIATED TO SUCH FUNCTIONS OR OFFICES FOR SUCH PERIOD OF TIME AS MAY REASONABLY BE NEEDED TO FACILITATE THE ORDERLY IMPLEMENTATION OF THIS ACT."

ALSO, WITH CONSENT, THE SECRETARY OF EDUCATION MAY -

"*** WITH OR WITHOUT REIMBURSEMENT, USE THE RESEARCH, EQUIPMENT, SERVICES, AND FACILITIES OF ANY AGENCY OR INSTRUMENTALITY OF THE UNITED STATES *** IN CARRYING OUT ANY FUNCTION OF THE SECRETARY OR THE DEPARTMENT."

(PUBLIC LAW NO. 96-88 SEC. 419(A)(1), 93 STAT. 686.)

THESE PROVISIONS CLEARLY ALLOW FOR SUCH NEEDS OF THE DEPARTMENT OF EDUCATION AS ACQUISITION FROM DOD OF SUPPORT SERVICES IN THE MANAGEMENT OF THE OVERSEAS SCHOOL SYSTEM ON A CONTINUING BASIS. THEY SATISFY ANY CONCERN THAT MIGHT OTHERWISE BE RAISED THAT THE SECRETARY OF EDUCATION'S ACQUISITION OF SUPPORT SERVICES FROM DOD AMOUNTS TO AN IMPROPER DELEGATION OF AN ADMINISTRATIVE FUNCTION. (SEE DISCUSSION BELOW.)

CONTRACTUAL AGREEMENTS BETWEEN FEDERAL AGENCIES FOR THE PROVISION OF SERVICES ARE SPECIFICALLY AUTHORIZED BY SECTION 601 OF THE ECONOMY ACT OF 1932, 47 STAT. 417, AS AMENDED, 31 U.S.C. SEC. 686. THIS STATUTE AUTHORIZES ANY EXECUTIVE DEPARTMENT OF THE GOVERNMENT TO OBTAIN FROM ANOTHER EXECUTIVE DEPARTMENT EQUIPMENT, SUPPLIES, WORK OR SERVICES THAT THE REQUISITIONED AGENCY MAY BE ABLE TO PROVIDE, IF THE REQUISITIONING AGENCY DETERMINES SUCH AN AGREEMENT TO BE IN THE INTEREST OF THE GOVERNMENT AND REIMBURSES THE REQUISITIONED AGENCY.

THE DEPARTMENT OF EDUCATION PROPOSAL MEETS THE REQUIREMENTS OF THIS STATUTE. INASMUCH AS THE DOD OFFICES, WHICH HAVE PROVIDED THIS SERVICE FOR THE OFFICE OF DEPENDENT SCHOOLS, ARE NOW EQUIPPED TO SO CONTINUE, IT WOULD APPEAR THAT EDUCATION'S PROPOSAL IS IN THE BEST INTEREST OF THE GOVERNMENT. SEE 58 COMP.GEN. 471 (1979); SEE ALSO B-167790, DECEMBER 23, 1977.

WE HAVE IN THE PAST RECOGNIZED AS PROPER AGREEMENTS WHEREBY OFFICERS OF ONE AGENCY PROVIDE ADMINISTRATIVE SUPPORT SERVICE, INCLUDING CERTIFICATION OF VOUCHERS, FOR ANOTHER AGENCY (55 COMP.GEN. 388 (1975); 44 COMP.GEN. 100 (1964)), AND WE HAVE ACKNOWLEDGED THE ECONOMY ACT TO BE A BASIS FOR SUCH AGREEMENTS (55 COMP.GEN. 388; 59 COMP.GEN. 471 (1980)). IN ORDER TO SATISFY THE REQUIREMENTS OF 31 U.S.C. SEC. 82B THAT THE CERTIFYING OFFICER BE AN OFFICER OR EMPLOYEE OF THE AGENCY WHOSE FUNDS ARE INVOLVED AND BE APPOINTED FOR THAT PURPOSE BY THE AGENCY HEAD, THE SECRETARY OF EDUCATION OR HIS DELEGATE MUST APPOINT THE DOD DISBURSING OFFICERS AS EDUCATION CERTIFYING OFFICERS. SUCH AN APPOINTMENT, WE HAVE HELD, OPERATES IMPLICITLY TO CONSTITUTE THE DOD EMPLOYEES AS EDUCATION EMPLOYEES (WITHOUT COMPENSATION) FOR PURPOSES OF 31 U.S.C. SEC. 82B, 59 COMP.GEN. 471; 44 COMP.GEN. 100.

CONCERNING INTERAGENCY AGREEMENTS FOR THE PERFORMANCE OF ADMINISTRATIVE FUNCTIONS, WE HAVE CONSISTENTLY HELD THAT 31 U.S.C. SEC. 686 CANNOT BE USED BY AN AGENCY TO DELEGATE OR TRANSFER STATUTORY DUTIES VESTED IN IT TO ANOTHER AGENCY. SEE 52 COMP.GEN. 128, 132 (1972); B-117604-O.M., DATED JUNE 30, 1970; B-156010-O.M., DATED MARCH 16, 1965; B-45488, DATED NOVEMBER 11, 1944; AND A-70486, DATED MARCH 18, 1936. THIS INTERPRETATION IS BASED UPON THE PRINCIPLE THAT, INHERENT IN A CONGRESSIONAL GRANT OF AUTHORITY TO A DEPARTMENT, AGENCY, OR HEAD THEREOF, TO PERFORM AN ADMINISTRATIVE FUNCTION AND TO EXPEND MONEYS IN THE COURSE OF PERFORMING THAT FUNCTION IS A RESPONSIBILITY THAT MAY NOT BE TRANSFERRED IN THE ABSENCE OF SPECIFIC ACTION OF CONGRESS. SUCH A TRANSFER HAS BEEN DISALLOWED, FOR EXAMPLE, IF IT WOULD HAVE REQUIRED THE REQUISITIONED AGENCY TO TAKE ACTIONS THAT WOULD HAVE BEEN FINAL AND CONCLUSIVE UPON ALL OFFICIALS OF THE UNITED STATES, THEREBY COMPLETELY DIVESTING THE REQUISITIONING AGENCY OF ITS DUTIES AND RESPONSIBILITIES WITH RESPECT TO THAT ADMINISTRATIVE FUNCTION. HOWEVER, WHERE THE REQUISITIONING AGENCY HAS RETAINED ULTIMATE RESPONSIBILITY FOR THE FUNCTION, THE AGREEMENT WAS NOT CONSIDERED A TRANSFER OF AN ADMINISTRATIVE FUNCTION. THUS, IN B-45488, NOVEMBER 11, 1944, WE APPROVED AN ARRANGEMENT UNDER WHICH THE CIVIL SERVICE COMMISSION WOULD AUDIT ALL REFUND DISBURSEMENTS MADE BY THE WAR DEPARTMENT ON THE COMMISSION'S BEHALF AND MAKE ITS REQUIRED ANNUAL REPORT TO CONGRESS, THEREBY RETAINING ULTIMATE RESPONSIBILITY FOR THE PERFORMANCE OF THE FUNCTION.

IN THE INSTANT CASE, WHERE EDUCATION PROPOSES TO DETERMINE EXPENDITURES, RECEIVE FROM DOD AN ACCOUNTING OF DISBURSEMENTS FOR THE SCHOOL SYSTEM, RECONCILE DISCREPANCIES IN PAYMENTS, AND ACCOUNT FOR THE USE OF FUNDS APPROPRIATED FOR THIS PURPOSE, IT WOULD APPEAR THAT EDUCATION IS RETAINING RESPONSIBILITY FOR THE ADMINISTRATIVE FUNCTION.

EDUCATION HAS INQUIRED WHETHER, UNDER SUCH AN ARRANGEMENT, THE DOD DISBURSING OFFICERS CAN ASSUME NOT ONLY THE AUTHORITY BUT THE LIABILITY OF AUTHORIZED CERTIFYING OFFICERS. SECTION 82C OF TITLE 31, U.S.C. PROVIDES THAT THE OFFICER OR EMPLOYEE CERTIFYING A VOUCHER SHALL BE HELD LIABLE FOR THE AMOUNT OF ANY ILLEGAL, IMPROPER, OR INCORRECT PAYMENT RESULTING FROM ANY FALSE, INACCURATE OR MISLEADING CERTIFICATE MADE BY HIM AS WELL AS FOR ANY PAYMENT PROHIBITED BY LAW OR WHICH DID NOT REPRESENT A LEGAL OBLIGATION. BECAUSE THE DOD EMPLOYEES WILL BE AUTHORIZED CERTIFYING OFFICERS OF THE DEPARTMENT OF EDUCATION, THEIR LIABILITY IS AS SET FORTH IN SECTION 82C. 55 COMP.GEN. 388. HOWEVER, IF THE AGREEMENT BETWEEN EDUCATION AND DOD PROVIDES FOR CERTIFICATION ORIGINALLY BY AN EDUCATION EMPLOYEE, LEAVING DOD OFFICIALS "THE SOLE FUNCTION OF MECHANICALLY PROCESSING SUCH VOUCHERS FOR FINAL PAYMENT" (55 COMP.GEN. 388, 390), THEN THE LEGAL LIABILITY OF THE DOD OFFICIALS WOULD BE LIMITED TO ERRORS MADE IN FINAL PROCESSING BY THEM. ID.

EDUCATION HAS QUESTIONED WHETHER DOD'S PERFORMANCE OF DISBURSEMENT SERVICES FOR THE OFFICE OF DEPENDENT SCHOOLS IS PROHIBITED BY SECTION 4 OF EXECUTIVE ORDER NO. 6166, OF JUNE 10, 1933, AS AMENDED BY EXECUTIVE ORDER NO. 6728, OF MAY 29, 1934, REPRINTED AT 5 U.S.C. SEC. 901 NOTE. EXECUTIVE ORDER NO. 6166 TRANSFERRED TO THE DEPARTMENT OF THE TREASURY THE FUNCTION OF DISBURSEMENT OF MONEYS OF THE UNITED STATES WITH RESPECT TO ALL GOVERNMENT AGENCIES. EXECUTIVE ORDER NO. 6728 EXCEPTED FROM THIS TRANSFER THE WAR AND NAVY DEPARTMENTS (PREDECESSORS OF DOD), PROVIDED, HOWEVER, "*** THAT UPON THE REQUEST OF THE SECRETARY OF THE TREASURY AND WITH THE APPROVAL OF THE SECRETARY OF WAR AND THE SECRETARY OF THE NAVY, AS THE CASE MAY BE, THE FACILITIES OF THE WAR AND NAVY DEPARTMENTS AND THE PANAMA CANAL MAY BE UTILIZED IN THE DISBURSEMENT, OR AIDING IN THE DISBURSEMENT, OF PUBLIC MONEYS OF THE UNITED STATES AVAILABLE FOR EXPENDITURE BY ANY EXECUTIVE DEPARTMENT, INDEPENDENT ESTABLISHMENT, OR AGENCY OF THE GOVERNMENT."

THE DEPARTMENT OF EDUCATION STATES IN ITS PROPOSAL THAT THE TREASURY DEPARTMENT HAS EXPRESSED ITS WILLINGNESS TO DELEGATE DISBURSING AUTHORITY TO DOD. WE HAVE IN ANALOGOUS CIRCUMSTANCES DETERMINED THAT DISBURSING OFFICERS OF THE FOREIGN SERVICE MIGHT HANDLE DISBURSEMENT FOR THE WAR DEPARTMENT. 22 COMP.GEN. 48, 51 (1942). LIKEWISE, THERE IS NO LEGAL REASON WHY DOD MAY NOT RENDER DISBURSING SERVICES FOR A NON DEFENSE AGENCY. THUS, WE DID NOT OBJECT TO THE AGREEMENT BETWEEN THE WAR DEPARTMENT AND THE CIVIL SERVICE COMMISSION PURSUANT TO SECTION 601 OF THE ECONOMY ACT BY WHICH THE WAR DEPARTMENT PROVIDED DISBURSEMENT SERVICES FOR THE CIVIL SERVICE COMMISSION. B-45488, NOVEMBER 11, 1944, SUPRA. IN VIEW OF THE AUTHORITY PROVIDED IN SECTION 4 OF EXECUTIVE ORDER NO. 6166 AND THE ABSENCE OF ADMINISTRATIVE INTERPRETATION TO THE CONTRARY, WE SEE NO LEGAL OBSTACLE TO THE DELEGATION OF DISBURSEMENT AUTHORITY BY THE TREASURY DEPARTMENT TO DOD.

DIGEST

RESPONSIBILITY FOR DEFENSE OVERSEAS DEPENDENTS' SCHOOLS WILL BE TRANSFERRED TO EDUCATION DEPARTMENT. ECONOMY ACT (31 U.S.C. SEC. 686) AGREEMENT BETWEEN DEFENSE AND EDUCATION IS AUTHORIZED, WHEREBY DEFENSE DISBURSING OFFICERS WILL BE AUTHORIZED CERTIFYING OFFICERS OF EDUCATION DEPARTMENT AND, ON REIMBURSABLE BASIS, WILL PROVIDE FINANCIAL SERVICES FOR SCHOOLS. DEFENSE DISBURSING OFFICERS WILL HAVE LIABILITY OF CERTIFYING OFFICERS FOR TRANSACTIONS ON BEHALF OF EDUCATION (UNLESS AGREEMENT LIMITS THEIR ROLE TO MECHANICALLY PROCESSING VOUCHERS CERTIFIED BY EDUCATION). OTHER AUTHORITY FOR PROPOSED ARRANGEMENT IS DEPARTMENT OF EDUCATION ORGANIZATION ACT, PUB. L. NO. 96-49, SECTIONS 419(A)(1) AND 511.