B-28733, OCTOBER 24, 1942, 22 COMP. GEN. 387

B-28733: Oct 24, 1942

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TELEGRAMS - MULTIPLE-ADDRESS MESSAGES - EVIDENCE REQUIREMENTS FOR PAYMENT BILLS FOR TELEGRAM TRANSMISSION SERVICES SHOULD BE SUPPORTED BY EVIDENCE (1) THAT THE OFFICIAL MESSAGE REQUIRED TO BE SENT WAS THE MESSAGE ACTUALLY TRANSMITTED. (2) THAT THE MESSAGE WAS IN FACT TRANSMITTED. (3) THAT THE CLASS OF SERVICE RENDERED AND CHARGED FOR WAS THAT REQUESTED BY THE SENDER. A SELF-SERVING STATEMENT BY A TELEGRAPH COMPANY OFFICIAL THAT THE SERVICES WERE PERFORMED AS REQUESTED CANNOT BE ACCEPTED IN LIEU OF THE REQUIRED DATA. WHERE TRANSMISSION OF A MULTIPLE-ADDRESS TELEGRAM IS FROM THE ORIGINALLY FILED COPY OF THE MESSAGE. WHERE TRANSMISSION IS FROM COPIES OF SUCH ORIGINAL. ARE REQUIRED TO BE FILED WITH THE VOUCHER.

B-28733, OCTOBER 24, 1942, 22 COMP. GEN. 387

TELEGRAMS - MULTIPLE-ADDRESS MESSAGES - EVIDENCE REQUIREMENTS FOR PAYMENT BILLS FOR TELEGRAM TRANSMISSION SERVICES SHOULD BE SUPPORTED BY EVIDENCE (1) THAT THE OFFICIAL MESSAGE REQUIRED TO BE SENT WAS THE MESSAGE ACTUALLY TRANSMITTED, (2) THAT THE MESSAGE WAS IN FACT TRANSMITTED, AND (3) THAT THE CLASS OF SERVICE RENDERED AND CHARGED FOR WAS THAT REQUESTED BY THE SENDER, AND A SELF-SERVING STATEMENT BY A TELEGRAPH COMPANY OFFICIAL THAT THE SERVICES WERE PERFORMED AS REQUESTED CANNOT BE ACCEPTED IN LIEU OF THE REQUIRED DATA. WHERE TRANSMISSION OF A MULTIPLE-ADDRESS TELEGRAM IS FROM THE ORIGINALLY FILED COPY OF THE MESSAGE, THE VOUCHER COVERING PAYMENT FOR THE TRANSMISSION SERVICES MUST BE SUPPORTED BY SUCH ORIGINAL AND THE LIST OF ADDRESSES WITH APPROPRIATE DATA PLACED THEREON AT THE TIME OF TRANSMISSION, BUT WHERE TRANSMISSION IS FROM COPIES OF SUCH ORIGINAL, THE COPIES, CONTAINING THE NECESSARY DATA FOR A PROPER AUDIT, ARE REQUIRED TO BE FILED WITH THE VOUCHER.

ACTING COMPTROLLER GENERAL ELLIOTT TO THE SECRETARY OF THE NAVY, OCTOBER 24, 1942:

I HAVE YOUR LETTER OF SEPTEMBER 4, 1942, AS FOLLOWS:

THE BUREAU OF SUPPLIES AND ACCOUNTS STATES THAT UNDER PRESENT PRACTICE WITH RESPECT TO MULTIPLE-ADDRESS TELEGRAMS FILED WITH A COMMERCIAL TELEGRAPH COMPANY, IT IS REQUIRED THAT ALL BILLS BE SUPPORTED BY THE ORIGINALS OF SUCH MESSAGES, WHICH INDICATE THEREON EVIDENCE, NOT ONLY OF FILING, BUT ALSO OF TRANSMISSION; THAT, EXCEPT IN CASES WHERE MULTIPLE- ADDRESS TELEGRAMS ARE FILED WITH A BRANCH OFFICE OF A COMMERCIAL TELEGRAPH COMPANY AND THE MESSAGE AND LIST OF ADDRESSES ARE TRANSMITTED BY WIRE TO THE MAIN OFFICE, IT IS NECESSARY THAT THE ORIGINAL MESSAGE TRANSMITTED BE FURNISHED IN SUPPORT OF EACH CHARGE. THIS PRACTICE IS IN CONFORMITY WITH A DECISION OF THE COMPTROLLER GENERAL A-71677, OF AUGUST 12, 1937 IN THE CASE OF WESTERN UNION TELEGRAPH COMPANY AND ARTICLE 2136-42 (C) OF BUREAU OF SUPPLIES AND ACCOUNTS MANUAL.

AN INQUIRY HAS BEEN MADE BY THE WESTERN UNION TELEGRAPH COMPANY, SAN FRANCISCO, CALIFORNIA, WHETHER IN THE CASES OF MULTIPLE-ADDRESS MESSAGES NOW REQUIRING INDIVIDUAL COPIES FOR EACH ADDRESS TO SUPPORT A VOUCHER, IT WOULD BE SATISFACTORY TO SUBMIT ONE OR TWO COPIES OF THE TEXT OF THE MESSAGE WITH A LIST ATTACHED THERETO INDICATING THE ADDRESSES TO WHOM THE MESSAGE WAS SENT, AND AN ENDORSEMENT BY THE TELEGRAPH COMPANY ON THE WHOLE CERTIFYING THAT THE TEXT OF THE MESSAGE WAS PROPERLY TRANSMITTED TO THE LIST OF THE ADDRESSES SHOWN.

IN VIEW OF THE PRESENT WAR CONDITIONS, THE INCREASE IN THE USE OF SUCH MULTIPLE-ADDRESS MESSAGES, AND THE NECESSITY OF REDUCING PAPER WORK TO AN ABSOLUTE MINIMUM, A DECISION IS REQUESTED AS TO WHETHER THE PROCEDURE SET FORTH IN THE INQUIRY REFERRED TO IN THE SECOND PARAGRAPH ABOVE WILL BE ACCEPTABLE TO THE GENERAL ACCOUNTING OFFICE.

IN THE DECISION OF AUGUST 12, 1937, A-71677, REFERRED TO IN YOUR SUBMISSION, IT WAS SAID:

IT APPEARS THAT THE AMOUNT IN QUESTION, NAMELY, $100.99, COMPRISES CHARGES MADE FOR VARIOUS SO-CALLED "BOOK MESSAGES.' AN EXAMINATION OF THE ENTIRE VOUCHER DISCLOSES TWO DISTINCT CLASSES OF BOOK MESSAGES. ONE CLASS CONSISTS OF THE ORIGINAL-FILED MESSAGE BEARING DISTINCT CHARACTERISTICS EVIDENCING TRANSMISSION OF THE MESSAGE. THESE CHARACTERISTICS CONSIST CHIEFLY OF IDENTIFYING NUMBERS OPPOSITE EACH OF THE ADDRESSES TO WHICH THE TELEGRAMS WERE DIRECTED TO BE SENT, AS WELL AS AN INITIAL INDICATING THE BRANCH OF THE OFFICE FROM WHICH THE TELEGRAMS WERE TRANSMITTED AND INCLUDING, ALSO, THE TIME OF TRANSMISSION. AS TO THIS CLASS THE DATA ON THE TELEGRAMS ARE SUFFICIENT FOR AUDIT PURPOSES. THE OTHER CLASS CONSISTS OF WHAT APPEAR TO BE THE ORIGINAL-FILED MESSAGES BUT WHICH BEAR NO DISTINCT CHARACTERISTICS EVIDENCING TRANSMISSION OF THE MESSAGE AS IN THE FIRST CLASS DESCRIBED. AS A MATTER OF FACT, THE BOOK MESSAGES OF THIS CLASS BEAR CERTAIN NOTATIONS WHICH TEND TO INDICATE THAT IF THE MESSAGES WERE IN FACT TRANSMITTED THEY WERE TRANSMITTED NOT FROM THE ORIGINAL-FILED MESSAGE BUT FROM COPIES THEREOF--- THE ORIGINAL-FILED MESSAGES HAVING A STAMPED LEGEND SHOWING WHEN THE MESSAGE WAS RECEIVED, THE NUMBER OF COPIES MADE, BY WHOM MADE, AND THE TIME THE COPIES WERE COMPLETED.

THE PRACTICE OF THIS OFFICE, THE REGULATIONS OF THE SEVERAL DEPARTMENTS AND BUREAUS, AS WELL AS THE TARIFFS OF YOUR COMPANY, REQUIRE THAT ALL BILLS OF SENT PAID MESSAGES BE SUPPORTED BY THE ORIGINALS OF SUCH MESSAGES. THE ORIGINALS AS HERE REFERRED TO HAVE BEEN UNDERSTOOD BY THIS OFFICE AS THOSE BEARING TRANSMISSION MARKS SUCH AS THOSE ALLUDED TO UNDER THE FIRST CLASS OF BOOK MESSAGES ABOVE DESCRIBED. IT APPEARS FROM YOUR REQUEST FOR RECONSIDERATION OF THE MATTER THAT YOU ARE OF THE OPINION THE FILING OF THE ORIGINAL-FILED MESSAGES IN SUPPORT OF YOUR BILL FOR TRANSMISSION CONSTITUTED A SUFFICIENT COMPLIANCE WITH THE REGULATIONS, ETC. HOWEVER, IN ORDER THAT THERE MAY BE NO FURTHER MISUNDERSTANDING IN THIS MATTER, THE EVIDENCE WHICH THIS OFFICE WILL REQUIRE HEREAFTER FOR ACCOUNTING PURPOSES IN THESE CASES WILL CONSIST OF THOSE MESSAGES ACTUALLY FILED WITH THE COMPANY FROM WHICH TRANSMISSIONS ARE MADE--- THE EVIDENCE OF TRANSMISSION TO CONSIST OF APPROPRIATE IDENTIFYING DATA. BUT WHERE TRANSMISSIONS ARE NOT MADE FROM THE MESSAGES ACTUALLY FILED, AS IN THE SECOND CLASS OF BOOK MESSAGES HEREINABOVE DESCRIBED, THOSE COPIES MADE FOR TRANSMISSION PURPOSE--- KNOWN AS "WIRE COPIES"--- WILL BE REQUIRED IN ADDITION TO THE ORIGINAL-FILED BOOK MESSAGE.

IN A LATER DECISION OF OCTOBER 25, 1941, 21 COMP. GEN. 364, IT WAS SAID:

IT IS A WELL-ESTABLISHED ACCOUNTING PRACTICE OF THE GENERAL ACCOUNTING OFFICE TO REQUIRE IN SUPPORT OF CLAIMS FOR TELEGRAPH SERVICE THE ORIGINALS OF THE MESSAGES TRANSMITTED. 22 COMP. DEC. 26; 4 COMP. GEN. 860; 14 ID. 825; A-71677, AUGUST 12, 1937. HOWEVER, CONFUSION FREQUENTLY ARISES AS TO WHAT CONSTITUTES AN ORIGINAL WITHIN THIS RULE. THE BASIC REASON FOR THE REQUIREMENT THAT THE ORIGINAL BE FILED IS TO INSURE THAT THE CHARGES FOR TRANSMISSION WERE CORRECTLY COMPUTED FOR THE SERVICES ACTUALLY RENDERED AND TO PREVENT DUPLICATING PAYMENT OF SUCH CHARGES. THIS IS BEST ACCOMPLISHED BY ACCOMPANYING THE VOUCHER WITH THE COPIES OF THE TELEGRAMS USED FOR TRANSMISSION, SHOWING THEREON THE COMPANY NOTATIONS WITH RESPECT TO THE TIME FILED, THE NUMBER OF WORDS PAID FOR, ETC., SUCH COPIES BEING COMMONLY REFERRED TO AS TRANSMISSION OR WIRE COPY. IT IS IMMATERIAL FOR AUDIT PURPOSES WHETHER THE TRANSMISSION OR WIRE COPIES BE WRITTEN IN LONG HAND OR CONSIST OF CARBON COPIES; ON THE OTHER HAND, A RIBBON COPY NOT SHOWING THE TRANSMISSION DATA WOULD BE OF LITTLE, IF ANY, USE IN AUDITING THE CHARGES.

THE MATTER WAS GIVEN FURTHER CONSIDERATION IN A LETTER OF MAY 18, 1942, A -13067, IN WHICH IT WAS SAID:

IT HAS LONG BEEN THE POLICY OF THIS OFFICE TO ACCEPT ONLY THE ORIGINALS OF MESSAGES IN SUPPORT OF BILLS AGAINST THE GOVERNMENT, WHICH IS IN ACCORDANCE WITH GOOD ACCOUNTING PRACTICES IN PREVENTING DUPLICATE PAYMENTS AND EXCESS CHARGES FOR MESSAGES SENT OR RECEIVED. PREVIOUS TO THIS, THERE HAS BEEN NO REASONABLE BASIS FOR CHANGING THIS REQUIREMENT; HOWEVER, IN THE CASE OF MAIN OFFICE WIRE-TRANSMISSION COPIES RECEIVED FROM WIRE- OPERATED BRANCHES, THERE ARE SEVERAL REASONS PRESENTED IN YOUR LETTER ON WHICH A CHANGE IN GOVERNMENT REQUIREMENTS COULD BE BASED. IT IS STATED THAT MESSAGES FILED IN WIRE-OPERATED BRANCH OFFICES ARE TRANSMITTED BY WIRE TO THE OPERATING DEPARTMENT OF THE MAIN OFFICE AND ALL ACCOUNTING INFORMATION IS TRANSMITTED AS A PART THEREOF; THAT AFTER TRANSMISSION, THE MAIN OFFICE MESSAGE IS NOT AVAILABLE TO THE PERSON ACCEPTING THE ORIGINAL WHEN FILED IN THE BRANCH OFFICE. FROM THIS EXPLANATION IT APPEARS THAT MAIN OFFICE WIRE TRANSMISSION COPIES ARE OF THE SAME CATEGORY AS MESSAGES FILED BY TELEPHONE, EXCEPT THAT THE ORIGINAL MESSAGE RETAINED IN THE FILES OF THE BRANCH OFFICE WILL BE PERMANENT TANGIBLE EVIDENCE FOR REFERENCE PURPOSES, WHEREAS THE "ORIGINAL" OF A MESSAGE FILED BY TELEPHONE IS ONLY THAT WHICH IS PREPARED BY THE RECORDING TELEPHONE OPERATOR OF THE TELEGRAPH COMPANY AS DICTATED BY THE SENDER.

SINCE THERE IS NO DIFFERENCE IN ACCEPTING AS "ORIGINALS" THE MESSAGES PREPARED BY TELEGRAPH COMPANY OPERATORS DICTATED OVER THE TELEPHONE BY THE SENDER AND MESSAGES TRANSMITTED BY WIRE TO OPERATORS IN THE MAIN OFFICE FROM THE ORIGINALS FILED IN THE BRANCH OFFICES, THE PRESENT GOVERNMENT REQUIREMENT WHICH SPECIFIES THAT ORIGINALS OF MESSAGES BE SUBMITTED IN SUPPORT OF BILLS AGAINST THE GOVERNMENT IS REVISED, AND THE MAIN OFFICE WIRE-TRANSMISSION COPIES OF ORIGINAL MESSAGES FILED AT WIRE-OPERATED BRANCH OFFICES WILL BE ACCEPTED AS ORIGINALS, PROVIDED ALL INFORMATION NECESSARY TO A PROPER AUDIT BY THIS OFFICE IS SHOWN THEREON.

THE FOREGOING QUOTATIONS SHOULD CLEARLY SHOW THE REQUIREMENTS IN THE MATTER AND THE PURPOSE TO BE SERVED BY THE DATA OBTAINED UNDER SUCH REQUIREMENTS. IT SHOULD BE READILY APPARENT THAT A PROPER AUDIT CAN BE MADE BY THIS OFFICE OF BILLS OF TELEGRAPH COMPANIES ONLY IF THERE BE BURNISHED IN SUPPORT OF SUCH BILLS EVIDENCE (1) THAT THE OFFICIAL MESSAGE REQUIRED TO BE SENT WAS THE MESSAGE ACTUALLY TRANSMITTED; (2) THAT THE MESSAGE WAS IN FACT TRANSMITTED; AND (3) THAT THE CLASS OF SERVICE RENDERED AND CHARGED FOR WAS THAT REQUESTED BY THE SENDER. OBVIOUSLY, A SELF-SERVING CERTIFICATE BY AN OFFICIAL OF THE TELEGRAPH COMPANY INVOLVED THAT THE SERVICES WERE PERFORMED AS REQUESTED WOULD NOT BE SUFFICIENT FOR THE PURPOSE AND COULD NOT BE ACCEPTED BY THIS OFFICE IN LIEU OF DATA DEEMED ESSENTIAL FOR A PROPER AUDIT OF THE ACCOUNTS.

I AM IN FULL AGREEMENT WITH THE VIEW THAT UNNECESSARY PAPER WORK IN THE GOVERNMENT SHOULD BE ELIMINATED DURING THE PRESENT EMERGENCY AND THIS OFFICE IS ANXIOUS TO COOPERATE IN THAT RESPECT TO THE FULLEST EXTENT POSSIBLE CONSISTENT WITH THE PERFORMANCE OF THE DUTIES IMPOSED UPON IT BY LAW. HOWEVER, IT IS NOT APPARENT THAT THE PRESENT MATTER NECESSARILY INVOLVES UNNECESSARY PAPER WORK; AND IT HAS NOT BEEN SHOWN THAT THE PRESENT PRACTICE IMPOSES BURDENSOME REQUIREMENTS UPON THE TELEGRAPH COMPANIES OR UPON THE ADMINISTRATIVE OFFICES WITH RESPECT TO MULTIPLE- ADDRESS TELEGRAMS. UNDER THE PRESENT REQUIREMENTS THE MATTER IS LEFT MORE OR LESS TO THE DISCRETION OF THE TELEGRAPH COMPANIES IN THE HANDLING OF SUCH TELEGRAMS. IF THE TRANSMISSION IS FROM THE ORIGINALLY FILED COPY OF THE MESSAGE AND LIST OF ADDRESSES WITH APPROPRIATE DATA PLACED THEREON AT THE TIME OF TRANSMISSION OF THE MESSAGE, THE FURNISHING OF SAID ORIGINAL MESSAGE AND LIST WITH SUCH DATA IN SUPPORT OF THE BILL IS ALL THAT IS REQUIRED. IN CASES WHERE THE TRANSMISSION IS NOT FROM THE ORIGINALS BUT FROM COPIES, THE COPIES USED FOR SUCH TRANSMISSION, CONTAINING THE NECESSARY DATA FOR A PROPER AUDIT OF THE ACCOUNT BY THIS OFFICE AS HEREIN INDICATED, ARE REQUIRED TO BE FILED. SUCH REQUIREMENTS APPEAR REASONABLE AND MAY NOT BE WAIVED ON THE RECORD PRESENTED.

ACCORDINGLY, THE SPECIFIC QUESTION YOU SUBMIT IS ANSWERED IN THE NEGATIVE.