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A-49009, B-45107, APR. 15, 1957

B-45107 Apr 15, 1957
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INC.: REFERENCE IS MADE TO YOUR LETTER OF MARCH 19. WHICH PROVIDE FOR THE DISCONTINUANCE OF THE CERTIFICATION BY VENDORS ON BILLS OR INVOICES THAT SUCH BILLS ARE CORRECT AND JUST AND THAT PAYMENT HAS NOT BEEN RECEIVED. INSOFAR AS VOUCHERS FOR TRANSPORTATION AND ACCESSORIAL SERVICES ARE CONCERNED. THERE WAS CONSIDERED THE DIFFERENCE IN THE METHODS OF PROCUREMENT AND OF DETERMINING THE PRICING ARRANGEMENTS FOR SUCH SERVICES. AS COMPARED WITH THOSE INVOLVED IN THE PURCHASE AND PROCUREMENT OF OTHER SUPPLIES AND SERVICES AND IT WAS DETERMINED SUCH DIFFERENCE JUSTIFIED A DIFFERENT CONCLUSION AS TO THE SIGNIFICANCE OF THE CERTIFICATION IN RELATION TO BILLS FOR TRANSPORTATION. MATERIAL AND SUPPLIES OF ALL KINDS ARE ORDINARILY PROCURED BY GOVERNMENT DEPARTMENTS AND AGENCIES BY CONTRACTS AWARDED AFTER COMPETITIVE BIDDING OR BY PURCHASE FROM SUPPLIERS ON GENERAL SUPPLY SCHEDULES.

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A-49009, B-45107, APR. 15, 1957

TO AMERICAN TRUCKING ASSOCIATION, INC.:

REFERENCE IS MADE TO YOUR LETTER OF MARCH 19, 1957, FILE 306, CONCERNING OUR GENERAL REGULATIONS NO. 134, DATED MARCH 11, 1957, WHICH PROVIDE FOR THE DISCONTINUANCE OF THE CERTIFICATION BY VENDORS ON BILLS OR INVOICES THAT SUCH BILLS ARE CORRECT AND JUST AND THAT PAYMENT HAS NOT BEEN RECEIVED. AS STATED, THOSE REGULATIONS DO NOT APPLY WITH RESPECT TO BILLS FOR TRANSPORTATION AND ACCESSORIAL SERVICES. YOU QUESTION THE PROPRIETY OF THIS EXCEPTION, AND ASK THAT THIS "DISCRIMINATION" AGAINST TRANSPORTATION LINES BE REMOVED.

INSOFAR AS VOUCHERS FOR TRANSPORTATION AND ACCESSORIAL SERVICES ARE CONCERNED, THERE WAS CONSIDERED THE DIFFERENCE IN THE METHODS OF PROCUREMENT AND OF DETERMINING THE PRICING ARRANGEMENTS FOR SUCH SERVICES, AS COMPARED WITH THOSE INVOLVED IN THE PURCHASE AND PROCUREMENT OF OTHER SUPPLIES AND SERVICES AND IT WAS DETERMINED SUCH DIFFERENCE JUSTIFIED A DIFFERENT CONCLUSION AS TO THE SIGNIFICANCE OF THE CERTIFICATION IN RELATION TO BILLS FOR TRANSPORTATION. MATERIAL AND SUPPLIES OF ALL KINDS ARE ORDINARILY PROCURED BY GOVERNMENT DEPARTMENTS AND AGENCIES BY CONTRACTS AWARDED AFTER COMPETITIVE BIDDING OR BY PURCHASE FROM SUPPLIERS ON GENERAL SUPPLY SCHEDULES. UNIT COSTS OF SUPPLIES AND MATERIAL ARE STATED IN PLAIN TERMS IN THE CONTRACTS AND GENERAL SUPPLY SCHEDULES. TRANSPORTATION AND ACCESSORIAL SERVICES, ON THE OTHER HAND, ARE OBTAINED WHEN SHIPMENTS OF PROPERTY ARE TENDERED TO THE AGENT OF THE CARRIER AT THE POINT OF ORIGIN ON GOVERNMENT BILLS OF LADING OR ON STANDARD COMMERCIAL BILLS OF LADING. PURSUANT TO SUCH PROCUREMENT THE APPLICABLE TRANSPORTATION CHARGES ARE DETERMINED ON THE BASIS OF RATES, FARES, CHARGES, AND RULES, REGULATIONS AND PRACTICES OF THE CARRIERS, PUBLISHED IN TARIFFS FILED WITH THE FEDERAL OR STATE REGULATORY AUTHORITY, OR OFFERED IN SPECIAL TENDERS OR OFFERS MADE BY THE CARRIERS PURSUANT TO SECTION 22 OF THE INTERSTATE COMMERCE ACT OR OTHER COMPARABLE PROVISIONS OF LIKE STATUTES OF THE SEVERAL STATES WHICH PERMIT THE CARRIERS TO TRANSPORT PERSONS AND PROPERTY FOR OR ON BEHALF OF THE UNITED STATES FREE, OR AT REDUCED RATES, I.E., AT RATES LOWER THAN THOSE PUBLISHED AND FILED WITH THE REGULATORY AGENCIES.

BECAUSE OF THESE FUNDAMENTAL DIFFERENCES, ESPECIALLY IN DETERMINING THE PRICING ARRANGEMENTS, THE GOVERNMENT ACCOUNTING OFFICERS HAVE FOUND IT NECESSARY TO ESTABLISH AND MAINTAIN DIFFERENT ACCOUNTING PROCEDURES AND FORMS TO ENABLE A PROPER DISCHARGE OF THEIR AUDITING FUNCTIONS. STANDARD FORM NO. 1034, PUBLIC VOUCHER FOR SUPPLIES AND SERVICES, FOR EXAMPLE, HAS PROVEN ADEQUATE FOR USE BY VENDORS AS A VEHICLE FOR PRESENTING BILLS OR INVOICES FOR SUPPLIES AND MATERIAL, WHEREAS ENTIRELY DIFFERENT PUBLIC VOUCHER FORMS HAVE BEEN PRESCRIBED FOR USE IN PRESENTING BILLS FOR TRANSPORTATION AND RELATED SERVICES. THE ACCURACY OF THE CHARGES CLAIMED BY A BIDDER OR CONTRACTOR ON STANDARD FORM NO. 1034 CAN BE DETERMINED IN MANY INSTANCES BY THE APPLICATION OF THE UNIT PRICES STATED ON THE VOUCHER WITH THE UNIT PRICES SPECIFIED IN THE INVOLVED CONTRACT OR PURCHASE ORDER, AND BASIC ARITHMETICAL COMPUTATIONS, WHEREAS, THE DETERMINATION OF THE ACCURACY OF CHARGES CLAIMED FOR TRANSPORTATION AND RELATED SERVICES REQUIRES FAMILIARITY WITH AND THE USE OF VARIOUS CLASSIFICATIONS, EXCEPTIONS, TARIFFS, ROUTING GUIDES, SPECIAL RATE TENDERS, ETC., IN ORDER TO ARRIVE AT THE PROPER UNIT RATE, FARE, OR CHARGE. SUCH RATES MAY BE STATED IN CENTS PER 100 POUNDS, PER TON, PER CORD, PER GALLON, PER CARLOAD, OR OTHER UNIT OF MEASURE, AND MANY FACTORS ENTER INTO THE DETERMINATION OF WHICH ONE OF A GREAT MANY PUBLISHED RATES BETWEEN THE SAME POINTS OF ORIGIN AND DESTINATION SHOULD BE APPLIED ON ANY GIVEN SHIPMENT.

A FUNDAMENTAL DIFFERENCE ARISES ALSO FROM THE FACT THAT IN THE CASE OF THE PROCUREMENT OF MATERIALS, SUPPLIES, AND SERVICES, OTHER THAN TRANSPORTATION AND ACCESSORIAL SERVICES, THE GOVERNMENT REQUIRES THE ACCURACY OF THE CHARGES CLAIMED TO BE DETERMINED PRIOR TO PAYMENT, AND CERTIFYING OFFICERS OR DISBURSING OFFICERS ARE HELD ACCOUNTABLE FOR ANY EXCESSIVE OR IMPROPER PAYMENTS. IN THE CASE OF BILLS FOR TRANSPORTATION AND ACCESSORIAL SERVICES, HOWEVER, PAYMENT PRIOR TO AUDIT BY THE GENERAL ACCOUNTING OFFICE IS PERMITTED AS TO CARRIERS SUBJECT TO THE INTERSTATE COMMERCE ACT, AS AMENDED, AND CERTIFYING OFFICERS AND DISBURSING OFFICERS ARE EXPRESSLY RELIEVED FROM LIABILITY FROM ANY OVERPAYMENT FOR TRANSPORTATION ON GOVERNMENT BILLS OF LADING OR TRANSPORTATION REQUESTS WHEN SUCH OVERPAYMENT ARISES BECAUSE OF ERRORS IN RATES, CLASSIFICATION, OR FAILURE TO OBSERVE APPROPRIATE AGREEMENTS. SINCE THE EFFECT OF THE STATUTORY PROVISIONS PERMITTING THESE EXCEPTIONS IN FAVOR OF THE CARRIERS IS TO EXPEDITE PAYMENT THROUGH RELAXING THE PROCEDURES OF AUDIT APPLIED AND OBSERVED IN THE CASE OF OTHER VENDORS AND SUPPLIERS, IT WAS OUR VIEW, WHEN THE REGULATION HERE IN QUESTION WAS ISSUED, THAT IT WAS ONLY RIGHT AND PROPER TO REQUIRE CARRIERS TO CERTIFY THEIR BILLS AS TO THE CORRECTNESS OF THE TRANSPORTATION AND ACCESSORIAL SERVICE CHARGES CLAIMED BY THEM. WE BELIEVE THIS VIEW TO BE JUSTIFIED UNDER THE CIRCUMSTANCES.

THE POSSIBILITY OF A DISPARITY IN THE COST OF SUPPLIES AND MATERIALS AND OF THEIR TRANSPORTATION CHARGES, TO WHICH YOU REFER, DOES NOT APPEAR MATERIAL TO THE QUESTION OF CERTIFICATION FOR THE TRANSPORTATION SERVICES RENDERED.

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