B-61938, APR 6, 1962

B-61938: Apr 6, 1962

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SECRETARY: WE HAVE RECEIVED A LETTER DATED FEBRUARY 8. SUPPORTING DOCUMENTS AND RELATED PERSONNEL RECORDS FOR UNITS TO WHICH OFFICERS OF THE ACTIVE FORCE ARE NOT ASSIGNED. ALSO SOME AIR NATIONAL GUARD MEMBERS REMAINING WITHIN A STATE AFTER THEIR UNIT HAS BEEN ACTIVATED ARE WITHOUT AN OFFICER OF THE ACTIVE FORCE SINCE SUCH OFFICER WOULD BE PLACED ON DUTY WITH THE FEDERALIZED UNIT OR TRANSFERRED. OUR CONCURRENCE WAS BASED IN PART ON THE CONCEPT AS ADVANCED BY THE DEPUTY COMPTROLLER FOR ACCOUNTING. THE PROPOSED ACTION WOULD REMOVE THIS CONTROL FEATURE BY PLACING THE RESPONSIBILITY FOR CERTIFYING PAYROLLS IN AN INDIVIDUAL WHO WOULD ALSO HAVE ACCESS TO THE CHECKS AND BE RESPONSIBLE FOR THEIR DISTRIBUTION.

B-61938, APR 6, 1962

PRECIS-UNAVAILABLE

MR. SECRETARY:

WE HAVE RECEIVED A LETTER DATED FEBRUARY 8, 1962, FROM THE ASSISTANT SECRETARY OF THE AIR FORCE REQUESTING AUTHORITY FOR AIR FORCE RESERVE AND AIR NATIONAL GUARD OFFICERS NOT ON EXTENDED ACTIVE DUTY TO CERTIFY PAYROLLS, SUPPORTING DOCUMENTS AND RELATED PERSONNEL RECORDS FOR UNITS TO WHICH OFFICERS OF THE ACTIVE FORCE ARE NOT ASSIGNED. PROCEDURES APPROVED BY THIS OFFICE ON SEPTEMBER 10, 1954, B-61938, REQUIRED SUCH DOCUMENTS TO BE CERTIFIED BY AN OFFICER OF THE REGULAR ESTABLISHMENT.

THE LETTER STATES THAT SINCE THAT TIME, IT HAS BEEN DECIDED THAT CERTAIN RESERVE UNITS WOULD BE STAFFED ENTIRELY BY RESERVISTS NOT ON EXTENDED ACTIVE DUTY. ALSO SOME AIR NATIONAL GUARD MEMBERS REMAINING WITHIN A STATE AFTER THEIR UNIT HAS BEEN ACTIVATED ARE WITHOUT AN OFFICER OF THE ACTIVE FORCE SINCE SUCH OFFICER WOULD BE PLACED ON DUTY WITH THE FEDERALIZED UNIT OR TRANSFERRED. IN EACH OF THESE INSTANCES THERE WOULD NOT BE AN OFFICER ON EXTENDED ACTIVE DUTY AVAILABLE TO SERVE AS CERTIFYING OFFICER.

IN OFFICE LETTER A-7621, A-8256 DATED APRIL 9, 1958, WE INTERPOSED NO OBJECTION TO THE CHANGE INSTITUTED BY THE AIR NATIONAL GUARD TO PROVIDE FOR DELIVERY OF CHECKS TO MEMBERS THROUGH THEIR UNIT COMMANDERS. OUR CONCURRENCE WAS BASED IN PART ON THE CONCEPT AS ADVANCED BY THE DEPUTY COMPTROLLER FOR ACCOUNTING, FINANCE, AND AUDIT POLICY IN HIS MEMORANDUM OF DECEMBER 11, 1959, THAT THE INDEPENDENT VERIFICATION AND CERTIFICATION OF THE PAYROLLS NOW PERFORMED BY THE AIR ADVISOR WITH EACH UNIT PROVIDES ADEQUATE INTERNAL CONTROL OVER WEAKNESSES INHERENT IN A SYSTEM WHICH PROVIDES FOR INDIRECT DELIVERIES OF CHECKS. THE PROPOSED ACTION WOULD REMOVE THIS CONTROL FEATURE BY PLACING THE RESPONSIBILITY FOR CERTIFYING PAYROLLS IN AN INDIVIDUAL WHO WOULD ALSO HAVE ACCESS TO THE CHECKS AND BE RESPONSIBLE FOR THEIR DISTRIBUTION.

WE UNDERSTAND THAT CURRENT PROCEDURES IN EFFECT IN AIR FORCE RESERVE UNITS PROVIDE FOR CHECKS PREPARED FROM PAYROLLS CERTIFIED BY UNIT CERTIFYING OFFICERS TO BE MAILED DIRECTLY TO THE PAYEES BY THE FINANCE OFFICERS. THIS SYSTEM ASSURES THAT CERTIFICATION DUTIES AND CHECK DISTRIBUTION DUTIES ARE NOT VESTED IN THE SAME INDIVIDUAL. IT APPEARS THAT THE PROPOSED CHANGE WOULD NOT AFFECT THIS ARRANGEMENT.

IN VIEW OF THE ABOVE WE WILL NOT OBJECT TO ACTION TO DESIGNATE COMMANDERS AND DEPUTY COMMANDERS OF AIR FORCE RESERVE UNITS AS CERTIFYING OFFICERS AND ALTERNATE CERTIFYING OFFICER, RESPECTIVELY, WHEN OFFICERS OF THE REGULAR ESTABLISHMENT ARE NOT AVAILABLE FOR SUCH DUTIES. HOWEVER, WE DO NOT APPROVE THE PROPOSED ACTION WITH RESPECT TO THE AIR NATIONAL GUARD UNLESS CONTROL FEATURES ARE INSTITUTED TO PROVIDE FOR A SEPARATION OF PAYROLL CERTIFICATION AND CHECK DELIVERY RESPONSIBILITIES.

A COPY OF THIS LETTER IS BEING FORWARDED TO THE SECRETARY OF THE AIR FORCE.

ENCLOSURE

MR. SECRETARY:

ENCLOSED IS A COPY OF OUR LETTER TO THE SECRETARY OF DEFENSE RELATIVE TO CERTAIN CHANGES IN PROCEDURE FOR THE CERTIFICATION OF PAYROLLS OF THE AIR FORCE RESERVE AND THE AIR NATIONAL GUARD. OUR LETTER PERTAINS TO THE PROPOSAL MADE IN LETTER OF FEBRUARY 8, 1962, FROM THE ASSISTANT SECRETARY OF THE AIR FORCE.