B-45107, A-49009, AUG. 28, 1957

B-45107, A-49009, AUG. 28, 1957

TO HONORABLE FRANKLIN G. FLOETE, ADMINISTRATOR, GENERAL SERVICES ADMINISTRATION:

YOUR LETTER OF JULY 2, 1957, REFERS TO OUR GENERAL REGULATIONS NO. 134, DATED MARCH 11, 1957, AND STATES THAT THE ELIMINATION OF THE REQUIREMENT FOR VENDOR INVOICE CERTIFICATION PROMULGATED THEREBY, WHICH SIMPLIFIED BILLING PROCEDURES OF VENDORS AND FACILITATED THE PAYMENT OF BILLS AND INVOICES SUBMITTED TO THE GOVERNMENT, COULD PAVE THE WAY FOR CHANGES IN BILLING AND PAYMENT PRACTICES WHICH WOULD REPRESENT FURTHER SIMPLIFICATIONS.

YOU SUGGEST THAT AUTHORITY BE EXTENDED TO AGENCIES TO PAY AND/OR TO WORK OUT ARRANGEMENTS WITH VENDORS FOR PAYMENTS TO BE MADE UNDER THE FOLLOWING CIRCUMSTANCES WHENEVER SUCH AGENCIES ARE SATISFIED THAT PAYMENTS ARE DUE AND THAT APPROPRIATE STEPS HAVE BEEN TAKEN TO PREVENT DUPLICATE PAYMENTS:

1. INVOICE OR COPIES THEREOF SUBMITTED IN ACCORDANCE WITH VENDOR BILLING PRACTICES ALTHOUGH NOT IN ACCORDANCE WITH PRESENT REQUIREMENTS AS TO DESCRIPTION OF ARTICLES, UNIT COSTS OR OTHER ELEMENTS OF ITEMIZATION.

2. EXPANDED USE, UNDER PROPER CIRCUMSTANCES, OF AGENCY-VENDOR AGREEMENTS TO MAKE PAYMENTS WITHOUT THE NECESSITY FOR SUBMITTING INVOICES.

3. BY ARRANGEMENT WITH VENDORS, MAKE PAYMENT ON BASIS OF PERIODIC STATEMENTS CONTAINING SUFFICIENT INFORMATION TO IDENTIFY THE ACCOUNT TO BE PAID. SUCH STATEMENTS WOULD USUALLY BE ACCOMPANIED BY COPIES OF DELIVERY TICKETS OR OTHER DOCUMENTS USED IN COMMERCIAL PRACTICE.

OUR UNDERSTANDING IS THAT SUGGESTION (1) IS INTENDED TO COVER THOSE INSTANCES WHEN A VENDOR'S INVOICE OR BILL REFERS TO A PURCHASE ORDER INSTEAD OF CONTAINING DETAILED INFORMATION AS TO THE DESCRIPTION OF THE ARTICLES, UNIT COSTS, ETC., TOGETHER WITH INSTANCES WHEN THE VENDOR SENDS A CARBON COPY OF THE INVOICE RATHER THAN THE ORIGINAL BUT MARKS THE CARBON "ORIGINAL," THE INVOICES CONTAINING ALL THE REQUIRED DETAILS. IN EITHER CASE, THE DESCRIPTION OF THE ARTICLES, UNITS, AND UNIT COSTS, AS WELL AS RECEIVING REPORTS, ARE AVAILABLE TO THE AGENCY AND TO THE AUDITORS OF THE GENERAL ACCOUNTING OFFICE. BASED UPON THIS UNDERSTANDING, WE HAVE NO OBJECTION TO THIS SUGGESTION PROVIDED THERE IS NO DISCREPANCY BETWEEN THE ARTICLES SHIPPED AND THE PURCHASE ORDER. SEE 31 COMP. GEN. 649.

WE HAVE PERMITTED PAYMENTS WITHOUT CERTIFIED INVOICES FROM THE VENDOR IN CASES WHERE THERE IS A FIXED RECURRING PAYMENT AND THE AGENCY IS IN A POSITION TO VERIFY THAT THE AMOUNTS ARE DUE, SUCH AS RENTALS, JANITORIAL SERVICES, ETC. WE HAVE NO OBJECTION TO EXTENDING THIS ARRANGEMENT AS SUGGESTED IN ITEM (2) TO OTHER AREAS WHEN PAYMENTS ARE DEFINITE AS TO AMOUNT AND ARE DUE AT FIXED PERIODIC INTERVALS.

THE PROCEDURE SET OUT IN SUGGESTION (3) HAS BEEN IN EFFECT FOR SOME TIME. THE ONLY REQUIREMENTS ARE THAT THE PERIODIC STATEMENTS DEFINITELY IDENTIFY THE ARTICLES COVERED, UNIT COSTS AND TOTAL COSTS, EITHER ON THE STATEMENT ITSELF OR BY REFERENCE TO OTHER DOCUMENTS, AND THAT THIS INFORMATION BE READILY AVAILABLE TO BOTH AGENCY OFFICIALS AND THE AUDITORS OF THE GENERAL ACCOUNTING OFFICE.

THEREFORE, AUTHORITY IS HEREBY EXTENDED TO GOVERNMENT AGENCIES GENERALLY, TO PAY AND/OR TO WORK OUT AGREEMENTS WITH VENDORS FOR PAYMENTS TO BE MADE UNDER THE CIRCUMSTANCES AND CONDITIONS SET OUT ABOVE, SUBJECT TO REVIEW BY THE GENERAL ACCOUNTING OFFICE. IT IS TO BE UNDERSTOOD THAT WHAT IS SAID HEREIN IS NOT TO BE APPLIED TO BILLS AND INVOICES OF PERSONS, CORPORATIONS, OR AGENCIES FURNISHING THE GOVERNMENT WITH TRANSPORTATION AND ACCESSORIAL SERVICES AS TO WHICH THE REQUIREMENT OF VENDOR INVOICE CERTIFICATION WAS RETAINED IN GENERAL REGULATIONS NO. 134 OF MARCH 11, 1957.