TABLE OF CONTENTS
| Topics | Sections |
|---|---|
| OVERVIEW | 9.1 What is the purpose of this chapter? 9.2 What is the scope of this chapter? 9.3 What is the overall policy? 9.4 What are the authorities for this chapter? 9.5 What terms do you need to know to understand this chapter? 9.6 What types of miscellaneous obligations (MO) does the Service process? |
| RESPONSIBILITIES | 9.7 Who is responsible for the Service’s MOs? |
| MISCELLANEOUS OBLIGATION REQUIREMENTS AND LIMITATIONS | 9.8 What are the backup documentation requirements for each MO type? 9.9 For what types of transactions must employees NOT use the MO process? 9.10 What are the responsibilities associated with the AP_MO role in the Financial and Business Management System (FBMS)? |
| FHWA POINT OF OBLIGATION (POB) PROCESS | 9.11 What is a Federal Highways Administration (FHWA) point of obligation (POB)? 9.12 How are POBs recorded in FBMS? 9.13 When is a POB MO reversed or de-obligated? 9.14 How long can the POB MO stay obligated in FBMS? |
| COMMITMENT ITEM | 9.15 What commitment item should employees use on an MO? |
| WAIVER REQUIREMENTS | 9.16 How does the AP_MO user apply for an exception to this policy? |
OVERVIEW
9.1 What is the purpose of this chapter? This chapter establishes U.S. Fish and Wildlife Service (Service) guidance and procedures for the use of miscellaneous obligations (MO) in the Financial and Business Management System (FBMS).
9.2 What is the scope of this chapter? This chapter applies to those employees who enter MOs in FBMS.
9.3 What is the overall policy? Since MOs are recorded in FBMS without an approval workflow, employees should only use them under limited circumstances, which require external approvals and supporting documentation attached to the transaction. The employee who creates an MO bears the responsibility for the accuracy and accountability of these actions.
9.4 What are the authorities for this chapter?
A. Federal Acquisition Regulation (FAR) (48 CFR).
B. Federal Highway Administration (FHWA) Accounting Handbook for Recipient Accounts, Attachment 1: Project Funds Management Guide for State Grants.
C. Federal Lands and Tribal Transportation Programs (23 U.S.C. 201).
D. Department of the Interior (Department) Miscellaneous Obligations Policy.
E. Department’s Acquisition, Assistance, and Asset Policy (DOI-AAAP).
F. Department’s Office of Financial Management, Inter-Intra Agency Agreement Handbook.
G. General Services Administration Acquisition Regulation (GSAR) (48 CFR Part 5).
H. Moving Ahead for Progress in the 21st Century Act (MAP-21), Federal Motor Carrier Safety Administration.
I. Principles of Federal Appropriations Law (i.e. The Red Book), U.S. Government Accountability Office.
9.5 What terms do you need to know to understand this chapter?
A. Accounts Payable Miscellaneous Obligations (AP_MO). Role in FBMS that creates MOs using the custom “Miscellaneous Obligation iView.”
B. Commitment item (budget object code [BOC]). Codes that drive the general ledger posting of individual transactions. The codes describe the nature of the service or article for which obligations are first incurred, regardless of the purpose, function, or program served. Users should refer to the Department's BOC definitions list and choose the code that best fits the transaction.
C. Intra-agency agreement. When the Service contracts with another bureau within the Department to obtain products or services.
D. Intra-governmental payment and collection (IPAC). A way for Federal agencies to transfer funds from one agency to another with standardized descriptive data.
E. Miscellaneous obligation (MO). A valid obligation that does not use the acquisition process in the Department’s financial system of record (i.e., travel, intra-agency agreements, etc.). Employees may only use MOs when they are authorized to do so for typical acquisition transactions (i.e., contract, grant, financial assistance, etc.).
F. PRISM. The Department's contract management system.
9.6 What types of MOs does the Service process? See Table 9-1.
Table 9-1: Types of MOs the Service Processes
| A. Commercial bills of lading (CBL) not related to a contract or employee relocation | J. Inter/intra-agency Personnel Act agreements (IPAs) |
| B. FHWA points of obligation (POB) (see section 9.11) | K. Inter/intra-agency travel agreements (ITAs) FWS Form 3-2368 |
| C. Fleet aviation services | L. Land acquisitions, including easements, rights of way. |
| D. Government bills of lading (GBL) not related to a contract or employee relocation | M. Micro-purchases using FBMS when a purchase card is not accepted, and that do not include sensitive property (optional) |
| E. GSA-leased space costs – Authorized until the GSA/Department of Homeland Security (DHS) rental obligation real property module is released in FBMS | N. Non-fleet aviation services (the Interior Business Center (IBC) distributes the IPAC charges and references the obligation) |
| F. GSA communication Non-NetWorx – Authorized until a new document type is established in FBMS | O. Office of Personnel Management (OPM) background investigations (optional) |
| G. GSA communication NetWorx – Authorized until implementation of the GSA Enterprise Infrastructure Solutions (EIS) | P. Printing and binding through the Government Printing Office (GPO) SF-1 – Authorized until a new document type is established in FBMS |
| H. GSA reimbursable work authorization (RWA) – Authorized until a new document type is established in FBMS | Q. Tort claims (optional) |
| I. Intra-agency agreements | R. Training courses/educational activities (using an SF-182) at or below the micro-purchase threshold when the purchase card is not accepted, and above the micro-purchase threshold up to and including $50,000 (see DOI-AAAP-0052) |
RESPONSIBILITIES
9.7 Who is responsible for the Service’s MOs? See Table 9-2.
Table 9-2: Responsibilities for the Service’s MOs
| This employee… | Is responsible for… |
|---|---|
| A. The Director | Approving or declining to approve Servicewide policy. |
| B. Assistant Director – Management and Administration (i.e., MA or Associate Chief Financial Officer) | (1) Maintaining and enforcing compliance with the MO policy, and (2) Submitting requests for exceptions to this policy to the Department (see section 9.16). |
| C. Joint Administrative Operations (JAO) Administrative Operations Center (AOC), Financial Operations Chief | (1) Recommending changes to the MO policy; (2) Ensuring OMB, Treasury, and Departmental MO policies are part of our policy; (3) Ensuring staff record and process MOs in the Service’s financial system; (4) Providing oversight and review of MOs in line with Departmental policy (e.g., reviews and certifications) to ensure that timely de-obligations occur as appropriate; and (5) Providing guidance on MO obligation policies and procedures. |
| D. JAO AOC Payments and Collections Chief | Providing guidance to field station personnel on MO policies and procedures. |
| E. Regional Chief Engineers | Ensuring POB obligations are properly approved and documented. |
| F. AP_MO Users | (1) Familiarizing themselves with and applying the authorities and procedures in this chapter (also see section 9.10); and (2) Ensuring, at a minimum, the following information is provided for each approved MO document: (a) The appropriate BOC(s); (b) A clearly documented period of performance (POP) that includes start and end dates where possible; (c) Name of the vendor providing the good(s) or service(s); (d) A description of the good(s) or service(s) that the vendor is providing; and (e) Authorized approving signatures. |
MISCELLANEOUS OBLIGATIONS REQUIREMENTS AND LIMITATIONS
9.8 What are the backup documentation requirements for each MO type? See Table 9-3.
Table 9-3: Backup Documentation Required
| Type | Documentation Required |
| A. CBLs | Signed CBL. |
| B. FHWA POBs | (1) Full packet of the construction plan; (2) Plans, specifications, and estimates (PS&E) document that the Regional Chief Engineer has signed; and (3) The Regional Transportation Coordinator’s approval of the funding. |
| C. Fleet aviation services | Signed Office of Aircraft Services (OAS) referencing sheet. |
| D. GBLs | Signed GBL (SF-1103). |
| E. GSA-leased space costs | Estimated leased space costs worksheet, signed by the Project Leader/Supervisor. |
| F. GSA communication Non-NetWorx | FWS Form 3-2366, Department of the Interior Inter/Intra-Agency Agreement (see 264 FW 2, Exhibit 1), signed by both agencies. |
| G. GSA communication NetWorx | FWS Form 3-2366, Department of the Interior Inter/Intra-Agency Agreement (see 264 FW 2, Exhibit 1), signed by both agencies. |
| H. GSA reimbursable work authorization (RWA) (paid outside of leased space) | Signed RWA (GSA Form 2957). |
| I. Intra-agency agreements and modifications | FWS Form 3-2366, Department of the Interior Inter/Intra-Agency Agreement (see 264 FW 2, Exhibit 1), signed by both bureaus. |
| J. IPAs | (1) Notification of Personnel Action (SF-50), or (2) Assignment Agreement (OF-69). |
| K. ITAs | Signed FWS Form 3-2368. |
| L. Land acquisition, including easements, rights of way | Signed contractual agreement between Realty Officer and seller (3rd party). |
| M. Micro-purchases (when the purchase card is not accepted) using FBMS, and that do not include sensitive property | (1) Approved Acquisition Request (FWS Form 3-2109) or equivalent documentation showing fund availability/certification for the estimated amount, and (2) Quote/invoice from vendor or equivalent documentation to support the MO. |
| N. Non-fleet aviation services | Signed OAS referencing sheet. |
| O. OPM investigations | Spreadsheet showing unbilled OPM investigations. |
| P. Printing and binding | Approved GPO printing request form (SF-1). |
| Q. Tort claims | (1) Report that shows the Service is obligated to pay the claim (if applicable), and (2) Court documents showing judgement against the Service (if applicable). Documents do not need to be uploaded in FBMS if they contain sensitive information. However, offices must maintain the supporting documentation in accordance with their procedures for handling sensitive information. |
| R. Training courses and educational activities (at or below the micro-purchase threshold when the purchase card is not accepted, and above the micro-purchase threshold up to and including $50,000 see DOI-AAAP-0052 Purchase of Training at DOI) | SF-182 approved by: (a) At or below the micro-purchase threshold when the purchase card is not accepted – Supervisor (b) Above the micro-purchase threshold up to and including $25,000 – Training Official (c) Above $25,000 up to and including $50,000 – Senior Training Official |
9.9 For what types of transactions must employees NOT use the MO process? Employees must not use MOs for the following types of transactions:
A. Agreements not signed by both parties.
B. Any of the following types of transactions (including when a charge card is used) that are subject to the FAR for procurements above the micro-purchase levels:
(1) Blanket purchase agreements (BPA),
(2) Commercial leased space,
(3) Contracts and modifications,
(4) Contracts studies,
(5) End-of-year acquisitions not processed through PRISM,
(6) Indefinite delivery/quantity contracts (IDIQ),
(7) Inter-agency agreements (not including GSA communication Non-NetWorx/Networx, GSA RWAs, IPAs, and ITAs, for which employees may use MOs),
(8) Photographic services,
(9) Realty transactions (e.g., title search, closings, fees, environmental tests, surveys),
(10) Relocation service contracts, and
(11) Task orders against IDIQs and BPA calls.
C. Employee-related expenditures for:
(1) Awards,
(2) Employee claims for reimbursement of official business expenditures (OF-1164),
(3) Payroll costs,
(4) Permanent change of station (PCS) costs,
(5) Temporary duty travel (TDY) costs, and
(6) Transit subsidy costs.
D. Estimated or future purchases (i.e., items or services that are forecasted). MOs signify a defined agreement where the Federal Government has an obligation to pay a defined amount for a defined service/good.
E. Express mail (e.g., FedEx), except when using GPO to obtain Government FedEx rates.
F. Financial assistance awards (i.e., cooperative agreements and grants).
G. Purchase of sensitive/controlled property (i.e., laptops, mobile devices, firearms, servers, desktops) regardless of cost.
H. GSA Advantage transactions over $2,500.
I. GSA motor vehicle purchases (AutoChoice).
J. Memorandums of Understanding (MOU).
K. Micro-purchases that can be made using the purchase card.
L. “Parking” of funding (i.e., saving prior year funds for a future purchase).
M. Split purchases.
N. Tentative quotes.
O. Training courses or other educational activities at or below the micro-purchase threshold when the purchase card is accepted.
P. Utilities (obligation is only allowed through a PRISM contract).
Q. Volunteer payments (FWS Form 3-2373).
R. Any other item/transaction not listed in Table 9-1.
9.10 What are the responsibilities associated with the AP_MO role in FBMS? The AP_MO is responsible for:
A. Using the “Custom MO” transaction to obligate funds.
B. Including a description of good(s) or service(s) that the vendor is providing.
C. Using the correct commitment item (budget object code).
D. Entering the period of performance start and end dates in the “Public Sector” tab.
E. Verifying that the “Goods Receipt” flag on the “Delivery” tab is not checked.
F. Entering the Trading Partner (TP) main account for Federal vendors.
G. Uploading supporting documentation as we describe in Table 9-3 – Backup Documentation Required.
H. Ensuring authorized approving signatures are obtained prior to obligation.
FHWA POINT OF OBLIGATION (POB) PROCESS
9.11 What is an FHWA POB? Title 23 U.S.C. 201 states that Federal agencies should recognize contractual obligations in the Highway Trust Fund when the plan, specifications, and estimates for construction of a project are approved. These obligations are referred to as POB documents.
9.12 How are POBs recorded in FBMS? We record POBs in FBMS:
A. As an MO using the “ZMOB” purchase document type.
B. Using a generic vendor code of “0071324230 MISCELLANEOUS VENDOR.”
C. Using commitment item 252H00 – Contractual obligations for point of obligation projects.
D. Attaching the following supporting documentation for the transaction:
(1) Full packet of the construction plan,
(2) PS&E document that the Regional Chief Engineer has signed, and
(3) The Regional Transportation Coordinator’s approval of funding.
9.13 When is a POB MO reversed or de-obligated? We must reverse or de-obligate a POB MO when we enter the formal obligation in FBMS through PRISM, which ties the obligation to an actual vendor.
9.14 How long can the POB MO stay obligated in FBMS? Although the legislation does not dictate a timeframe for how long POBs may remain before a contract is awarded, the Service is requiring that the transaction be awarded through PRISM within 120 days. If a POB extension is needed beyond 120 days, we will require a justification for the extension as part of the backup documentation.
COMMITMENT ITEM
9.15 What commitment item should employees use on an MO?
A. Employees must be careful when selecting the commitment item (budget object code) for an MO.
B. Never use commitment item 252Z00 – Contracts, Other.
C. Contact the Financial Operations payments and collections team with any questions about the appropriate commitment item.
WAIVER REQUIREMENTS
9.16 How does the AP_MO user apply for an exception to this policy?
A. The employee must submit an exception waiver request for an MO transaction that is not on the approved list in Table 9-1 through the Associate Chief Financial Officer (i.e., MA) to the Chief, Financial Policy and Data Analysis, at the Department’s Office of Financial Management for concurrence.
B. To request an exception, contact the Financial Operations payments and collections team for help with the process. In addition to counseling you about payment options, the team will require:
(1) The document or transaction type,
(2) A justification for the use of an MO, and
(3) Any associated supporting documentation.