TABLE OF CONTENTS
| Topics | Sections |
| OVERVIEW | 2.1 What is the purpose of this chapter? 2.2 What is the scope of this chapter? 2.3 What is the overall policy? 2.4 What are the authorities for this chapter? 2.5 What terms do you need to know to understand this chapter? |
| RESPONSIBILITIES | 2.6 Who is responsible for the Service’s Certifying Officers? |
| SURETY BONDS | 2.7 Are Certifying Officers eligible for a surety bond? |
| INTERNAL CONTROLS | 2.8 What controls over payments does the Service have? |
| LIABILITY | 2.9 What is a Certifying Officer’s liability? 2.10 What resources are available to Certifying Officers to determine the legality of a payment? 2.11 Are there types of payments that have limited liability for the Certifying Officer? 2.12 How do Certifying Officers receive relief of liability? |
OVERVIEW
2.1 What is the purpose of this chapter? This chapter defines the policy and procedures for authorized Certifying Officers for the U.S. Fish and Wildlife Service (Service).
2.2 What is the scope of this chapter? This chapter applies to all authorized Certifying Officers. The concepts of accountability and relief the chapter discusses apply only to authorized Certifying Officers who certify vouchers on which Disbursing Officers are to pay out money.
2.3 What is the overall policy?
A. The authorized Certifying Officer must sign all vouchers and schedules of payment.
B. We must not assign an employee to the position of authorized Certifying Officer without that employee completing prior appropriate training. The training must include orientation on the regulations that govern the duties and responsibilities of the position.
C. Only Federal employees are eligible to fill an authorized Certifying Officer position.
2.4 What are the authorities for this chapter?
A. Department of the Interior’s (Department) Office of Financial Management (PFM), Cash Management Handbook.
B. Federal Acquisition Regulation (FAR) (CFR Title 48).
C. Federal Managers’ Financial Integrity Act of 1982 (P.L. 97-255).
D. Money and Finance (31 U.S.C.).
E. Policy and Procedures Manual for Guidance of Federal Agencies: Title 7 – Fiscal Guidance, U.S. Government Accountability Office (GAO).
F. Principles of Federal Appropriations Law (the Red Book), GAO.
G. Prohibition Against Surety Bonds for U.S. Government Personnel (31 U.S.C. 9302).
H. Requests for Decisions of the Comptroller General (31 U.S.C. 3529).
I. Responsibilities and Relief from Liability of Certifying Officials (31 U.S.C. 3528).
J. Vouchers (31 U.S.C. 3325).
2.5 What terms do you need to know to understand this chapter?
A. Accountable Officers are individuals who the Service officially designates as responsible for the protection, custody, and use of public funds.
B. Approving Officials are individuals who review electronic or paper invoices and attest by signature or electronic means that cost data and amounts billed are correct and that services or goods have been received.
C. Authorized Certifying Officers are Federal employees that the Service designates in writing as responsible for certifying vouchers to the U.S. Department of Treasury (Treasury) that trigger payments by a Treasury Disbursing Officer. They are responsible for the existence and correctness of the facts recited in the certificate or otherwise stated on the voucher or its supporting documents, and for the legality of the proposed payment under the appropriation or fund involved. The authorized Certifying Officers are also accountable for and required to “make good” to the U.S. Government the amount of any illegal, improper, or incorrect payment resulting from any false, inaccurate, or misleading certificate made, as well as for any payment prohibited by law or which does not represent a legal obligation under an appropriation or fund.
D. Disbursing Officers are officers or employees of a Federal department that the agency designates to disburse money and render accounts in accordance with the laws and regulations.
RESPONSIBILITIES
2.6 Who is responsible for the Service’s Certifying Officers?
| These employees... | Are responsible for... |
| A. The Director | Approving or declining to approve Servicewide policy. |
| B. Assistant Director – Management and Administration (i.e., AD-MA or Associate Chief Financial Officer) | (1) Maintaining appropriate internal controls to process payments in the correct amount and payable to the proper vendor, and (2) Ensuring Certifying Officers maintain payment records according to the appropriate retention schedules (i.e., 6 years and 3 months) and that the records are available to the Department’s Office of Inspector General or the GAO for audit. |
| C. Joint Administrative Operations (JAO), Administrative Operations Center (AOC), Financial Operations Division Chief | (1) Designating authorized Certifying Officers on Treasury’s Designation for Certifying Officer form (FS Form 210CO) and forwarding the form to Treasury; (2) Completing Treasury’s Delegation of Authority form (FS Form 2958DO) and forwarding the form to Treasury; and (3) Renewing their delegation of authority with Treasury every 2 years from the effective date, unless revoked earlier. |
| D. JAO, AOC, Payments and Collections Branch Chief | Acting as a liaison between the Department’s Interior Business Center and Service personnel. |
| E. JAO, Headquarters, Policy, Economics, Risk Management, and Analytics (PERMA), Risk Management Branch Chief | Conducting periodic reviews of payment operations to ensure that requirements are being observed and the control structure structure Something temporarily or permanently constructed, built, or placed; and constructed of natural or manufactured parts including, but not limited to, a building, shed, cabin, porch, bridge, walkway, stair steps, sign, landing, platform, dock, rack, fence, telecommunication device, antennae, fish cleaning table, satellite dish/mount, or well head. Learn more about structure is effective. |
| F. Authorized Certifying Officers | (1) Completing Treasury’s Designation for Certifying Officer form (FS Form 210CO) and submitting the form to the Financial Operations Chief for approval; (2) Renewing their designation as Certifying Officer with Treasury every year from the effective date, unless revoked earlier; (3) Relying on the Service's system of internal controls to ensure the propriety of payments; (4) Avoiding personal liability by learning about and working with the Service’s internal control systems and complying with established procedures; (5) Determining that: (a) Funds are legally available for payment; (b) Services for which bills have been presented have been rendered; (c) Advancement of funds prior to the rendering of such services is legally proper; (d) Payment complies with all laws and Service regulations referenced in section 2.4; (e) Vouchers are correct; (f) Computations are correct; and (g) Amounts of any illegal, improper, or incorrect payments are not certified for payment; (6) Ensuring payment transactions that do not provide evidence of following established internal control procedures are not certified; (7) Returning payment transactions that are deficient to the appropriate administrative officials for correction; and (8) Certifying vouchers for payment. |
SURETY BONDS
2.7 Are Certifying Officers eligible for a surety bond?
A. We are prohibited by 31 U.S.C. 9302 from requiring or obtaining surety bonds for employees in connection with the performance of their duties.
B. We must assume the risk for fidelity losses (i.e., financial loss).
C. Personal liability still applies to employees.
D. Employees may purchase a personal bond for faithful performance through any bonding company, if desired, and at their own expense.
INTERNAL CONTROLS
2.8 What controls over payments does the Service have? We are required to have in place the appropriate, effective internal controls over disbursements that are both cost effective and practical. Our manual and automated controls include:
A. Control environment. We establish and maintain an environment where honesty and integrity are valued, and the highest ethical standards are upheld.
B. Separation of Duties (SOD). To the extent practicable, we must separate operations to reduce risk of error, waste, and wrongful acts. In the Financial and Business Management System (FBMS), we can achieve SOD by the assignment of different responsibilities by function. We should also ensure that disbursing operations are separated from such operations as purchasing, receiving, examining invoices, preparing vouchers, authorizing the hiring of employees, keeping time and attendance records, maintaining voucher registers or similar records, collections, and accounting.
C. Modern payment processes. In addition to internal controls, we use modern payment processes such as statistical sampling, fast payment (fast pay) procedures, electronic signatures, and records retention at remote sites.
D. Documentation. Our payment policies and procedures are documented here:
(1) Service Manual chapter 261 FW 3, Payments; and
(2) Payments and Collections team SharePoint site.
E. Expired appropriations. We have established special controls over payments from expired appropriations (see 260 FW 13).
F. Pre-payment audits. Certifying Officers audit and approve payments before certifying them for payment. Automated control procedures and computer-assisted audit techniques can provide viable alternatives to the traditional requirement for the 100% prepayment examination of payments.
LIABILITY
2.9 What is a Certifying Officer’s liability? Although Certifying Officers have no public funds in their possession, except as we describe in section 2.12 below, they are accountable for and required to repay the U.S. Government for:
A. The amount of any illegal, improper, or incorrect payment resulting from any false, inaccurate, or misleading certification they make; and
B. Any payment prohibited by law or that did not represent a legal obligation under the appropriation or fund involved.
2.10 What resources are available to Certifying Officers to determine the legality of a payment? Certifying Officers:
A. Have the right to apply for and obtain an advance decision by the Comptroller General of the United States (i.e., the Director of GAO) on any question of law involved in a payment on any voucher presented to them for certification. Advance decisions:
(1) Provide the official protection against legal liability;
(2) Must be supported by all documents and facts relevant to the decision; and
(3) Are deemed invalid (i.e., the Comptroller General will not grant the official relief or protection against liability) if the requesting official fails to present any known facts pertinent to the decision and the payment later becomes challenged and deemed illegal, improper, or incorrect.
B. May request that the Comptroller General make a determination whenever a notice of exception involves a doubtful question of law.
C. Must use assistance, such as from the Office of the Solicitor within the Department, to resolve doubtful questions of law prior to contacting the Comptroller General.
D. May rely upon written advice from the Department’s Office of the Solicitor for items of $100 or less.
E. Should consider whether the matter has had a previous ruling and is covered in a published or unpublished decision of the Comptroller General.
2.11 Are there types of payments that have limited liability for the Certifying Officer? Certifying Officers are not responsible for overpayments for transportation furnished on Government Bills of Lading or transportation requests when due to improper rates, classification, or failure to make proper deductions under a land grant law or agreement. (Liability still exists for mathematical errors, illegal payments, or errors made during the payment process.)
2.12 How do Certifying Officers receive relief of liability?
A. When a Certifying Officer certifies an improper or incorrect payment, the Comptroller General may grant relief. The Comptroller General may:
(1) Relieve a Certifying Officer of responsibility for the physical loss or deficiency of public money, vouchers, checks, securities, or records; or
(2) Authorize reimbursement from an appropriation or fund available for the activity in which the loss or deficiency occurred.
B. Certifying Officers acting in good faith and in conformity with an authorized control system or statistical sampling procedure will not be held liable for any certification or payment on a voucher that was not subject to specific examination because of the procedure.
C. Factors the Comptroller General considers are if:
(1) The obligation was incurred in good faith,
(2) No law specifically prohibited the payment,
(3) The U.S. Government received value for the payment,
(4) There is evidence that the payment is accurate and legal relating to an automated system rather than the individual transaction,
(5) Information shows that the system on which Certifying Officers rely is functioning properly, and
(6) There is evidence that reviews are made periodically to determine that the automated systems are operating effectively and can be relied on to produce payments that are accurate and legal.