Coast Guard--Electronic Certification Procedures, B-302789, July 6, 2005

Case: B-302789 Agency: Protester: Coast Guard Date: 2005-07-06 Appropriations Law
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B-302789 Jul 06, 2005 Jump To VIEW DECISION DOWNLOADS RELATED PAGES GAO CONTACTS Highlights The Commanding Officer of the U.S. Coast Guard Finance Center (Center) has requested our decision regarding appropriate separation of duties for the electronic certification procedures used by the Center for certifying and transmitting vouchers to the Department of the Treasury for payment. Letter from Captain Loren P. Tschohl, Commanding Officer, U.S. Coast Guard, Finance Center, to Tom Armstrong, U.S. Government Accountability Office, March 16, 2004 (Tschohl Letter). Currently, the Center transmits a schedule of vouchers to Treasury for payment, and a Center certifying officer confirms the total number of vouchers, and the total amount of these vouchers, listed on the schedule. Occasionally, that certifying officer may also have certified individual vouchers listed in the schedule. View Decision B-302789, Coast Guard--Electronic Certification Procedures, July 6, 2005 Decision Matter of: Coast Guard--Electronic Certification Procedures File: B-302789 Date: July 6, 2005 DIGEST 1. Under the Coast Guard Finance Center's electronic certification system, the same certifying officer who approves the transmission of schedules of vouchers to Treasury for disbursement may also have certified individual vouchers included in the schedule. The government's risk of loss due to error, waste, or wrongful act is not jeopardized by a certifying officer's confirmation of totals on the schedule of vouchers that may include vouchers he or she individually certified. 2. A certifying officer who approves a schedule of payments transmitted to Treasury for disbursement is responsible only for errors made in the processing of the voucher schedule. DECISION The Commanding Officer of the U.S. Coast Guard Finance Center (Center) has requested our decision regarding appropriate separation of duties for the electronic certification procedures used by the Center for certifying and transmitting vouchers to the Department of the Treasury for payment. Letter from Captain Loren P. Tschohl, Commanding Officer, U.S. Coast Guard, Finance Center, to Tom Armstrong, U.S. Government Accountability Office, March 16, 2004 (Tschohl Letter). Currently, the Center transmits a schedule of vouchers to Treasury for payment, and a Center certifying officer confirms the total number of vouchers, and the total amount of these vouchers, listed on the schedule. Occasionally, that certifying officer may also have certified individual vouchers listed in the schedule. We conclude that the Center is not required to separate the function of certifying individual vouchers from the function of confirming the total number of vouchers. As explained below, the former function is a certification function to which pecuniary liability attaches. The latter is simply a check permitting Treasury disbursing officers to disburse without having to examine each voucher--it is evidence that the disbursement amounts processed by Treasury agree in summary with the voucher amounts submitted by the Coast Guard. BACKGROUND The Coast Guard Finance Center (Center) certifies invoices and transmits electronic files of those invoices to the Department of the Treasury for payment. Under the Center's procedures, numerous authorized certifying officers (ACO) individually certify hundreds of invoices for payment daily. Tschohl Letter. These certified invoices are entered into the Coast Guard's core accounting system, Oracle Financials. Id . Each day a person from the Center's Systems Division generates what the Coast Guard calls a "payment file" from Oracle Financials based on invoice payment dates. Id. The payment file lists certified vouchers scheduled for payment on a given date. The payment file is electronically transmitted to Treasury on the day before the payment date. Id. Approximately 30 to 45 minutes following transmittal, Treasury sends to the Center something it calls a pre-edit report. Tschol Letter. The pre-edit report shows the total number of payments and the total dollar amount of payments that Treasury received electronically from the Center. Letter from Loren P. Tschohl, Captain, U.S. Coast Guard, to Thomas H. Armstrong, Assistant General Counsel for Appropriations Law, August 19, 2004 (Second Tschol Letter). The Center checks Treasury's pre-edit report totals against the totals sent by the Center. Id. If the pre-edit report totals match the totals that the Center sent to Treasury, a Center accounting technician enters the certified invoices that were listed in the payment file into Treasury's electronic certification system (ECS). A certifying officer, who may have certified individual invoices, checks the total number of invoices and the total payment amount as entered by the accounting technician to be sure that these totals match the totals of the Treasury pre-edit report. The officer then approves transmission to Treasury for disbursement.

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