Insert Title (2nd line if necessary)

Insert Title (2nd line if necessary)

Army's Use of Contractor DODAACs for GFM (Government Furnished Material) Defense Finance and Accounting Service Lori Peterson Systems Accountant LMP Integrity - Service - Innovation The Issue Army is citing Contractor DODAACs as bill-to party for Government Furnished Material (GFM) and citing fund codes which are associated with Army lines of accounting. Government pays for GFM Contractor DoDAAC TAC 3 actually directs bill to US Army When material is Contractor Furnished Material (vice GFM) contractor pays Those orders should correctly identify the contractor as the bill-to party and not cite an Interfund billing fund code Army is the predominate user of this practice, but other components may do the same FPRC Chair asked Army to brief the topic

02/28/2020 Integrity - Service - Innovation 2 Regulation According to MILSBILLS DLM 4000.25, Volume 4, April 11, 2012 which can found at: http:// www2.dla.mil/j-6/dlmso/elibrary/manuals/dlm/dlm_pubs.asp#v4_AP_1 C2.2.3.2. Billing shall be under noninterfund procedures when: C2.2.3.2.2. The bill-to office is a DoD contractor (Bill-To Service Code is C, E, HG, L, Q, SD, or U) or the fund code requires non-interfund billing (normally XP fund code). 02/28/2020 Integrity - Service - Innovation 3 Regulation

C2.2.3.3. Method of Billing Summary. Billing methods are summarized in Table C2.T1. Table C2.T1. Method of Billing Condition Number Billed DoDAAC Begins With: And Fund Code is: Then the Billing Method is: Method is: E, G, HG, HX, L, Q, SD, U, Z, or 1 C, numeric Any NON INTERFUND 2 Any Service code

XP or otherwise designates noninterfund NON INTERFUND 3H Not identified as eligible for interfund billing NON INTERFUND 4 Anything other than conditions described by 1, 2, or 3 INTERFUND AR 725-50 Ch 16 DOD Material Inventories required by Defense Contracts (GFM) also applies. 02/28/2020 Integrity - Service - Innovation 4 Issues

LMP (AWCF ERP) bills the C DODAAC by Interfund if the fund code is citing an Army appropriation which is not consistent with the regulations. Interfund billing is much more efficient and less costly to process than 1080 billing. GCSS-Army only has Interfund bills in scope and did not expect to see or process any 1080/IPAC billings. DLA bills this same situation as NON-INTERFUND. Bills sent directly to the Contractor address or 1080 IPAC process DLA has many aged open receivables. 02/28/2020

Integrity - Service - Innovation 5 Issues Continued Federal vs Non Federal determinations. Contractor DODAAC indicates Non Federal Army LOA is being billed indicates Federal. GFM vs CFM. Structure of transaction would indicate CFM; shows contractor bill-to Management Control Authority validation of authorized materiel may be problematic for some Components 02/28/2020 Integrity - Service - Innovation 6

Potential Solutions Change regulations to allow Interfund processing on C DODAACs if an appropriation is assigned to the signal fund code combination. Structure the transactions to designate the Government bill-to party either in the Supplementary Address or by using signal code C or L to direct the bill to the correct Government entity via the Fund Code to Billed Office DoDAAC Table. Are there sufficient fund codes available for signal code group C/L for each component? 02/28/2020 Integrity - Service - Innovation 7 Example Examples: DODAAC: CY0SJN SERVICE/AGENCY:US Army (USA)

AUTHORITY CODE: 00 - Requisitioner TAC 1: KELLOGG BROWN & ROOT SERVICES, INC 1080 ELDRIDGE PKWY HOUSTON TX 77077-2575 TAC 2: KELLOGG BROWN & ROOT SERVICES TASK AST BALKANS CAMP BONDSTEEL FERIZAJ KV KOSOVO TAC 3: DFAS ROME 13145 GCSS ARMY 325 BROOKS ROAD ROME NY 13441-4527 02/28/2020 Integrity - Service - Innovation 8

Example Example: Billed by interfund by LMP: A01AJ2E8540002910389 BX00011CY0SJN42542006BW90A0DJ41 PAPER TOWELS 122552LWXHAAD IV Billed by Non- interfund (1080) by EBS: A31SMSS5325011752185 EA00002CY0SJN41129504RW90A0DJ41 FASTENER ASSEMBLY,TURNLOCK 02/28/2020 Integrity - Service - Innovation 121132A SGA 9

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