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  • Question

    Can we use FY13 3080 funds to purchase all of our equipment items and then FY14 3080 funds for the installation of those same items? These are not long-lead procurement items. The FMR indicates, "Procurement appropriations are used to finance investment items, and should cover all costs necessary to deliver a useful end item intended for operational use or inventory." This statement from the FMR implies installation costs are part of the "necessary" costs, but our assessment is since we are fully funded and we're only using one FY funding to complete the puchase of the items and another FY for the installation then we should be covered by the full funding policy.


    Answer

    Perhaps the best FMR reference for this issue is Vol 2B, Chapter 4, Exhibit P3a, page 4 of 5. That paragraph deals with modifications and describes how to budget for A kits and B kits.  It states: Installation. The installation costs should be portrayed in the year of actual installation so that the total cost of the installation is portrayed for each year’s procurement of end items. Procurement quantities and installation quantities reflected in the procurement detail should equal the quantity displayed in the installation schedule. 

    This FMR paragraph indicates there should be no problem using Other Procurement funds to fund the end item in one year and installation in another year.  Just ensure your budget justification materials reflect your intent.
    DAU actually has a case exercise in BCF211 where a modification kit is purchased in one fiscal year and the installation is funded in the following fiscal year.

    When in doubt, confirm with your local comptroller or your acquisition legal assistance office.


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