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    Can a puchase be made with Army Working Capital Funds in Sep 2012 for items that will not be used until Sep 2013? Would this be considered and ADA violation?


    You would follow the usual bona fide need rules for your requirement.  You should be able to do your purchase if it is a bona fide need.  Please also check with your comptroller or counsel.  Chapter 12, page 114 of Volume III of the GAO redbook states: 
    •  Thus, the various rules discussed in Chapter 5 governing the obligation and expenditure of fixed-year appropriations with respect to time generally do not apply to receipts and collections that a revolving fund has earned through its operations. For purposes of comparison, the time availability of receipts and collections that a revolving fund earns through its operations, unless otherwise restricted by statute, is similar to that of a no-year appropriation—the money is "available until expended." This being the case, the rules for no-year appropriations provide a useful analogy. Under a no-year appropriation—and therefore a revolving fund as well—"all statutory time limits as to when the funds may be obligated and expended are removed." 40 Comp. Gen. 694, 696 (1961). Amounts earned and credited to the fund are treated as unobligated balances and are available for obligation the same as any other unobligated money in the fund. Id. at 697. Deobligated funds are treated the same way. B-200519, Nov. 28, 1980.

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