Should the travel costs for the active duty personnel to conduct the engineering and installation be charged to the Procurement funds (vice Operations and Maintenance). My research seems to indicate the Engineering and Installation costs of Procurement funded items are chargeable to the Procurement appropriation as follows:
1. DODFMR, V2, Chap 1, paragraph 010201.D.3.j: equipment engineering and assembly are chargeable to procurement
2. DODFMR, V2, Chap 1, paragraph 010201,D.3.k: When investment equipment is to be installed in real property facility, the costs of both the equipment and its installation are considered investments.
3. DODFMR, V2, Chap 1, paragraph 010201,D.3.e: outfitting of an investment item to make it ready to operate is part of the initial investment cost
4. AFI65-601V1, paragraph 8.17.3: Installation costs of investment items are funded with investment funds.
5. AFI65-601V1, paragraph 8.19: Engineering and Installation costs are chargeable to investment.
Couple of additional items of guidance:
1. Full Funding of Procurement Programs guidance (DODFMR, V2, Chap 1, paragraph 010202) addresses the requirement to capture the entire cost of a Procurement item. Recording the Engineering and Installation piece in any appropriation other than Procurement would appear to violate the intent of that doctrine.
2. Defense Acquisition University guidance states...Procurement Appropriations are used to finance Investment items, and should cover all costs necessary to deliver a useful end item intended for operational use. That would seem to include Engineering and Installation costs of the investment item.
You have done all the proper research and have appropriately cited all the applicable rules/regulations regarding proper use of appropriations for different purposes. It is proper to use Procurement funds to install the equipment that was purchased with Procurement funds. Therefore, it is appropriate to pay for the travel to have active duty personnel install the equipment with the funds appropriated to pay for the installation costs (in this case Procurement funds). This all assumes that the dollars were intended for this purpose, meaning that in the Procurement documentation to Congress (P-Docs) that we let Congress know the purpose of the requested funds. If the documentation to Congress did not state/indicate that we intended to use the Procurement dollars for the installation of this system, I highly recommend consulting with a fiscal law trained attorney to ensure we are not violating any fiscal laws.
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