At what point do ARMY Aircraft Tech Manuals(TM), Interactive Electronic Technical Manuals (IETM) and Publications go from being funded with Procurement dollars to Operations and Maintenance dollars. Additionally, if a fielded aircraft is cycled through a Procurement funded modification line that inserts new technology, what color of money funds the updates to the manuals?
If the procurement funding was provided for the purpose of updating the IETM, then procurement funding should be used; however, at the point that the program goes into sustainment the cost would then become an expense and O&M funding would be used. DoD Financial Management Regulation Volume 2A, Chapter 1, Section 0102 outlines the criteria for determining expenses and investment costs.
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Section 010201, D, 3 states: Costs budgeted in the Operation and Maintenance (O&M) and Military Personnel appropriations are considered expenses. Costs budgeted in the Procurement and Military Construction appropriations are considered investments. Costs budgeted in the Research, Development, Test and Evaluation (RDT&E), Base Realignment and Closure (BRAC), and Family Housing appropriations include both expenses and investments.
Section 010201, D, 1 states: Expenses. Expenses are costs of resources consumed in operating and maintaining the Department of Defense. When costs generally considered as expenses are included in the production or construction of an investment item, they shall be classified as investment costs.
3. Conditional Cases. The following are conditional cases that take precedence over the criteria contained in paragraphs 1 and 2 above:
Section 010201, D, 3, j states: The cost of civilian personnel compensation and other direct costs (i.e., travel, office equipment leasing, maintenance, printing and reproduction) incurred in support of procurement and/or production programs by departmental headquarters staff, contracting offices, contract audit offices, system project offices, and acquisition managers are expenses. Procurement and/or production direct support costs such as production testing, quality assurance, production engineering, and equipment assembly, whether performed under contract or by in-house personnel funded on a reimbursable basis are investments.
You also want to look at your budget exhibits to see where this work was budgeted since this should help you identify which funding should be used. You may wish to consult with your local comptroller office or your local legal office to get their interpretation of which section of the FMR prevails.