Since the waiver was signed one year after the funds had already expired, would it be a breach of the Anti-Deficiency Act (ADA), the bona fide need rule in particular, to use the obligated 2011 RDT&E funds, or must we use current funds? Would this be considered an adjustment or a new requirement?
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Yes, we believe that you can no longer obligate the 2011 RDT&E funds that expired long before the waiver was signed. This is opinon only. Payments against travel regulations is not expertise found within DAU. Although our best guess is that this would be an adjustment, you need to contact www.defensetravel.dod.mil for needed expertise.