Is there any guidance on whether or not delegations of authority can specify the title or positions of the personnel accepting assets rather than listing each individual? Thanks for your help.
When it comes to Financial Improvement and Audit Readiness (FIAR), the Office of the Secretary of Defense’s (OSD) guidance is contained in their "FINANCIAL IMPROVEMENT AND AUDIT READINESS (FIAR) GUIDANCE (November 2013)", located on-line at: http://comptroller.defense.gov/Portals/45/documents/micp_docs/Reference_Documents/FIAR_Guidance-2013_November.pdf
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More specific guidance for each service, which for you as a Navy command would come from the Office of the Assistant Secretary of the Navy, Financial Management and Comptroller, Office of Financial Operations (FMO) office, is also available on-line at: http://www.fmo.navy.mil/Divisions/FMO4/financial_improvement_program.html
To achieve FIAR objectives, the Under Secretary of Defense (Comptroller) (USD(C)) designated two priorities in their guidance, as follows:
1) Budgetary Information
2) Mission Critical Asset Information
The second priority, which is to be addressed during “Wave 3” of the overall FIAR effort, focuses improvement and audit readiness efforts on information that is essential to the effective management of the Department’s mission critical assets. For purposes of this priority, mission critical assets are the following:
- Military Equipment (ME) (e.g., ships, aircraft, combat vehicles);
- Real Property (RP) (e.g., land, buildings, structures, construction in progress, facilities);
- Inventory (INV) (e.g., rations, supplies, spare parts, fuel);
- Operating Materials and Supplies (OM&S) (e.g., ammunition, munitions, missiles);
- General Equipment (GE) (e.g., material handling equipment, training equipment, special tooling, and special test equipment).
As such, when reviewing the OSD guidance towards answering your specific question, focus was placed on this wave 3 effort for Mission Critical Asset Information (specifically, General Equipment). In reviewing both the OSD and FMO guidance, there seems to be nothing that gets nearly that specific as to prescribe whether or not delegations of authority (DOA) can specify the title or positions of the personnel accepting assets rather than listing each individual (in fact, I cannot even locate the FIAR requirement that you state in your AAP question ("FIAR requirement for General Equipment states that individuals who accept and sign forms such as DD250, DD1348-1A or DD1149 must have a written delegation of authority."). The closest thing that I was able to find was the following:
OSD's "FINANCIAL IMPROVEMENT AND AUDIT READINESS (FIAR) GUIDANCE (November 2013)" states that: Contract documentation, including (for base assets and asset modifications) includes: Receiving report or other acceptance document (e.g., DD250 (Materiel Inspection and Receiving Report) or DD1354 (Transfer and Acceptance of DoD Real Property).
Obviously, this is more general than what your requirement seems to be. In fact, neither the OSD nor FMO guidance address DOA’s whatsoever. As such, we are left to conclude that such a specific requirement reflects either your local command policy to meet the more general OSD audit guidance, or FMO’s guidance provided directly to your command. In discussions with the question submitter, it was revealed that this specific FIAR requirement for General Equipment that individuals who accept and sign forms such as DD250, DD1348-1A or DD1149 must have a written DOA, was coming directly from FMO, as when they conduct their FIAR testing, they are looking for DOAs which name the individual accepting an asset or equipment. Remember, service policy can always be more restrictive than higher OSD policy so long as it is in compliance with it, so such direction from FMO is perfectly allowable. Also note that specific FIAR guidance from the services has been changing to incorporate lessons learned from other commands and services as their audits are successfully completed.
I was also able to come across some completed sample DOA forms that list "multiple" individuals, but still "individuals", vice position:
http://www.marines.mil/Portals/59/Publications/NAVMC 4000.5 .pdf
(see page 93)
Furthermore, you can also see when reviewing the DOA form that the Marine Corps used (NAVMC 11869), blocks 4-8 require the listing of actual individual names and signatures, vice positions:
NAVMC 11869 form (Delegation of Authority):
You also stated that the new corrective action plan (CAP) that you are still working with FMO on requires that the DOA should be on a DD577, which as you can see from the form itself, would also be for each individual (http://www.hqmc.marines.mil/Portals/137/DD-Form 577_ID Number Fillable.pdf):
In conclusion, while there appears to be no specific written guidance on whether or not DOA’s can specify the title or positions of the personnel accepting assets rather than listing each individual, the form being used by FMO, as well as the individual guidance they have provided directly to your command, all support their desired requirement to have DOA’s for each individual. I further advise you to continue to work this issue directly with Navy’s FMO office to identify the best way to meet this requirement.