IN WHAT CIRCUMSTANCES CAN YOU USE RDT&E FUNDS TO PAY FOR PCS COSTS?
I KNOW ONR CAN USE THEIR RDT&E FUNDS, BUT IS THERE A GUIDANCE POLICY THAT DICTATES THE USE AND APPROPRIATION FOR PAYMENT OF PCS COSTS.
The question posed concerns the use of RDT&E to pay for PCS costs. In reviewing the Financial Management Regulation (FMR) 7000.14-R, two chapters are pertinent to answer the question. The first is Volume 2A Chapter 1 and the second is Volume 2A Chapter 2.
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FMR 7000.14-R Volume 2A Chapter 1 explains the definition of expenses which RDT&E is comprised of both expenses and investments. In reviewing Chapter 2A there is no identification of being able to use RDT&E funds for PCS moves. The next FMR 7000.14-R Volume 2A Chapter 2 explains the use of MILPERS for military personnel and explains that PCS travel costs would be issued under the MILPERS appropriation.
DoD 7000.14-R Financial Management Regulation Volume 2A, Chapter 1
D. Procedures for Determining Expenses Versus Investments.
The following criteria will be used to distinguish those types of costs to be classified as expenses from those to be classified as investments for budgeting purposes:
1. 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. Military personnel costs are an exception to this rule. The following guidelines shall be used to determine expense costs:
a. Labor of civilian, military, or contractor personnel.
b. Rental charges for equipment and facilities.
c. Food, clothing, and fuel.
d. Supplies and materials designated for supply management of the Defense Working Capital Funds.
e. Maintenance, repair, overhaul, rework of equipment.
f. Assemblies, spares and repair parts, and other items of equipment that are not designated for centralized item management and asset control and which
have a system unit cost less than the currently approved dollar threshold of $250,000 for expense and investment determinations. This criterion is applied on the basis of the unit cost of a
complete system rather than on individual items of equipment or components that, when aggregated, become a system. The concept of a system must be considered in evaluating the
procurement of an individual end item. A system is comprised of a number of components that are part of and function within the context of a whole to satisfy a documented requirement. In
this case, system unit cost applies to the aggregate cost of all components being acquired as a new system.
g. Cost of incidental material and items that are not known until the end item is being modified are conditional requirements and are considered expenses
because the material is needed to sustain or repair the end item.
h. Engineering efforts to determine what a modification will ultimately be or to determine how to satisfy a deficiency are expenses.
i. Facilities sustainment, O&M-funded restoration and modernization projects. Planning and design costs are excluded from the cost determination for
purposes of determining compliance with the amounts established in 10 U.S.C. 2805 for minor construction projects; however, design costs are not excluded from capitalization.
DoD 7000-R Financial Management Regulation Volume 2A, Chapter 2
5. Permanent Change of Station (PCS) Travel - For expenses incident to permanent change of station travel of military personnel, individually or as part of organized units. The PCS travel costs include mileage; monetary allowance in lieu of transportation; transportation by common carrier (rail, bus, air, or water, including Air Mobility Command and Military Sealift Command); per diem allowances, actual and necessary expenses and cost of subsistence while in a PCS travel status; issue of meal tickets in lieu of subsistence; temporary lodging expense; travel of dependents and transportation of baggage and household goods, port handling charges for personnel, their household goods, baggage and privately owned automobiles passing through CONUS MTMC terminals; payments of dislocation allowances; authorized transportation of dependents and personal and household effects of deceased military personnel; costs of contract packing, crating, handling and temporary storage of household goods; cost of non-temporary storage of household goods; cost of trailer allowances; travel incident to organizational movements on permanent change of station whether for training or non-training purposes; expenses incident to PCS movement of any military group traveling under one order from the same point of origin to the same destination; minor supplies and services incident to troop or organizational PCS movements; expenses and allowances incident to separation travel, discharge or release. Also included is all authorized Temporary Duty Travel directly related to and an integral part of PCS movement of individuals or organizational units. Excludes Temporary Duty Travel other than that directly related to and an integral part of PCS movements. All authorized PCS travel expenses provided for under this budget program account shall be charged to the same subprogram account cited in PCS travel order of the military member. The term ”CONUS” (Continental United States) referred to herein applies to the United States Territory, ”including the adjacent territorial waters located within the North American Continent between Canada and Mexico.”
I strongly recommend you contact your local Comptroller/BFM or legal office for further guidance on the question posed. You should also review the budget exhibits that were prepared and approved which should contain information if the PCS costs were included in the RDT&E budget exhibits.