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    Can the IG office obligate funds without prior approval through the normal GPC authorizing process (i.e. through the Approving Official)? If not, is it legal to pay the invoice using the GPC more than 5 months after services were performed but never approved?


    Nobody who has not been officially appointed as a contracting officer with a warrant or as a GPC card holder can legally obligate federal funds. The IG office cannot obligate funds until and unless a person who can officially obligate funds actually does so. The invoice can be paid through the ratification process if the requirements at FAR 1.602-3 are met. The fact that the services were performed in the current fiscal year simplifies things a bit. And of course, be certain to work directly with your activity's legal counsel on the matter.

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