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    As Air Force weapon systems (weapons systems listed on the Acquisition Master List or AML) make migrations to the cloud for their applications (Air Force Distributed Common Ground System - AF DCGS is a prime example), the Centralized Asset Management (CAM) office have determined that paying for cloud capacity is NOT a 3400 sustainment/CAM bill. They have determined that there is no appropriate Element of Expense Investment Code (EEIC) that allows for CAM funding to fund cloud capacity and that is an O&M bill at the unit level. Is paying for cloud capacity a CAM/3400 bill for weapon system sustainment? Is there precedence for 3400/CAM funding to pay for Cloud Capacity for a weapons system in sustainment?


    This response is based on the information provided.  We suggest you discuss with your finance team, program manager and/or legal department as appropriate.


    The Financial Management Regulation (FMR) 7000.14-R Volume 2A Chapter 1 Paragraph 010201 funding for cloud services would be considered an expense.  Per the FMR 7000.14-R “Expenses are costs of resources consumed in operating and maintaining the Department of Defense.”

    From a statutory/regulatory perspective, sustainment cloud services is properly categorized as an expense.  Your query is not question of categorization, but one regarding who is responsible.  We have no opinion on that, it is an Air Force determination.

    To pursue the issue further your unit needs to involve your financial team, legal office, and program manager to make your case.    We suggest you review the Air Force FY 2020 budget exhibits to determine who requested the funds (CAM or unit) to pay for cloud services or services that cloud is replacing.

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