After discussions with the program personnel, these additional facts were gathered:

The radios in question, are currently in operation by multiple programs/platforms and are fully developed.  The only development activity required is to integrate the radios and utilizing them in some testing activity.

Budget Activity 7 is intended for development efforts to upgrade systems that have been fielded or have received approval for full rate production and anticipate production funding in the current or subsequent fiscal year. All items are major line item projects that appear as RDT&E Costs of Weapon System Elements in other programs. Program control is exercised by review of individual projects. Programs in this category involve systems that have received Milestone C approval. A logical progression of program phases and development and production funding must be evident in the FYDP, consistent with the Department's full funding policy.

This appears to be consistent with the intent of the program office asking the question.  One additional recommendation would be to make sure the R Documents that were submitted to Congress for approval of these RDT&E funds in BA 7, are consistent with what is planning to be done.  That is to ensure we are not using the RDT&E funds differently than what we told Congress we were going to do when we submitted the request.

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Question Title: 3600 RDT&E Budget Appropriations

Question Background: Current Situation: The program office needs to procure two TKI radios via a MIPR through another military department.  The radios are a 12 month long-lead item and funding needs to be sent before 31 July; a yearly ordering cycle. 

Issue:

The program expects to receive MDD approval within the next few weeks, the Milestone B approval is not expected until after this 31 July date.  If the order is not placed by this date, then either a solution to obtain these radios will need to be found or the program schedule will slip by 12 months.  Currently, the program is listed on the FY20 PB as a new start with the BPAC coding of 67____.  During our recent MDD briefing, the following question was posed “do we have the appropriate RDT&E funds available for this effort”.

The second digit within the BPAC, budget activity, is 7 therefore representing Operation System Development.  There are multiple RDT&E budget activities accordingly to FMR Volume 2B section 050201.  One of the budget activities is Budget Activity 4, Advanced Component Development and Prototypes (ACD&P). 

Question: If the MDD approved is obtained, are we committing any regulatory mistakes by assuming we have the correct RDT&E budget appropriation.  Is the currently BPAC correct or should be start with 64_____?