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    In an FMS Admin funded position is there a percentage threshold for how much of my time can be spent performing non fms duties?


    Answer

    We consulted with our colleagues at the Defense Security Cooperation University (DSCU), who provided the following information:

    The definition of a "FMS full-time employee" is contained in the DoD Financial Management Regulation (FMR) Vol 15 (Security Cooperation Policy, https://comptroller.defense.gov/Portals/45/documents/fmr/Volume_15.pdf) Chapter 8 Section 080702 which states FMS full-time employees are DoD MILPERS or CIVPERS whose "full-time is 90 percent or more of their time spent on FMS".

    The FMR also contains guidance on DoD MILPERS and CIVPERS who work 'part-time' on FMS Admin or FMS case efforts. Just because an employee is not "FMS full time", any effort in support of FMS activities still needs to be charged.  FMR VOL 15 Chapter 7 Section 070502 (DoD Component Administrative Expenses) states "DoD organizations that provide general administrative support to the FMS program must recoup the full cost (excluding a pro rata share of fixed base operations costs) to provide such support. "  Additionally, that same FMR section states "The personnel portion of actual administrative expenses must include a pro rata share of those personnel who spend 10 percent or more of their time performing FMS duties. This same measure applies to contractor-provided support for FMS administrative functions. These functions may be indirect (e.g., support across multiple purchasers/cases) or direct (e.g., support to a specific case or program).."

    Since the questioner info indicates they are located in the Department of the Army, DAU recommends consulting -- through your local Security Cooperation 'chain-of-command' -- with the US Army Security Assistance Command (USASAC) on the application of these FMS-related DoD FMR provisions within the Army.

     

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