An agency may obligate its fiscal year appropriation only to meet a legitimate, or bona fide, need arising in the fiscal year for which the appropriation was made. This principle of appropriations law is known as the bona fide needs rule.

Generally, the relevant date to determine whether training is a bona fide need of a particular fiscal year is the date that the training is delivered (GAO Decision B-321296, July 13, 2011). Thus, the cost of training ordinarily is charged to the appropriation available in the fiscal year in which the training is delivered. However, in some circumstances, training may be a bona fide need of the fiscal year prior to the fiscal year in which the training is delivered (70 Comptroller Gen 296  1991). The prior year’s appropriation may be used for training occurring in the subsequent fiscal year, where the training provider requires the agency to register during the expiring fiscal year, the training date offered is the only one available, and the time between the registration and the training is not excessive. In 70 Comp. Gen 296, training that began the first day of fiscal year 1990 was held chargeable to 1989 appropriations where the training had been identified as a need for 1989. Compare GAO Decision B-321296 where training was delivered in January 2011 and registration was not required until October 15, 2010, such training was a bona fide need of fiscal year 2011 even though the need for training was identified in fiscal year 2010.

In the GAO Decision B-213141-O.M. (March 29, 1984), three scenarios are provided with an explanation in each case as to the appropriate fiscal year to be charged.

1.  The first situation occurs when approval is given near the end of a fiscal year for training which begins in that fiscal year. Our cases generally hold that when a nonseverable services contract is entered into during one fiscal year, and performance of the contract also begins in that fiscal year, the contract fulfills a bona fide need of that fiscal year only. See, e.g., 23 Comp.Gen. 370 (1943). Accordingly, in this situation, the training must be charged to the fiscal year in which the training is approved and begins.

2.  The second situation occurs when approval is given near the end of a fiscal year for training which begins in the succeeding fiscal year, but the appropriation for the succeeding fiscal year has not been enacted. In that case the training may be charged to the appropriation for the expiring fiscal year only if registration for the course is required before the end of that fiscal year. See 60 Comp.Gen. 452, 455 (1981). Otherwise, we conclude that the course could not be deemed a bona fide need of the expiring fiscal year and, accordingly, funds of that fiscal year could not be used for payment. Further, due to the Antideficiency Act, discussed above, the contract may not be charged to the succeeding fiscal year, because Congress has not yet enacted an appropriation for that year. See, e.g., 42 Comp.Gen. 272, 277 (1962).

3.  The third situation occurs when approval is given near the end of a fiscal year for training which begins in the succeeding fiscal year, and the appropriation for the succeeding fiscal year has been enacted. In this situation, the agency may properly charge the training to appropriations for the expiring fiscal year if, as indicated above, registration is required before the end of that fiscal year. Alternatively, if registration is not required until after the start of the new fiscal year, (whether or not the student actually registers before the new fiscal year,) the training is a bona fide need of the new fiscal year only and may be charged only to appropriations of that year. We note, however, that in the latter situation, the student could register prior to the new fiscal year without violating the Antideficiency Act, because funds have already been appropriated for the succeeding fiscal year. This succeeding fiscal year appropriation may be obligated upon its enactment to meet bona fide needs of the succeeding fiscal year. 20 Comp.Gen. 868 (1941).However, should the training be charged to the succeeding fiscal year, no payments may be made under the training contract until the funds actually become available at the beginning of the new fiscal year.

Based on the information that you provided, all training scheduled for FY20 couldn’t be delivered due to the unforeseen circumstances of the coronavirus and has left a balance of $47K. The excess funds cannot be used for training that will occur in FY21 unless it meets the following criteria:  training provider requires the agency to register during FY20, the training date offered in FY21 s the only one available, and the time between the registration and the training is not excessive.  I would recommend that you talk to your local legal department to get an opinion.