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  • Question

    Our team received a question about Using APA Base funding on a task order that was originally funded with OCO APA funding. They were under the impression that they could not use APA Base funding within the first year of performance. I was wondering if this is the case, or where in the FMR this information.


    Answer

    DoD 7000.14-R Financial Management Regulation Volume 2B, Chapter 17 and Volume 12, Chapter 23 addresses budgeting and use of OCO funding.

    The OCO can be used for the incremental costs are additional costs to the DoD Component appropriations that would not have been incurred had the contingency operation not been supported.   

    In order to ensure that the requested funding is defensible and realistic, and the submitted data and justification material complies with congressional requirements, each Component is required to submit the contingency operations budget exhibits.

    The funding derived from a contingency transfer account is available only for those incremental costs incurred in direct support of a contingency operation. As such, funds that are transferred into a Component’s baseline appropriation are not to be used to finance activities and programs that are not directly related to the incremental cost of the contingency. In addition, the funds transferred to a Component’s appropriation are not to be used to procure durable and expendable items in excess of what is required. Furthermore, those durable items procured with transferred funds are to be retained in support of the contingency even after the Component/unit has completed its tour of duty to support the contingency. Those durable items in the inventory, such as office equipment and expendable supplies that have not been consumed, should be made available to Components/units that are replacing the Component/unit that is departing the contingency operation area.

    It is vital for civilian and military personnel authorized to obligate and expend funds in support of a contingency operation, using resources derived from the transfer of funds from a centrally funded transfer account (e.g., OCOTF), to employ a fiduciary approach to ensure that the funds are used in a prudent manner. Contingency funds are not to be used for purchases that are improper or are in excess of government requirements.

    The costs associated with contingency operations are limited to the incremental costs of the operation, that is, costs that are above and beyond baseline training, operations, and personnel costs. The Component must demonstrate that the end item is directly associated with current operations. The request should not contain funding to support accelerations of baseline procurement end items unless specifically approved by OUSD(C).

    Reporting is an integral part of the Department’s stewardship. Components must make every effort possible to capture and accurately report the cost of the contingency operation. Components are required to report the obligation of all funds (regardless of source) to cover the incremental costs of the contingency, including funds received in a supplemental. Each Component will develop and publish a Standard Operating Procedure (SOP) or other supplemental guidance that will cover Component specific items for cost reporting, under this chapter and validating monthly reporting.

    Based on the information provided, there should be no restriction on placing the APA Base funding on the same contract, as long as the items are within the scope of the contract, are not used for the same purpose, and they are tracked separately to ensure accurate reporting for the OCO funding, which includes only the additional costs to the DoD Component appropriations that would not have been incurred had the contingency operation not been supported.  Recommend that you check with the local PCO and Comptroller for a final determination.

     

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