Our AF Central Procurement Office (CPO) for controlled cryptologic items (CCI) does not have the funds to purchase items that are both centrally managed (because it is CCI) and disposable after use. Because it is centrally managed they use procurement funds to purchase these items. Our CPO is not a DWCF organization, they are centrally managed using appropriated funds. When they purchase them they get them from the Army (via MIPR) that does a onetime buy each year. This year our need for the disposable item far exceeds the normal amount we get. The 65-605, 9.10, tells us that in order for us to be able to locally purchase (send the Army a MIPR from us) them that our central procurement office must send us the procurement funds. Which they do not have available. However we have O&M funds that we could use for the purchase. Is there any guidance that trumps this conundrum? I.E. mission needs…
In the background provided you state the asset is Centrally Managed, which is addressed in the the DoD Financial Management Regulation 7000.14-R (FMR), Volume 2A, Chapter 1, paragraph 010201, section F provides a very useful Decision Tree (in a table format) that can be used to help determine if OMA or OPA is appropriate. The Decision Tree is based on the verbiage in FMR, Volume 2A, Chapter 1, paragraph 010201, sections D. 1, 2, and 3.
The first question that the Decision Tree at FMR, Volume 2A, Chapter 1, paragraph 010201, section F asks is, “Is the item a centrally managed /asset controlled item?” To see what is meant by “a centrally managed /asset controlled item” we can find the definition at FMR, Volume 2A, Chapter 1, paragraph 010224. That paragraph, with regard to Centralized Item Management and Asset Control, says, “The management in the central supply system or a DoD-wide or Service wide acquisition and control system in which the manager has the authority for management and procurement of items of equipment. This includes such functions as requirements determination, distribution management, procurement direction, configuration control and disposal direction. Asset control includes the authority to monitor equipment availability and take such action as necessary to restock to approved stockage levels.”
Based on the background, the answer to the first question in the Decision Tree was YES, we are led to the next question which asks, “Is the item purchased from DWCF?” Again, in the background information you stated not a WCF the answer to the second question would be, NO.
Since the answer to the second question in the Decision Tree was NO, the Decision Tree leads to the conclusion that the purchase in question has to be classified as an investment. Therefore, OPA would be the appropriate funding to use for its acquisition, regardless of whether it exceeds the $250K threshold or not.
I suggest a review of the FY 2021 Budget Exhibits to ascertain which Appropriation Category Funding was requested for this purchase.
Suggestions: Read DoD Financial Management Regulation 7000.14-R, Volume 2A, Chapter 1, paragraph 010201 paying particular attention to sections C. 1 through 4, D. 1 through 3, and F. In addition, we most strongly recommend that you contact your local comptroller organization, and legal counsel for more information and their policy interpretation of this issue.