Normally we use FFRDCs with research and development. However, DoD does O&M for FFRDC as an exception. Is there any DoD documentation or USD policy that indicates FFRDCs using O&M appropriation?
The answer appears to be yes. While researching the Financial Management Regulation (FMR), DoDI 7000.14, I did not find anything prohibiting the use of O&M, I did stumble upon the following document:
[Note that the aforementioned form could not be attached and was e-mailed directly to the AAP POC]
DEPARTMENT OF DEFENSE ,DD 1414, BASE FOR REPROGRAMMING ACTIONS
DIVISION C OF PUBLIC LAW 115-141, DEPARTMENT OF DEFENSE
APPROPRIATIONS ACT, 2018
APPROVED: MARCH 23, 2018
EFFECTIVE: OCTOBER 1, 2017
Note that the Appropriation Account Title is Operation and Maintenance, Army (OMA) and one of the reductions is FFRDC. The unclassified document showed a reduction of $1.8M in FFRDC funding. The obvious implication is that OMA can be used to fund FFRDCs.
We always recommend consulting with your local comptroller chain of command and legal office before taking action.