How does applying exceptions to using RDT&E funds across multiple fiscal years for a Defense Business System affect the annual Defense Business Certification
As a Financial Management SME, I can only answer the issue on the RDT&E funding that crosses fiscal years. As per the Financial Management Regulation (FMR) 7000.14-R Volume 2A Chapter 1 Paragraph 010214, you can ask for permission from the Comptroller to fund in the first year a contracted effort that is greater than 12 months but less than 18 months if one of the following is true: a) the effort is not logically divisible; b) it is infeasible to shorten the contract length; or c) you do not expect bids if the contracted effort is not fully funded.
I would also expect to look at the Budget Exhibits to determine what you included for this particular effort. The RDT&E funds have to be in the Current phase, so available for new obligations (if this is a new effort).
I strongly suggest you seek guidance from your Comptroller, and/or Legal office for this particular issue.