Is it a UAC if the a soldier was approved to attend training (COTs) by the chain of command, funding was made available prior to the training event and all pre-approvals granted however the SF-182 was not completed prior to the training event.
Bottom line: Unless your activity has a Government Purchase Card (GPC) Standard Operating Procedures (SOP) or directive governing the SF-182 process where a completed SF-182 is required before ordering training from a vendor or beginning training, and if adequate funds were available at the time training was ordered from the vendor, and if the order from the vendor was placed properly according to your organization’s GPC procedures, and if invoice payment was supported by an approved SF-182, then this does not appear to constitute an Unauthorized Commitment (UAC).
** In a situation like this, it's a best practice to obtain concurrence from your A/OPC before affecting payment by GPC and document your decision in GPC files. **
- AFARS Appendix EE, 3-2(b) states: “GPC payment for commercial off-the-shelf training must be accompanied by an SF-182” and is silent on the matter if the SF-182 must be approved prior to attending training. Your Army organization may have a GPC SOP or SF-182 process directive mandating SF-182 approval prior to ordering training from a vendor, so you should review any such policies.
- Army Regulation 350–1 Army Training and Leader Development requires SF-182 approval prior to attending training for DA Civilians, however is silent regarding SF-182 approval for military members.
The question author was contacted for additional information and provided this context:
- The chain of command approved a Soldier to attend training in a course provided by a non-government organization.
- At the time of beginning training, a SF-182 was in-process, however not approved.
- After the Soldier completed training, an invoice was received by the Army activity.
- At the time of invoice receipt, the approved SF-182 was available.
- No payments were made via Government Purchase Card thus far.