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Question
I have FY22 Funding that expires 30 Sept but I have a contract that needs to be executed in beginning of Oct which would be FY23, we normally do not get our new funding until late to end of Oct which would be to late to get this class on contract at that time. Can I use FY22 Funding for a class held in the next FY, do I need to invoke 2410, would it be severable or non severable at that point. The contract is for training the team requires so what will allow me to use the FY22 funding and get contracts to execute by 30 Sept?
Answer
Yes, Comptroller General Decisions B-233243, B-213141- O.M., and B-321296 determined that agencies may use current fiscal year’s funds to pay for training in the next fiscal year, if the training is deemed a bona fide need. In order to classify as a bona fide need, the training must meet the following requirements:

The training provider requires the agency to register during the expiring fiscal year;

There is only one date offered; and

The time between registration and the training is not excessive.

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