Memorandum for the record subject fi finance only invoices

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Title: MFR - CASX Funding for SW_v2 (MFR - CASX Funding for SW_v2.doc:1)
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  • MEMORANDUM FOR THE RECORD SUBJECT: FI (Finance Only) Invoices
  • DEPARTMENT OF - Digital Library

DEPARTMENT OF - Digital Library

MEMORANDUM FOR THE RECORD
SUBJECT: FI (Finance Only) Invoices
Issue
The NASA FY 2010 Appropriations Bill provides that NASA's Cross-Agency Support Funds
(CASX) are limited to a one-year period of availability and will expire on September 30, 2010.
This paper addresses the requirements for processing FI invoices. A FI invoice is an invoice
that is received by the Center for payment of goods/services that does not have a formal
procurement instrument. This means that there is no pre-existing commitment or obligation
within SAP to make payment against. When a FI invoice is processed it simultaneously
records the commitment, obligation, cost, and disbursement in SAP.
The NASA FY 2010 Appropriation states that NASA's Cross Agency Support Funds (CASX) shall
be limited to one-year availability and expire on September 30, 2010.
The "Bona Fide Need Rule", from 31 U.S.C. sec. 1502, limits obligation of funds to the year in
which the funds are available:
The balance of an appropriation or fund limited for obligation to a definite period is
available only for payment of expenses properly incurred during the period of
availability, or to complete contracts properly made within the period of availability
and obligated consistent with section 1501 of this title. However, the appropriation
or fund is not available for expenditure for a period beyond the period otherwise
authorized by law.
When the need for the goods or services is recurring and continuous, then it should be
regarded as severable into the various time periods. Centers must fund severable needs
with dollars available for obligation on the date the goods and services are rendered.
In other words, PY 2010 funds cannot be used for invoices for goods or services that were
received in FY 2011, nor can PY 2011 funds be used to pay for invoices for goods or services
that were received in FY 2010.
This memorandum documents the method to ensure proper payment of FI invoices for
services rendered in the current fiscal year when using one-year and expiring funds.
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8/6/2010
Guidance
All FI invoices should be paid based on prompt payment regulations through August 31.
From September 1 through the Agency Fiscal Year End (FYE) disbursement cutoff date, it is
recommended that the OCFO waive prompt payment regulations to allow for early payment
of FI invoices. This will allow payment to be made upon receipt of the invoice. After the
Agency FYE disbursement cut-off date, any goods/services normally processed via FI invoice
that are still unpaid should be processed specially. Since the funds need to be obligated by
September 30, Centers should create a regular two-way match Purchase Order (not FI) in
SAP for these using the outside buyer role. POs should be created for each individual event
(i.e. transportation, tort claims, etc.). The PO must be created on or before September 30th.
To facilitate tracking for payment in FY 2011, Centers need to include in the PLI reference
field in SAP a link to the event (ex: FedEx tracking number, settlement claim number, etc.).
These actions will tie up the budget and record a commitment and obligation in preparation
for the payment of these expected FI Invoices in FY 2011. This year end process is for
expiring funds only.
Communication to the NASA community must be included in the FYE close out schedule to
ensure that all expiring funds are processed in a timely manner. Center CFO organizations
will need to work with their customers (e.g., Logistics for transportation charges, Legal for
torts claims, etc.) to obtain accurate values to be used to record the two-way match POs. It
is understood that some of the costs will be actual (based on shipments made), while some
will be estimates (based on estimated legal settlements).
Even with each Center performing an intelligent forecast, the Agency is exposing itself to
some level of risk of not having enough funds to cover unexpected FI invoices received in FY
2011 that pertain to FY 2010. To mitigate this risk, the Agency could post their own Agency
emergency forecast two-way match PO in case Centers need additional funding to make
payments in FY 2011.
On October 1, 2010, Centers can resume their normal processing of FI invoices for new year
activities. To pay those FI invoices that were already entered into SAP in September, 2010
as two-way match POs, Centers will need to work with the NSSC to pay these as LIV invoices,
using the information in the PLI reference field in SAP to tie to the source documents. By
following this process, Centers avoid having to create an SR (Service Request) requesting
OCFO concurrence, and NEACC support, for using expired PY 2010 funds to process the
payment in FY 2011.
In cases where additional expired funds are needed, and are over the parameter that the
system allows (10% or $500.00 whichever is lower) to pay the FI invoices, then the existing
SR process requiring OCFO approval must be followed.
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8/6/2010
Treatment of
Expiring Funds at FY2010 Close and FY 2011 Start Up
OCFO to waive Prompt Payment regulations to allow early payment of FI invoices citing
expiring funds during September to allow Centers time to commit, obligate and cost
expiring funds
Centers to identify all unpaid FY 2010 FI invoices with expiring funds that will need to
be paid in FY 2011 and enter two-way match POs for each event in SAP by September
30
Agency to forecast emergency amount to cover unforeseen needs in FY 2011 and enter
a two-way match PO in SAP to obligate this amount by September 30
Centers to pay in FY 2011 the FY 2010 FI invoices that need to be paid by recording a
LIV disbursement against the two-way match POs setup in SAP in September, 2010
using PY 2010 funds
Input Needed from OCFO
Is it necessary to estimate cost and record an accrual for these types of activities if they are
not deemed material in amount? For the last 12 months, the Agency has disbursed 1860
payments totaling $6.8M. No Centers use FI invoices for large utility payments; all utilize
other means (generally POs).
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8/6/2010

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