1. Lori Peterson Systems Accountant LMP
Army's Use of Contractor DODAACs for GFM (Government Furnished Material)
Lori Peterson
Systems Accountant LMP
Integrity - Service - Innovation

2. Integrity - Service - Innovation
The Issue
Army is citing Contractor DODAACs as bill-to party for Government Furnished Material (GFM) and citing fund codes which are associated with Army lines of accounting.
Government pays for GFM
Contractor DoDAAC TAC 3 actually directs bill to US Army
When material is Contractor Furnished Material (vice GFM) contractor pays
Those orders should correctly identify the contractor as the bill-to party and not cite an Interfund billing fund code
Army is the predominate user of this practice, but other components may do the same
FPRC Chair asked Army to brief the topic
11/23/2018
Integrity - Service - Innovation

3. Integrity - Service - Innovation
Regulation
According to MILSBILLS DLM , Volume 4, April 11, 2012 which can found at:
C Billing shall be under noninterfund procedures when:
C The bill-to office is a DoD contractor
(Bill-To Service Code is C, E, HG, L, Q, SD, or U)
or the fund code requires non-interfund billing (normally XP fund code).
11/23/2018
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4. Integrity - Service - Innovation
Regulation
C Method of Billing Summary. Billing methods are summarized in Table C2.T1.
Table C2.T1. Method of Billing
Condition
Number
Billed DoDAAC Begins With:
And Fund Code is:
Then the Billing Method is:
Method is: 1
C, E, G, HG, HX, L, Q, SD, U, Z, or numeric
Any
NON INTERFUND 2
Any Service code
XP or otherwise designates noninterfund 3 H
Not identified as eligible for interfund billing 4
Anything other than conditions described by 1, 2, or 3
INTERFUND
AR Ch 16 DOD Material Inventories required by Defense Contracts (GFM) also applies.
11/23/2018
Integrity - Service - Innovation

5. Integrity - Service - Innovation
Issues
LMP (AWCF ERP) bills the ”C” DODAAC by Interfund if the fund code is citing an Army appropriation which is not consistent with the regulations.
Interfund billing is much more efficient and less costly to process than billing.
GCSS-Army only has Interfund bills in scope and did not expect to see or process any 1080/IPAC billings.
DLA bills this same situation as NON-INTERFUND.
Bills sent directly to the Contractor address or 1080 IPAC process
DLA has many aged open receivables.
11/23/2018
Integrity - Service - Innovation

6. Integrity - Service - Innovation
Issues Continued
Federal vs Non Federal determinations.
Contractor DODAAC indicates Non Federal
Army LOA is being billed indicates Federal.
GFM vs CFM.
Structure of transaction would indicate CFM; shows contractor bill-to
Management Control Authority validation of authorized materiel may be problematic for some Components
11/23/2018
Integrity - Service - Innovation

7. Integrity - Service - Innovation
Potential Solutions
Change regulations to allow Interfund processing on C DODAACs if an appropriation is assigned to the signal fund code combination.
Structure the transactions to designate the Government bill-to party either in the Supplementary Address or by using signal code C or L to direct the bill to the correct Government entity via the Fund Code to Billed Office DoDAAC Table.
Are there sufficient fund codes available for signal code group C/L for each component?
11/23/2018
Integrity - Service - Innovation

8. Integrity - Service - Innovation
Example
Examples:
DODAAC: CY0SJN
SERVICE/AGENCY:US Army (USA)
AUTHORITY CODE: 00 - Requisitioner
TAC 1:
KELLOGG BROWN & ROOT SERVICES, INC
1080 ELDRIDGE PKWY
HOUSTON TX
TAC 2:
KELLOGG BROWN & ROOT SERVICES TASK
AST BALKANS
CAMP BONDSTEEL
FERIZAJ KV
KOSOVO
TAC 3:
DFAS ROME 13145
GCSS ARMY
325 BROOKS ROAD
ROME NY
11/23/2018
Integrity - Service - Innovation

9. Integrity - Service - Innovation
Example
Example:
Billed by interfund by LMP:
A01AJ2E   BX00011CY0SJN BW90A0DJ41      122552LWXHAAD IV 
PAPER TOWELS
Billed by Non- interfund (1080) by EBS:
A31SMSS   EA00002CY0SJN RW90A0DJ41      121132A       SGA  
FASTENER ASSEMBLY,TURNLOCK
11/23/2018
Integrity - Service - Innovation