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W Adewole

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  1. Update, Our policy individual had no answers and our legal department has no experience with a similar actions. Legal referred me to the purchase card (PC) office to find out about the process for using the SF182 for training. The PC office informed me that only the PC holder can obligate and this happens after they obtain an approval number/charge code from NERP. Based on the information provided by the PC office, legal has determined that this is a UAC. The best reason I got for the decision is that although, the SF182 is not cover under the FAR, using a purchase card for a class which already occurred falls under the realm of a UAC. The closest I got to a policy is the SECNAVINSA 12410.3 but nowhere does it say the training officer has the right to obligate. Thanks to everyone for your guidance
  2. Pepe, The other issue here is my agency instructions on UAC NAVAIRINST 4200.52A removes the word "solely" from the definition of unauthorized commitment. I am not sure if this was intentional but I believe this changes the definition of unauthorized commitment and opens the gate for what actions can be classified as UAC. " Unauthorized Commitment, as used in this instruction, means an agreement that is not binding because the Government representative whom made it lacked the authority to enter into that agreement on behalf of the Government." 4200.52A CH-1 - Ratification of Unauthorized Commitments.pdf
  3. The training officer stated to me that she had the authority to obligate but my Supervisor is not aware that the authority to obligate using the SF 182 can be granted to a training officer and is also unaware of our policy. I think its time to get a charge code for legal counsel and get our policy person involved. I am just trying to wrap my head around thousands of dollars in touch labor to ratify a $3500 class.
  4. Pepe, The routing process requires that a signature be obtained from the BFM and the Comptroller, I believe this is to ensure that the funds are available. I am leaning on 5 months of intern experience here but the question is, is the authority of the Training officer legitimate without the signatures/approval of the BFM and Comptroller.
  5. A Training Officer with authorization to use a SF182 to obligate funds and contract for training did not complete the routing process (BFM and comptroller signature was not acquired) of the SF182 before the training took place. Since the funding was available and the Government representative had the authority, is this action still an Unauthorized Commitment?
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