rexroad Posted August 30, 2011 Report Share Posted August 30, 2011 First off--I am not a contracting officer, I am an analyst embedded with a group of contracting officers--so please forgive any dumb statements. thanks.... My agency is used to using no-year money [fewer rules in relation to bona fide need, anticedent liability, etc. than with either one-year or two year money]. In FY11 we were given two-year money which many of us are seeing for the first time (some of us have experience with one-year money from other agencies). I am trying to dig out all the little nuances that my Contracting Officers and Program Managers (and some finance folks) should make themselves aware of with the new two-year funding. Some of the obvious are: bona fide need (including anticedent liability) must be considered; contract or task order performance must end before end of second FY of funds rather than one year after obligating; timely deobligations in order to use money elsewhere. Questions: what are some other things we should be aware of? Is there any place that I might find a consise description of the differences in the various appropriation styles? If I have to just read through thousands of pages of the GSA Redbook or the FAR, are there words or terms I might want to concentrate on. Thanks, Fred.............. Link to comment Share on other sites More sharing options...
ji20874 Posted August 30, 2011 Report Share Posted August 30, 2011 Fred, It isn't so obvious to me that "contract or task order performance must end before end of second FY of funds rather than one year after obligating." That will depend on the purpose of the appropriation, but you may be able to use this two-year money to pay for contract performance after the two-year period ends. Link to comment Share on other sites More sharing options...
Mike_wolff Posted August 31, 2011 Report Share Posted August 31, 2011 I suggest you start with Vol. 1 of the Principles of Federal Appropriations Law (the GAO Redbook) here: http://www.gao.gov/special.pubs/d04261sp.pdf and then search for the phrase "multiple year." This should be a good starting point to focus your research. "Multiple year" comes up 31 times in this volume, so it's not a ton to read, but regardless, I think you need to read the document regardless of length because appropriation law can get very messy, so I think it's best to go straight to the source documents and not rely on someone else's summation. Link to comment Share on other sites More sharing options...
rexroad Posted August 31, 2011 Author Report Share Posted August 31, 2011 Fred, It isn't so obvious to me that "contract or task order performance must end before end of second FY of funds rather than one year after obligating." That will depend on the purpose of the appropriation, but you may be able to use this two-year money to pay for contract performance after the two-year period ends. Perhaps my simplified explanation was bad... or maybe I have wrong information or maybe we need to throw in a discussion of severability (which virtually all our purchases are). My understanding is that, with a severable action, you could have a contract that (with one-year money) begins on Sept 30 and runs for one year (effectively the entire contract is executed during the next fiscal year), but with two-year money a contract that begins on, say, Sept 1 of the second year of the money can only run for one month. The performance cannot cross out of the fiscal years in which the money was valid. Is this wrong? or perhaps an agency restriction? Link to comment Share on other sites More sharing options...
rexroad Posted August 31, 2011 Author Report Share Posted August 31, 2011 I suggest you start with Vol. 1 of the Principles of Federal Appropriations Law (the GAO Redbook) here:http://www.gao.gov/special.pubs/d04261sp.pdf and then search for the phrase "multiple year." This should be a good starting point to focus your research. "Multiple year" comes up 31 times in this volume, so it's not a ton to read, but regardless, I think you need to read the document regardless of length because appropriation law can get very messy, so I think it's best to go straight to the source documents and not rely on someone else's summation. Thanks. This was the answer I was fearing. I have been reading a hard copy of the Redbook. Perhaps I could save myself some eye strain by searching through the electronic version. Thanks for the link.............. Link to comment Share on other sites More sharing options...
Guest Vern Edwards Posted August 31, 2011 Report Share Posted August 31, 2011 Oh for Pete's sake. Try looking at the Red Book table of contents. All you have to read is pages 5-11 through 5-28, which are in Volume I. Link to comment Share on other sites More sharing options...
rexroad Posted August 31, 2011 Author Report Share Posted August 31, 2011 Oh for Pete's sake. Try looking at the Red Book table of contents. All you have to read is pages 5-11 through 5-28, which are in Volume I. Gosh, Vern. I just did that and I still have questions. Apparently everything I need to know about multiple year appropriations is not in the bona fide needs chapter. Thanks for the encouragement though............ Link to comment Share on other sites More sharing options...
Guest Vern Edwards Posted August 31, 2011 Report Share Posted August 31, 2011 Ask specific questions, and I will try to answer them. Link to comment Share on other sites More sharing options...
rexroad Posted August 31, 2011 Author Report Share Posted August 31, 2011 Ask specific questions, and I will try to answer them. As soon as I find out all I can about the different rules for various appropriation types, I may have some specific questions. Until then, I'm just a neophyte digging through conflicting resources (many without a table of contents). Link to comment Share on other sites More sharing options...
Guest Vern Edwards Posted August 31, 2011 Report Share Posted August 31, 2011 There are not many different rules. Link to comment Share on other sites More sharing options...
.gif)
Recommended Posts