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A FFP Purchase Order for Severable Services was issued in early FY 12 using 11/12 funds (our agency has two year appropriations). Invoices are paid every two weeks so much of the initial funding has been paid out. Several months have passed and now the program is asking contracts to switch out the remaining 11/12 funds and replace it with 12/13 funds. I suspect the program is playing some sort of shell game with their funding and I've been getting an increasing amount of these "fund swaps". These swaps are administratively burdensome for the contracts staff to process and I want them to stop. Does anyone know if this may be a violation of Appropriations Law and if so, which rule (i.e. Purpose, Time, Amount)?

One other thing to note is that while the year of the appropriations may be the same (FY12), the other accounting information may not be the same (Budget Org Code, Object class, etc)

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Guest Vern Edwards

Interesting. I've never heard of overlapping appropriations before. I think that there is no violation of appropriations law as long the funds used cover a bona fide need of the year for which the funds were appropriated. If the need arose in FY 11, then I do not think you can use the FY 12/13 funds. But if the need arose in FY 12, then it should be okay to use the FY 12/13 funds.

If the program office is tying up your human resources to play funding games, then when they want to buy something tell them they'll have to wait until you finish all of their funding actions.

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Thank you, I suspected that was the case but I was hoping there was something I hadn't thought of. I plan to explain the additional burden involved and that time spent processing these "swaps" is time taken away from processing new actions.

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Make the program office draft all the paperwork associated with one of the funding swaps so they see what's involved. I'm assuming you are in an organization that includes all the line of accounting information in the contract, which means a lot of doublechecking to make sure all the right numbers got changed.

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