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govtacct02

Expiration date for Guidance from DPAP

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I am looking for a reference I can cite that articulates when a Guidance memo/paper issued by DPAP or Defense Pricing expires.  Can anyone help?

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Any document that is to be incorporated into a particular regulation is marked to indicate that regulation and either the actual date of incorporation or the estimated date of incorporation. After a document is incorporated into a regulation the actual date is marked and the document is transferred to archives. Documents not to be incorporated into policy are transferred to the archives 60 days after publication.

https://www.acq.osd.mil/dpap/ops/policy_vault.html 

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10 hours ago, Don Mansfield said:

Don, I didn’t read that policies not to be incorporated into a regulation expire upon transfer to the policy vault.  

“The Policy Vault is a central repository for documents that are available to the public. Uncontrolled unclassified memoranda, guidance, reports, and other DPAP-related policy documents are found here.”

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I suspect the question has to do with whether DPAP and other DoD activities can avoid the required regulatory rule-making process by issuing guidance and memoranda that interpret regulations, without actually incorporating those interpretations into the regulations.

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3 hours ago, joel hoffman said:

Don, I didn’t read that policies not to be incorporated into a regulation expire upon transfer to the policy vault.  

“The Policy Vault is a central repository for documents that are available to the public. Uncontrolled unclassified memoranda, guidance, reports, and other DPAP-related policy documents are found here.”

I don't know the significance of a document being transferred to the Policy Vault archives. The description of the archives sounds like a policy document graveyard:

Quote

 

Policy Vault Archives

The archives is the final repository for all documents that were incorporated into a regulation or instruction. It is also the final repository for any document that was not intended to be incorporated into regulation or instruction. Those documents shall be moved to archive after 60 days in the policy vault.

 

It would be strange to move documents to an archive if they were still effective. But, I admit I don't know for sure.

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22 hours ago, here_2_help said:

I suspect the question has to do with whether DPAP and other DoD activities can avoid the required regulatory rule-making process by issuing guidance and memoranda that interpret regulations, without actually incorporating those interpretations into the regulations.

Here - Yes, you are correct, and also to respond to DOD activities that are using old guidance to make a CAS-related argument where rulemaking has not occurred.

Thank you all.

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govtacct02,

Remember that DPAP issued a follow-up memo, stating that any assertions of CAS non-compliance had to cite to the CAS regulation and not to the original DPAP memo.

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