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B-170479 1 (1976-01-15)

handle is hein.gao/gaobaddst0001 and id is 1 raw text is: (C. THE COMPTROLLER GENERAL DECISWN ANOF THEUNITED STATE W AS H IN GTO0N, 0.C. 20548 r1976 FILE: B-170479 DATE: AN MATTER OF: Statistical Sampling Procedures DIGEST: GAO limitation, pursuant to 31 U.S.C.A. I 82b-l(a), on use of statistical sampling procedures to prepayment examination of disbursement vouchers for amounts not ex- ceeding $300 is applicable to ICC proposal for random sampling to verify contractor's invoices under steno- graphic reporting services contract. However, if contract were to provide for separate invoicing of transcripts individually under $300, statistical sampling of those transcripts would be permissible. This decision responds to a request by the Managing Director of the Interstate Commerce Commission (ICC) for advice as to the effect of our limitation on the use of statistical sampling procedures to the preppyment examination of disbursement vouchers for amounts not in excess of $300, on an ICC proposal to institute a random sampling procedure to verify contractor's invoices under a stenographic reporting services contract. The Mana'ing Director expresses concern that application of the $300 limitation could hinder the effectiveness of the proposed sam'ling system, since a significant number of the Com- mission's hearings result in transcripts with individual costs exceeding the maximum. The ICC contracts with a private concern for stenographic hearing transcripts by the page, and has been counting the pages in each trant script to determine the number of allowable pages under the contract terms. This information is furnished the contractor who then submits an invoice. The invoice is checked against ICC records as to number of transcripts and number of pages within each transcript before being approved for payment. It is proposed that the ICC no longer count pages, but rather have the contractor do so and submit page counts with each transcript. The contractor would submit a monthly invoice for all tran- scripts prepared during the month, using his page counts. The ICC would then, on a statistical sampling basis, verify the contractor's sub- mitted page counts. Sample size would be determined on the basis of a 99 percent confidence factor. The Managing Director states with respect to this proposal:

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