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B-210719 1 (1983-12-23)

handle is hein.gao/gaobadlmd0001 and id is 1 raw text is: OUCISION - FILE: B-210719 MATTER OF: LIGE T: THU COMPTRIIOLLER 61INEIRAL OP THE UNITEID TATUE WASHINGTON. 0.C. 20548 OATE: December 23, 1983 rmy Health Service Coftmand-Advance Payment for nterlaboratory Comparison Survey Program Army hospitals subscribe to Interlaboratory Comparison Survey Program to satisfy quality control and accredi- tation requirements. Program provides subscribers with printed evaluations based upon participant input. Fact that program supplies participants with survey kits so that they can perform tests to obtain input data does not taint evaluation report so as to preclude payment under 31 U.S.C. S 3324(d)(2), which permits advance payments for publications, since kits are means for collecting data evaluated in publications and analysis of data is the content of publication. The Chief of the Finance and Accounting Division, Fort Sam Houston, Texas, requests our decision to resolve an internal staff dispute concerning whether the Army can properly pay in advance for subscriptions to the College of American Pathologists' (CAP) Inter- laboratory Conparison Survey and Program. We conclude for the reasons given below that it can. CAP sells to Army hospitals, on a subscription basis, evalua- tion reports based upon data supplied by each participating labora- tory. The hospitals procure the CAP subscriptions in order to meet requirements established by the Joint Ommittee on Accreditation of Hospitals (JCAH) and to satisfy quality control standards. How- ever, soie Army officials question the propriety of paying in advance for the subscriptions because the program provides sub- scribers with laboratory kits in addition to the printed material. Participants perform various chemical tests using the kits in order to obtain data required for the evaluation reports. Thus, the question is asked, in effect, whether the inclusion of the labora- tory kits taints the evaluation reports so as to preclude advance payment under 31 U.S.C. S 3324(d)(2) (formerly 31 U.S.C. S 350). Section 3324(d) provides: The head of an agency may pay in advance from appropriations available for the purpose- * * * (2) charges for a publication printed or recorded in any way for the auditory or visual use of the agency. This Office has held that items which are read, such as books, pamphlets, newspapers, periodicals, microcards and other prints dk /I

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