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B-279620 1 (1998-03-31)

handle is hein.gao/gaobadsko0001 and id is 1 raw text is: 

LEI? a       Comptroller General
             of the United States
             Washington, D.C. 20548


             B-279620


             March 31, 1998

             The Honorable Charles E. Grassley
             United States Senate

             Dear Senator Grassley:

             This letter responds to your concern about a provision in the proposed
             Department of Defense (DOD) Reform Act that would permit DOD to use a
             combination of fast pay and statistical sampling procedures to verify receipt
             and acceptance of goods and services after payment. Your March 16, 1998,
             letter asked for our position on DOD's proposal.

             Section 401 would provide DOD with independent authority to implement a
             vendor payment process commonly referred to as fast pay. Using a fast pay
             process, DOD would pay vendors subject to post-payment verification of
             (1) receipt and acceptance of goods and services ordered and (2) the accuracy
             of invoices received. Section 401 directs DOD to perform its postpayment
             verification using statistical sampling procedures. DOD's proposal does not
             contain a dollar limitation for payments that would be subject to the fast pay
             procedures.

             The Office of Management and Budget (OMB) Circular A-125, Prompt Payment,
             Part 13 of the Federal Acquisition Regulation (FAR), and Title 7 of GAO's Policy
             and Procedures Manual for Guidance of Federal Agencies authorize agencies to
             implement fast pay processes using certain controls, which minimize the
             exposure of loss to the government. Separate legislative authority is not
             necessary for an agency that intends to follow these requirements.

             DOD currently lacks adequate systems and controls over payments as evidenced
             by the $22.7 billion in DOD's reported problem disbursements. DOD should
             first demonstrate that it can meet the control requirements currently prescribed
             in OMB Circular A-125, Part 13 of the FAR, and Title 7 of GAO's Policy and
             Procedures Manual followed by other federal agencies, before it implements fast
             pay procedures.

             A TYPICAL PAYMENT PROCESS

             Federal agency payment processes typically follow certain procedures which
             are designed to provide adequate controls to ensure that payments are proper.
             For example, agencies initiate a purchase order to obtain goods or services for

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