Fiscal Law Deskbook, 2013
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CHAPTER 2AVAILABILITY OF APPROPRIATIONS AS TO PURPOSEI.REFERENCES. .1II.CONSTITUTIONAL, STATUTORY AND OTHER BACKGROUND. .1A.U.S. Constitution .1B.The Purpose Statute. .2C.The “Necessary Expense Doctrine” (a.k.a. The 3-part Purpose Test). .2III.THE APPROPRIATION ACTS.4A.Overview. .4B.Appropriations .4C.Continuing Resolution Authorities.5D.Researching Appropriation Acts. .5IV. EXPRESS STATUTORY PURPOSE: THE DEPARTMENT OF DEFENSEAPPROPRIATIONS.6A.The Purpose Analysis Flowchart .6B.Overview of DOD Appropriations. .6C.Who is the purchase for? .6D.Classifying the Acquisition: .7E.Overview of the Major Defense Appropriations. .9F.Investment/Expense Threshold: .13G.Systems and the Expense/Investment Threshold. .15H.Accounting Classifications: .15Last updated 27 February 2013TJAGLCS-ADK2013 Fiscal Law Deskbook
I.GFEB .17J.Earmarks. .18V.IS THE EXPENDITURE OTHERWISE PROVIDED FOR IN A SEPARATEAPPROPRIATION?.19A.Overview. .19B.If there are two appropriations equally available: .20VI.LEGISLATION IMPACTING THE USAGE OF AN APPROPRIATION. .21A.Impacts Found Within the Actual Appropriation. .21B.Organic Legislation. .21C.Authorization Act. .22D.Miscellaneous Statutory Provisions.24E.Legislative History. .26VII. OTHER DOCUMENTS IMPACTING THE USAGE OF AN APPROPRIATION. .27A.Budget Request Documentation. .27B.Agency Regulations. .29C.Case Law. .30VIII.NECESSARY EXPENSE.31A.Express Statutory Purpose?. .31B.“Necessary Expense”.31C.GAO’s Necessary Expense Doctrine.32D.The first prong of the “necessary expense” doctrine. .32E.Exploring “necessary expenses”.322-2TJAGLCS-ADK2013 Fiscal Law Deskbook
F.Practical Aspects of applying the “necessary expense” doctrine. .32G.Agency Discretion. .32IX.TYPICAL QUESTIONABLE EXPENSES.33A.Overview. .33B.Clothing. .33C.Food. .34D.Bottled Water. .41E.Workplace Food Storage and Preparation Equipment .42F.Personal Office Furniture and Equipment. .43G.Entertainment. .44H.Decorations. .45I.Business Cards. .46J.Telephones. .46K.Fines and Penalties. .48L.Licenses and Certificates. .49M.Awards (Including Unit or Regimental Coins and Similar Devices). .50N.Use of Office Equipment. .53O.Expenditures for New or Additional Duties. .53X.AUGMENTATION OF APPROPRIATIONS & MISCELLANEOUS RECEIPTS.54A.General Rule - Augmentation of Appropriations Is Not Permitted.54B.Statutory Exceptions to the Miscellaneous Receipts Statute. .56C.GAO Sanctioned Exceptions to the Miscellaneous Receipts Statute. .592-3TJAGLCS-ADK2013 Fiscal Law Deskbook
XI.EMERGENCY AND EXTRAORDINARY EXPENSE FUNDS.62A.Definition. .62B.Historical Background. . .62C.Appropriations Language. .62D.Statutory Background. .63E.Regulatory Controls. .64XII.CONCLUSION. .69APPENDIX A: ANALYZING A PURPOSE ISSUE .72APPENDIX B: PURPOSE ANALYSIS FLOWCHART 802-4TJAGLCS-ADK2013 Fiscal Law Deskbook
CHAPTER 2AVAILABILITY OF APPROPRIATIONS AS TO PURPOSEI.II.REFERENCES.A.U.S. Constitution, Art. I, § 9.B.31 U.S.C. § 1301. The Purpose Statute.C.Department of Defense Appropriations Acts and National Defense AuthorizationActs (annual legislation found at: http://thomas.loc.gov/).D.DOD 7000.14-R, Financial Management Regulations (hereinafter “DOD FMR,”found at: http://www.dod.mil/comptroller/fmr/).E.Department of Air Force, Instr. 65-601, Budget Guidance and Procedures (16August 2012), available at http://www.e-publishing.af.mil.F.Principles of Fed. Appropriations Law, (commonly referred to as the “RedBook”) 3d ed., vol. I, chapters. 2-4, GAO-04-261SP (January 2004), found at:http://gao.gov/legal/index.html.G.A Glossary of Terms Used in the Federal Budget Process, GAO-05-734SP (Sept.2005) found at: http://www.gao.gov/products/GAO-05-734SP.H.OMB Cir. No. A-11, Preparing, Submitting, and Executing the Budget (August2012), § 51 available mb/assets/a11 current year/a 112012.pdfCONSTITUTIONAL, STATUTORY AND OTHER BACKGROUND.A.TJAGLCS-ADKU.S. Constitution.2013 Fiscal Law Deskbook
B.C.1.Art. I, § 9 provides that “[n]o Money shall be drawn from the Treasury,but in Consequence of Appropriations made by Law.” This establishesCongress has having the “power of the purse.” As a result, Congressmust annually pass and the President must sign Appropriations Actsbefore agencies can expend any money.2.In applying this provision of the constitution, the Supreme Court hassaid, “The established rule is that the expenditure of public funds isproper only when authorized by Congress, not that public funds may beexpended unless prohibited by Congress.” US v. MacCollom, 426 U.S.317 (1976). In other words, we must look for specific congressionalauthority prior to the expenditure of public funds.The Purpose Statute.1.31 U.S.C. § 1301(a) provides: “Appropriations shall be applied only tothe objects for which the appropriations were made except as otherwiseprovided by law.”2.Congress enacted this statutory control in the Act of March 3, 1809, 2Stat. 535, as part of a reorganization of the War, Navy, and TreasuryDepartments to limit the Executive Branch in spending appropriations.The “Necessary Expense Doctrine” (a.k.a. The 3-part Purpose Test). The purposestatute does not require every expenditure to be specified in an appropriation act.That is not possible or feasible. “The spending agency has reasonable discretionin determining how to carry out the objects of the appropriation.”1 Where aparticular expenditure is not specifically provided for in the appropriation act, it ispermissible if it is necessary and incident to the proper execution of the generalpurpose of the appropriation. The Government Accountability Office (GAO)applies a three-part test to determine whether an expenditure is a “necessaryexpense” of a particular appropriation:1See PRINCIPLES OF FEDERAL APPROPRIATIONS LAW, THIRD EDITION, VOLUME I, p.4-20, GAO-04-261SP (January2004)2-2TJAGLCS-ADK2013 Fiscal Law Deskbook
1.The expenditure must be necessary and incident to the purposes of theappropriation. In other words, the expenditure must bear a logicalrelationship to the appropriation sought to be charged, and it must makea direct contribution to carryout out either a specific appropriation or anauthorized agency function for which more general appropriations areavailable.2.The expenditure must not be prohibited by law.3.The expenditure must not be otherwise provided for; that is, it must notbe an item that falls within the scope of some other, more specificappropriation or statutory funding scheme.a.What if you have two equally available appropriations to fund anacquisition? I.e., neither appropriation is more specific?b.Election Doctrine: The GAO’s Election Doctrine states that if twoor more appropriations are equally available, then the agency maychoose which appropriation to use. Once the agency chooses acertain appropriation for that type of acquisition, however, theagency must continue to use the same appropriations for allacquisitions of that type – i.e., once the agency makes its choice ofappropriation, they are bound by that choice. See section V.B.below for further discussion.Principles of Fed. Appropriations Law, vol. I, ch. 4, 4-21, GAO-04-261SP (3d ed.2004). See Presidio Trust—Use of Appropriated Funds for Audio EquipmentRental Fees and Services, B-306424, 2006 U.S. Comp. Gen. LEXIS 57 (Mar. 24,2006).2-3TJAGLCS-ADK2013 Fiscal Law Deskbook
III.THE APPROPRIATION ACTSA.Overview. An appropriation is a statutory authorization “to incur obligations andmake payments out of the Treasury for specified purposes.”2 Generally, an“obligation” is a legal liability that arises from a mutual exchange of promises, orconsideration (usually a government promise to pay money in exchange for goodsand/or services), between the U.S. Government (USG) and a contractor.3B.Normally, Congress has, on an annual basis, passed thirteen appropriations acts.4Some of these acts provide appropriations to a single agency, while others provideappropriations to multiple agencies. See generally, Principles of Fed.Appropriations Law, 3d ed., vol. I, ch. 1, 1-26 – 1-27, GAO-04-261SP (Jan.2004). These annual appropriation acts are typically broken down as follows:1.Department of Defense.2.Military Construction.3.Agriculture, Rural Development, Food and Drug Administration andRelated Agencies.4.Commerce, Justice, and State, the Judiciary and Related Agencies.5.District of Columbia.6.Energy and Water Development.7.Foreign Operations and Export Financing and Related Programs.8.Interior and Related Agencies.2See A GLOSSARY OF TERMS USED IN THE FEDERAL BUDGET PROCESS, p.13-14, GAO-05-734SP (September 2005).3Id. at 70; see also 2013 Fiscal Law Deskbook, Chapter 5: Obligations.4As of late, Congress has relied upon an Omnibus, Continuing Resolutions or Consolidated Appropriation Act.E.g., Consolidated Appropriations Act, 2012, Pub. L. No. 112-74, 125 Stat. 786. [hereinafter 2012 CAA]2-4TJAGLCS-ADK2013 Fiscal Law Deskbook
59.Labor, Health and Human Services, and Education, and RelatedAgencies.10.Legislative Branch.11.Transportation and Related Agencies.12.Treasury and General Government Appropriations.13.Veterans Affairs and Housing and Urban Development, and IndependentAgencies.C.Optimally, each appropriation act is enacted by the President prior to the end ofthe preceding fiscal year. When the fiscal year begins, if there is no appropriationact for DOD, then DOD may have to stop (or “shut down”) its operations becausethere is a “funding gap,” or a period of time when it it does not have anyappropriated funds to obligate. Congress and the President, however, normallyavoid this DOD “shut down” by passing and enacting a Continuing ResolutionAuthority (CRA), which authorizes DOD to continue obligating funds – undercertain conditions – until the President can enact the fiscal year’s appropriationact.5D.Researching Appropriation Acts. In addition to Westlaw TM -based research,Judge Advocates (JA’s) can use the Thomas website (http://www.thomas.gov/) ofthe Library of Congress to conduct research on legislation enacted since 1973.This website also contains a consolidated listing of appropriation legislationenacted since 1998, and a list of pending appropriation bills for the current andupcoming fiscal years.See 2013 Fiscal Law Deskbook, Chapter 9: Continuing Resolution Authority (CRA).2-5TJAGLCS-ADK2013 Fiscal Law Deskbook
IV. EXPRESS STATUTORY PURPOSE: THE DEPARTMENT OFDEFENSE APPROPRIATIONSA.The Purpose Analysis Flowchart6 may provide a useful visual tool that JA’s mayuse to conceptualize the different statutory and regulatory fiscal law requirementsthat apply to DOD appropriations.B.In each of the two annual appropriations acts devoted to DOD, Congress grantsmultiple appropriations for different types of purchases that DOD needs to maketo successfully execute its mission. See e.g., Consolidated Appropriations Act,2012, Pub. L. No. 112-74, Division A, 125 Stat. 786 (providing over 50 separateappropriations to DOD); Consolidated Appropriations Act, 2012, Pub. L. No.112-74, Division H, 125 Stat. 786.C.Who is the purchase for? Congress appropriates funds for DOD in the annualDOD Appropriations Act (DODAA). Congress intends that DOD use theirappropriated funds by DOD for the primary benefit of DOD. As a result, tounderstand whether a unit may obligate appropriated funds for a purchase, JudgeAdvocates (JAs) must first determine who is the primary beneficiary of thepurchase is.7 Generally, there are three possible answers to this question: theprimary beneficiary of the purchase is the agency (i.e., the JA’s unit), the primarybeneficiary of the purchase is a different U.S. Government (USG) agency, or theprimary beneficiary of the purchase is a foreign government, military orpopulation.1.6Interagency Acquisitions (IA’s): The IA fiscal law applies whenever theprimary beneficiary of the purchase is a different USG agency. IA lawis a specialized area of fiscal law and is explored in detail in chapter 6 ofthe Fiscal Law Deskbook.8See infra, Appendix B: Purpose Analysis Flowchart.7The answer to this question is extremely important, as it will drive the remainder of the JA’s purpose analysis. If aunit is unable to answer this question, the JA cannot competently conduct a fiscal law review as to the legality of thepurchase.8See 2013 Fiscal Law Deskbook, Chapter 6: Interagency Acquisitions (IA’s).2-6TJAGLCS-ADK2013 Fiscal Law Deskbook
D.2.Operational Funding: Operational funding fiscal law applies wheneverthe primary beneficiary of the purchase is a foreign government, militaryor population. Operational funding is a specialized area of fiscal lawand is explored in detail in chapter 10 of the Fiscal Law Deskbook.93.Basic Purpose: For most expenditures, the primary beneficiary of thepurchase is the agency (i.e., the unit). The remainder of this outline willfocus on these purchases by DOD, when the agency is the primarybeneficiary. Once the JA determines that the primary beneficiary is theagency (i.e., the unit), then the JA must determine the nature of thesupply item or service that the unit is purchasing.Classifying the Acquisition: To determine the proper appropriation, a JA mustalso classify the acquisition. From a Purpose standpoint, DOD units make threetypes of acquisitions: DOD units acquire expense items (“expenses”), investmentitems (“investments”), and/or construction.101.9Expenses are “the costs of resources consumed in operating andmaintaining [DOD],” such as services, supplies, and utilities. Expensesare normally financed with Operations and Maintenance (O&M)11appropriations. See DOD FMR, vol. 2A, ch. 1, para. 010201. Commonexamples of expenses include:a.Services;b.Supply items that will be consumed in the current period;12c.Civilian employee labor;See 2013 Fiscal Law Deskbook, Chapter 10: Operational Funding.10Note that the classification of an acquisition into expenses, investments, and construction is limited to the Purposeanalysis. Under the Time portion of the fiscal analysis, the JA will classify the acquisition in a different manner toanalyze the Bona Fide Need; see 2013 Fiscal Law Deskbook, Chapter 3: Time.11Another common acronym for O&M is OMA, Operations and Maintenance, Army. OMA is more common fororganizations that utilize operations and maintenance funds from multiple services (e.g., operations andmaintenance, Air Force.)12In a prior version of Vol. 2A Chapter 1, the DOD Fimancial Management Regulation (DOD FMR) defined the“current period” as 2 years or less. Although this is no longer the rule, it may be useful for JAs to use this definitionof expenses as supply items that will last 2 years or less as a ‘rule of thumb’ to communicate the expense-investmentdistinction to their commanders.2-7TJAGLCS-ADK2013 Fiscal Law Deskbook
d.Rental charges for equipment and facilities;e.Fuel;f.Maintenance, repair, overhaul, and rework of equipment; andg.Utilities.2.Investments are the costs that result in the acquisition of, or an addition to,end items. These end items benefit current and future periods and generallyare of a long-term character. Investments include the “costs to acquirecapital assets such as equipment,” DOD FMR, vol. 2A, ch. 1, para.010201.D.2., or assets which will benefit both current and futureperiods and generally have a long life span. Investments are normallyfinanced with Procurement appropriations. Common examples ofinvestments include:a.All items of equipment, including assemblies, ammunition andexplosives, modification kits (the components of which are known atthe outset of the modification) .b.The costs of modification kits, assemblies, equipment, and materialfor modernization programs, ship conversions, major reactivations,major remanufacture programs, major service life extensionprograms, and the labor associated with incorporating these effortsinto or as part of the end item are considered investments. All itemsincluded in the modification kit are considered investment eventhough some of the individual items may otherwise be considered asan expense. Components that were not part of the modificationcontent at the outset and which are subsequently needed for repair areexpenses. The cost of labor for the installation of modification kitsand assemblies is an investment.c.A major service-life extension program, financed in procurement,extends the life of a weapon system beyond its designed service lifethrough large-scale redesign or other alteration of the weapon system.2-8TJAGLCS-ADK2013 Fiscal Law Deskbook
3.E.Construction is the erection of a complete and useable facility, or acomplete and useable improvement to an existing facility.13 Once aDOD unit classifies a project as a construction project, then thatconstruction project includes all the expense and investment itemsnecessary to erect a complete and useable facility or a complete anduseable improvement to an existing facility. Construction is fundedusing Construction Funding rules and is a specialized area of fiscal lawexplored in detail in chapter 8 of the Fiscal Law Deskbook.14Overview of the Major Defense Appropriations. The following is a list of thelarger and more important defense appropriations followed by a generaldescription, extracted from the appropriations acts themselves, of the purposes towhich these appropriations may be applied.1.Military Personnel (MILPER). Used for “pay, allowances, individualclothing, subsistence, interest on deposits, gratuities, permanent changeof station travel (including all expenses thereof for organizationalmovements), and expenses of temporary duty travel between permanentduty stations . . . .”15 In effect, MILPER pays for all the allowances thatservice-members receive on their Leave and Earnings Statement (LES).Government civilian salaries, on the other hand, are paid with the serviceOperations and Maintenance (O&M) appropriations.2.Operations and Maintenance (O&M). Used for “expenses, not otherwiseprovided for, necessary for the operation and maintenance of the[Service], as authorized by law . . . .” O&M appropriations pay for thecurrent operations of the force, and for the maintenance of all equipmentthat the Armed Services need to operate the force, including basemaintenance services, vehicle maintenance services, civilian salaries,and all expenses16 required to operate the force. For most DOD unitsand organizations, O&M is the only type of appropriation that they canaccess without higher-level approval.13See United States Code, Title 10 [hereinafter 10 U.S.C.], §2801; see also 2013 Fiscal Law Deskbook, Chapter 8:Construction Funding.14See 2013 Fiscal Law Deskbook, Chapter 8: Construction Funding.152012 CAA, supra note 3, at Div. A., Title I.162012 CAA, supra note 3, at Div. A., Title II.TJAGLCS-ADK2-92013 Fiscal Law Deskbook
3.Research, Development, Test and Evaluation (RDT&E). Used for“expenses necessary for basic and applied scientific research,development, test and evaluation, including maintenance, rehabilitation,lease, and operation of facilities and equipment . . . .”17 Congressprovides DOD Research and Development (R&D) organizations (e.g.,Defense Advanced Research Projects Agency – DARPA)18 with its ownappropriation to fund the scientific research and development of newtechnologies that have military applications. Of note is that Congressprovides these R&D organizations the RDT&E appropriation to fund notonly the scientific research and military development of newtechnologies, but also their normal operation and maintenance. As aresult, these DOD R&D organizations do not receive O&M funds – theymust fund their O&M-type expenses with the RDT&E appropriation.4.Procurement (Various). Congress provides various differentProcurement appropriations in the annual DOD Appropriations Act(DODAA) for different categories of investment items. Procurementappropriations include: Ammunition Procurement, MissileProcurement, Aircraft Procurement, Weapons and Tracked VehicleProcurement, Wheeled Vehicle Procurement, and Other Procurement.19The Other Procurement appropriation is a “catch-all” appropriation forinvestment items that are not purchased with the more specificProcurement appropriations.a.17Ammunition Procurement. Used for “construction, procurement,production, and modification of ammunition, and accessoriestherefor; specialized equipment and training devices; expansion ofpublic and private plants, including ammunition facilitiesauthorized by section 2854 of title 10, United States Code, and theland necessary therefor, for the foregoing purposes, and such landsand interests therein, may be acquired, and construction prosecutedthereon prior to approval of title; and procurement and installationof equipment, appliances, and machine tools in public and privateplants; reserve plant and Government and contractor-owned2012 CAA, supra note 3, at Div. A., Title IV.18See Defense Advanced Research Projects Agency (DARPA), available at: http://www.darpa.mil (last accessedMarch 17, 2010) (DARPA is one of the major DOD R&D organizations. It funds unique and innovative researchthrough the private sector, academic and other non-profit organizations as well as government labs. DARPAresearch runs the gamut from conducting scientific investigations in a laboratory, to building full-scale prototypes ofmilitary systems. They fund research in biology, medicine, computer science, chemistry, physics, engineering,mathematics, material sciences, social sciences, neuroscience, and other projects).19See 2012 CAA, supra note 3, at Div. A., Title III.TJAGLCS-ADK2-102013 Fiscal Law Deskbook
equipment layaway; and other expenses necessary for theforegoing purposes . . . .”20b.c.20Id.21Id.Id.22Missile Procurement: Used for the “construction, procurement,production, modification, and modernization of missiles,equipment, including ordnance, ground handling equipment, spareparts, and accessories therefor . . . . ” 21(1)Note that missiles are a type of ammunition. DOD,however, may not use the Ammunition Procurementappropriation to buy missiles because Congress provides amore specific appropriation to buy missiles – the MissileProcurement appropriation.(2)Additionally, if DOD were to obligate all of the funds inthe Missile Procurement appropriation, it would still beunable to use the Ammunition Procurement appropriationto buy missiles, because Congress has specified themaximum amount of money that DOD may obligate formissiles in the Missile Procurement appropriation.Other Procurement. There are several other procurementappropriations given to the various services, including one for eachof the following: aircraft, missiles, Weapons & Tracked Vehicles,and Shipbuilding and Conversion (Navy only). The languageutilized in each of these appropriations is similar to that utilized inthe Ammunition Procurement Appropriation above. There is alsoa residual catch-all procurement appropriation entitled “OtherProcurement” which is used for “construction, procurement,production, and modification of vehicles; . . . communications andelectronic equipment; other support equipment; spare parts,ordnance, and accessories therefor; specialized equipment andtraining devices . . . .”222-11TJAGLCS-ADK2013 Fiscal Law Deskbook
F.5.Military Construction (MILCON). Used for “acquisition, construction,installation, and equipment of temporary or permanent public works,military installations, facilities, and real property . . . .”236.Other Appropriations. Other than the 5 base DOD appropriations(MILPER, O&M, RDT&E, Procurement, and MILCON), Congresscreates additional appropriations for other purposes on an annual basis.For example, Congress provides a Family Housing appropriationannually. The Family housing appropriation is used for “expenses offamily housing for the [Service] for construction, including acquisition,replacement, addition, expansion, extension and alteration, as authorizedby law . . . .”24 Family housing has its own separate appropriation and isnot paid for with the Service MILCON used to pay for c
Feb 27, 2013 · see also 2013 Fiscal Law Deskbook, Chapter 5: Obligations. 4 As of late, Congress has relied upon an Omnibus,
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