We concur with your recommendation. This past summer, the Justice Management Division (JMD), Finance Staff modified the FMIS2+ system to ensure subcertifiers could not bypass the delegated payment limit presently established at $50,000.
We concur with your recommendation. The Facilities Management and Support Services Staff (FMSS) has requested through JMD, Procurement Services Staff (PSS) that the purchase card statements be modified to add a line for the date of review by the cardholder and approving official. JMD has contacted Bank One. Bank One indicated that this may require creating a special statement for the Offices, Boards and Divisions (OBD) (unlikely that they will be able to separate for just one Unit). Bank One stated that they will further investigate this request, arid informed us that there may be a cost for its implementation. JMD will provide us a response when they receive it, however it may be two to three weeks because of the current process of issuing the new cards. Since this will impact the OBDs, the final decision to implement this request will be at the JMD level.
The Resource Management and Planning Staff will coordinate with JMD's Finance Staff to discuss the redesign and reissuance of the Accountable Officer Signature Form, Form OBD-234. However, as discussed in the September 11, 2003, exit conference, JMD is responsible for the final decision regarding any modifications to this form.
The Federal Acquisition Regulation, Chapter 1, Subpart 1.603-2 states in so many words that delegations of procurement authority should be based on the knowledge and capability of the appointee considering the complexity and dollar value of the procurement. UNICOR, NIB/NISH, and FEDSTRIP are the most simple of all procurements. Regardless of dollar value, they do not require competition, set-asides, justifications, advertising or price reasonableness determinations. There is no difference in the procedure based on dollar value. While we do not see the value added by this recommendation, FMSS has requested that JMD, PSS, Acquisition Programs Group (APG) limit the delegated authority to the United States Attorneys' Offices for UNICOR, NIB/NISH, and FEDSTRIP to one million dollars. We also requested the authority for EOUSA components be limited to five million dollars. However, JMD is responsible for the final decision and action.
We concur with your recommendation. The evaluation guide used in the EARS reviews for acquisition management is constantly being updated and revised. It is currently undergoing revision and we will ensure that it includes tests to detect similar deficiencies as the audit.
We concur with your recommendation. The FMSS will expand the recommendation of records to be reviewed to include all years since the prior review of that office.
The JMD, PSS, APG mandates the use of their comprehensive checklist in all acquisitions exceeding $2,500. They also provide an optional checklist for micro-purchases (<$2,500) (Attachment 1). While receipt is not addressed in that checklist, it is addressed in the checklist for close out of the file (Attachment 2). The other elements that are provided in the report as applicable to most purchases are also addressed in the requirements of the instructions from the JMD/PSS/APG Simplified Acquisition Desk Reference. We will request that JMD enhance their forms to include the elements from the report listing that will add value to their checklists and required forms. However, JMD is responsible for the final decision and action.