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U.S. Geological Survey Manual

U.S. Geological Survey Instructional Memorandum

No:  IM AEI 2014-01

Issuance Date:  January 30, 2014

Expiration Date:  Retain Until Superseded

Subject: Vendor Waiver Processes for Electronic Funds Transfer, Invoice Processing Platform, and Treasury’s Automated Standard Application for Payments System. 

Instruction:  Replaces IM AEI 2012-05.

1.  Purpose.

This instructional memorandum provides policy and procedures on requesting vendor waivers for Electronic Funds Transfers (EFT), System for Award Management (SAM) formerly known as Central Contractor Registration (CCR), the Invoice Processing Platform (IPP), and Treasury’s Automated Standard Application for Payments (ASAP) system.

2.  References.

A.  The Debt Collection Improvement Act of 1996 (DCIA) (31 CFR Part 208) http://fms.treas.gov/eft/regulations/31cfr208.txt, requires that all payments be made electronically via EFT, unless specifically waived.  The DCIA also requires that we provide the Department of Treasury with taxpayer identification numbers (TIN) on all payment vouchers.  This includes salary payments, travel payments, and payments to vendors.  Electronic payment occurs when the payment is made directly through the banking system to the recipient’s bank account.  The Department of the Interior Acquisition Policy Release (DIAPR) 2012-06, Amendment 1, requires that an EFT waiver be approved and submitted via a Financial Business and Management System (FBMS) Help Desk Ticket.

B.  FAR 4.1102(a) (October 1, 2003), required all prospective vendors to be registered in CCR prior to award of a contract or agreement, with few exceptions.  CCR, the primary vendor database for the U.S. Federal Government transitioned to a new database called System for Award Management (SAM) located at http://www.sam.gov.  Throughout the remainder of this document SAM will refer to CCR and SAM. Exceptions can be granted on an individual basis in limited conditions, with formal waiver documentation and approval.  DIAPR 2012-07 requires that the Bureau Procurement Chief provide written approval of a waiver documenting the approved exception before an award can be made to a vendor not registered in the SAM system.

C.  DIAPR 2011-04, as amended, established policy regarding the use of special electronic invoicing requirements in solicitations and contracts issued using the FBMS.  IPP will be used as the electronic invoicing solution for FBMS.  The Department of Treasury Financial Management Service in partnership with the Federal Reserve Bank of Boston, a fiscal agent of the U.S. Treasury, provides the IPP service.  Effective May 1, 2011, the Department of the Interior (DOI or Department) mandated bureaus currently deployed on FBMS to incorporate the IPP clause, with limited exceptions.  DIAPR 2011-04 established a requirement for approval of a waiver for any vendor (not otherwise excluded) not using IPP.  Each bureau’s waiver request must be approved by the Department since all FBMS bureaus share a vendor record.

D.  DIAPR 2012-06, Amendment 1 (EFT) and DIAPR 2011-04 Amendment 4 (IPP) established that approved waivers will expire after 2 years from date of approval, at which time the vendor must reapply if the waiver condition still exists.

E.  Treasury’s Automated Standard Application for Payments (ASAP) System.  The DOI mandated bureaus currently deployed on FBMS to use ASAP for all financial assistance payments.  If a recipient is unable to use ASAP, typically true for foreign recipients, an ASAP waiver must be approved by the Department.

3.  Responsibilities.

A.  Chief, Office of Acquisition and Grants (OAG), will review and approve/disapprove all EFT, SAM, and IPP waiver requests.  Invitational travelers are the ONLY exceptions and do not require OAG approval.

B.  Financial Assistance Contracting Officers, OAG, will: (i) submit all ASAP waiver requests to the FBMS Project Management Office; and (ii) assist cost centers and grant recipients with questions regarding ASAP.

C.  Chief, Accounts Payable and Travel Branch (APTB), Office of Accounting and Financial Management, will review and approve/disapprove EFT and SAM waiver requests for non-PRISM (micro-purchase) requests and submit to the Chief, OAG, for final approval.

D.  Office of Accounting and Financial Management Vendor Desk:  (i) assists cost centers and vendors with questions regarding SAM and EFT payments; and (ii) submits vendor requests to the Departmental Master Data Management Vendor Team via FBMS Help Desk Tickets.

E.  Cost Center:  (i) provides vendor with information regarding EFT, SAM, and IPP when necessary; and (ii) submits requests for EFT and SAM waivers for vendors related to micro-purchases.

4.  Policy.

A.  Automated Clearing House (ACH)/Electronic Funds Transfer (EFT).  All Federal payments must be made electronically via ACH/EFT, unless specifically waived.  Treasury regulations allow for the following waivers to the EFT portion of the DCIA, 31 CFR Part 208.4:

(1)  An individual determines, at his or her sole discretion, that payment by electronic funds transfer would impose a hardship due to a physical or mental disability; a geographic, language, or literary barrier; impose a financial hardship; or where the individual does not have an account with a financial institution.

(2)  The political, financial, or communications infrastructure in a foreign country does not support payment by EFT.

(3)  Payment to a recipient in a designated disaster area.  Waiver is limited to submission of invoices made within 120 days after the disaster is declared.

(4)  A war or national emergency designated by the President or Congress or a military operation designated by the Secretary of Defense.

(5)  Payment by EFT may pose a threat to national security, jeopardize the life or physical safety of an individual, or compromise a law enforcement action.

(6)  The contract terms allow for a foreign vendor to invoice and be paid in foreign currency.

(7)  The cost of using EFT for making a non-recurring payment is greater than the cost of making that payment by check.  (Note: a non-recurring payment is defined as no more than one payment expected in a 12-month period to a particular payee.)

(8)  Where the USGS need for goods or services is of such a compelling urgency that the Government would be seriously injured unless payment is made by a method other than EFT; or where there is only one source for goods or services and the Government would be seriously injured unless payment is made by a method other than EFT.

All employees, as a condition of employment with USGS, will have their salaries paid to them electronically.  All non-salary payments to employees (e.g., travel reimbursements and claims for reimbursements such as training costs) must also be made electronically. 
 
The method of payment, wire transfer versus payment by check, must be identified for foreign vendors.

B.  System for Award Management (SAM) for Vendors.  The SAM, (formerly known as CCR), is the primary vendor database for the U.S. Federal Government.  Prospective vendors must be registered in SAM prior to the award of a contract, purchase order, delivery order, basic agreement, basic ordering agreement, or blanket purchase agreement.  Prior to registering in SAM, the vendor must obtain a Data Universal Numbering System (DUNS) number from Dun and Bradstreet.  Vendors complete a one-time registration to provide basic information relevant to procurement and financial transactions.  Vendors are required to renew their registration annually to maintain an active status and to ensure banking information is still valid to facilitate payment by EFT.  The data entered in SAM by the vendor is used to automatically create the vendor’s master record in FBMS.  SAM validates the vendor TIN and Social Security Number and electronically shares the secure and encrypted data with Federal agency finance offices to facilitate paperless payments through EFT.  In addition to the Federal Acquisition Regulations (FAR) exceptions listed below, the following actions are excluded from the DOI waiver requirements for SAM:

(1)  Invitational Travelers.

(2)  Tort Claim Payments.

FAR 4.1102(a) http://www.acquisition.gov/far/current/html/Subpart%204_11.html#wp1073576 provides a listing of SAM exceptions, summarized below:

(a)  Purchases that use a Government-wide commercial purchase card as both the purchasing and payment mechanism, as opposed to using the purchase card only as a payment method.

(b)  Classified contracts when registration in the SAM database, or use of SAM data, could compromise the safeguarding of classified information or national security.

(c)  Contracts awarded by:

(i)  Deployed contracting officers in the course of military operations, including, but not limited to, contingency operations or humanitarian or peacekeeping operations.

(ii)  Contracting officers in the conduct of emergency operations, such as responses to natural or environmental disasters or national or civil emergencies.

(d)  Contracts to support unusual or compelling needs.

(e)  Awards made to foreign vendors for work performed outside the United States, if it is impractical to obtain SAM registration.

(f)  Micro-purchases that do not use the EFT method for payment and are not required to be reported. 

Please note that:

1.  FAR 4.1103 (b) authorizes the Contracting Officer to award to the next most advantageous offer when the otherwise successful vendor will not register.

2.  The foreign vendor exception applies only when performance is outside the United States and when it is impractical for the vendor to register.

3.  Even if the SAM waiver is approved, vendors must have a DUNS number in order for an award to be issued in PRISM.

C.  Invoice Processing Platform (IPP).  IPP will be used as the electronic invoicing solution for FBMS.  Contracting Officers must include the IPP requirements template for insertion to all solicitations and contracts.  However, the following actions are excluded from IPP:

(1)  Interagency agreements awarded to Federal suppliers.

(2)  Grants and cooperative agreements disbursed through the Treasury ASAP System.

(3)  Miscellaneous obligations.

(4)  Real property leases for space.

(5)  Awards converted to FBMS from legacy systems.

(6)  Awards issued in PRISM prior to May 1, 2011 (except for those vendors participating in the IPP pilot prior to May 1, 2011).
 
(7)  PRISM awards using a Government purchase card for payment to vendors.

(8)  Awards that are modified to add Alt Payee Information if the Alt Payee is the vendor invoicing (if the Purchase Order (PO) vendor is invoicing, the PO would not be excluded).

(9)  Non-referencing payments.

(10)  Construction awards (UPC code starts with ‘Y’ or ‘Z’), issued prior to October 1, 2011.

(11)  Relocation services contractors (UPC code = V3010100).

(12)  Utility POs with one of the following UPC Codes S1110000, S111000E, S1110001, S11100W1, S1120000, S112000E, S1120001, S11200W1, S1140000, S114000E, S1140001, S11400W1, S1190000, S119000E, S1190001, or S11900W1.

(13)  POs awarded to a vendor without a Tax Identification Number (TIN), Employee Identification Number (EIN), or Social Security Number (SSN).

Contracting Officers may request a waiver from the use of the IPP requirement if the requirement would impose a hardship on the vendor.

Attachment A provides a letter template that can be used to explain the EFT and SAM requirements to vendors.

D.  Automated Standard Application for Payments (ASAP).  The Department requires that all payments be made to financial assistance recipients, after FBMS implementation, via the ASAP system.  Waivers to this requirement may be granted only under the conditions described below.

(1)  An individual with or without an account with a financial institution determines that payment through ASAP would impose a hardship due to either a physical or mental disability, language, or literacy barrier.  The requirement to receive payment via ASAP is automatically waived for all individuals who are not eligible to open an electronic transfer account under Public Law 104-208.

(2)  The recipient’s geographical area has been identified on the National Broadband Map as an area where there is no Internet service due to unavailable broadband providers.  Lack of Internet access is not an acceptable justification for financial hardship or for recipients that are required to register in Dun and Bradstreet and SAM.

(3)  Non-domestic/foreign recipient where the recipient’s foreign address prevents ASAP registration or recipient does not have a United States bank account and/or headquarters office.

(4)  Where the payment is to a recipient within an area designated by the President or an authorized agency administration as a disaster area.  This waiver is limited to payments made within 120 days after the disaster is declared.

(5)  A response to contingency operations conducted by or in support of the Department of Defense.

(6)  Where use of ASAP may pose a threat to national security, the life or physical safety of an individual may be endangered, or a law enforcement action may be compromised.
 
(7)  Where an agency’s need to deliver funding is of such unusual and compelling urgency that the public and/or the Government would be seriously injured unless payment is made by a method other than ASAP; or where there is only one possible recipient, and the public and/or the Government would be seriously injured unless payment is made by a method other than ASAP.

5.  Waiver Requests.

A.  SAM, EFT, and IPP Waivers.  Written approval is required by the Chief, OAG, for all SAM, EFT, and/or IPP waiver requests, including micro-purchases not using the Governmentwide commercial purchase card.  The waiver request must:

(1)  Identify the applicable SAM, EFT, and IPP exception on the applicable waiver request form and demonstrate how the exception applies.

(2)  Explain the need to apply the exception, including efforts made to get this vendor to comply and to locate other vendors who can comply.  In the case of requests claiming urgency, describe the injury the Government would suffer if the award was delayed while waiting for the vendor to register and/or locating another source.

(3)  Waiver requests for PRISM awards must be sent by the Contracting Officer to the Chief, OAG, via the process delineated in PPM 2012-01. Waivers will be signed electronically and saved to the appropriate location within OAG SharePoint.  OAG will maintain a log of incoming requests and track them through the response.

(a)  Attachment B1 provides the EFT Waiver Request Form, and Attachment B2 provides the IPP Waiver Request Form. 

(b)  Attachment C provides the SAM Waiver Request Form template.

(c)  An FBMS Vendor Request Form (Attachment D) must be submitted to the vendordesk@usgs.gov for all vendors not in SAM.  Detailed instructions on how to submit a vendor request are included in the Financial Operating Procedures Handbook (http://internal.usgs.gov/ops/ofs/fop-handbook/FOPindex.html).

B.  Micro-Purchase EFT and SAM Waiver Requests.  An EFT and SAM waiver request for a micro-purchase must be sent by the Administrative Officer to the Chief, APTB, via email to vendordesk@usgs.gov.  Prior to submitting any waiver requests, the center must verify that the vendor does not accept charge card payment and, if not, request that the vendor register in SAM.  Requests must include validation that these steps were taken and include a justification of why the waiver is necessary.  The Chief, APTB, will submit the requests to the Chief, OAG, for approval using the OAG SharePoint site.  Attachment B1 provides the EFT Waiver Request Form and attachment B2 provides the IPP Waiver Request Form.  Attachment C provides the SAM Waiver Request template.

(1) An FBMS Vendor Request Form (Attachment D) must be submitted along with all waiver requests in order to submit the request for upload in FBMS.  Detailed instructions on how to submit a vendor request are included in the Financial Operating Procedures Handbook (http://internal.usgs.gov/ops/ofs/fop-handbook/FOPindex.html).

C.  ASAP Waiver Requests.  ASAP Waiver Request Forms (Attachment E) must be submitted to the FBMS Project Management Office via a FBMS help desk ticket by a Contracting Officer.  Waiver forms will then be reviewed by the FBMS Financial Assistance Team and sent to the Department for review and decision.  Recipients waived from ASAP can be paid by the Office of Accounting and Financial Management.

6.  Micro-Purchase Waiver Processing Procedures.  In cases where the agency does not expect recurring invoices from the same vendor within a 1-year period and the cost of submitting the electronic invoice exceeds the cost of submitting the invoice by mail, cost centers should work with the Bureau Charge Card Lead, OAG, to determine if payment by convenience check is authorized.  If a non-referencing payment is required, the SAM waiver process is required.

 

/s/ Karen D. Baker                                                                                       January 30, 2014
__________________________________________                                    _____________
Karen D. Baker                                                                                                           Date   
Acting Associate Director for Administration and Enterprise Information
and Human Capital

Attachment A, Sample Vendor Letter requesting EFT/CCR/IPP signup
Attachment B1, EFT Waiver Request
Attachment B2, IPP Waiver Request
Attachment C, CCR Waiver Request
Attachment D, Vendor Application
Attachment E, Automated Standard Application for Payments (ASAP) Waiver Request

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