Summary: This report responds to a request made by the Defense Finance and Accounting Service (DFAS) that we approve the use of a statistical sampling plan for voucher prepayment examination of contract payments. While Title VII, "Fiscal Guidance," of the GAO Policy and Procedures Manual for Guidance of Federal Agencies requires prepayment examination of vouchers prior to their certification and payment, it permits the use of statistical sampling for vouchers up to $2,500. DFAS requested a waiver of the $2,500 ceiling for statistical sampling and approval of an alternative voucher prepayment examination plan that would, among other things, use statistical sampling for certain vouchers up to a maximum of $500,000 for contract payments.
At this time, we cannot approve the request for a waiver or the proposed alternative sampling plan. The submission, requesting exception to the $2,500 maximum for statistical sampling in voucher prepayment examination, does not justify the projected savings of approximately $4.2 million per year. Further, it is unclear how the proposed plan will adequately protect the government's interest. In addition, absent GAO approval, DFAS certifying officers risk personal liability for improper payments should they rely upon the voucher prepayment examination process under the proposed alternative sampling plan.
