BNUMBER:  B-247563.3
DATE:  April 5, 1996
TITLE:  Expenditures by The Department of Veterans Affairs
Medical Center, Oklahoma City, Oklahoma

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Matter of:Expenditures by The Department of Veterans Affairs                 
Medical Center, Oklahoma City, Oklahoma

File:     B-247563.3

Date:     April 5, 1996     
______________________________________________________________________
_  
DIGEST

1.  The Department of Veterans Affairs' appropriation for medical care 
was not available for the purchase of novelty items to potential 
employees.  These items did not directly contribute to an authorized 
function and, therefore, were not justified under the "necessary 
expense rule."

2.  The Department of Veterans Affairs was not authorized to use its 
medical care appropriation for contest prizes during Women's Equality 
Week absent evidence that the expenditures related to authorized 
activities of the department.

3.  The Department of Veterans Affairs' appropriation for medical care 
was not available to pay the sponsor fees and other costs associated 
with employees' participation in a competitive sporting event since 
such events are personal activities of the participants.

4.  In the absence of a statute or regulation imposing liability, 
agency officials who are not designated as accountable officers are 
not personally liable for illegal, improper, or incorrect payments.  
Officials for whom the Department of Veterans Affairs requests relief 
are not accountable officers and, thus, are not liable for 
unauthorized payments.

5.  To enhance accountability and help to safeguard public funds, 
agencies should designate officials authorized to issue third party 
drafts under the Department of the Treasury's third party draft system 
as accountable officers or issue regulations under which such 
individuals would be held financially liable for improper payments.
______________________________________________________________________
_
DECISION

In the aftermath of an investigation by the Department of Veterans 
Affairs' (VA) Office of Inspector General (IG), VA has requested an 
opinion on the legality of 72 expenditures made between March 1990 and 
September 1991 by the VA Medical Center in Oklahoma City, Oklahoma 
from VA's medical care appropriation.  VA has also requested relief 
from liability for seven Medical Center officials believed to be 
liable for the payments.  Finally, VA has requested guidance on the 
liability of various procurement and financial management officials 
for improper payments.

To facilitate our analysis and discussion, we have divided the 72 
expenditures at issue into four general categories:  recruitment, 
contests, refreshments, and miscellaneous purposes.  In this decision, 
we address the Medical Center's 15 expenditures for recruitment and 
contests.[1]  We will address the 57 expenditures for refreshments and 
miscellaneous purposes in a separate decision.

As discussed below, we conclude that of the eight recruitment-related 
expenditures totalling $10,096.71 submitted for our review, four, 
totalling $2,782.21, were unauthorized.  In addition, we conclude that 
all seven of the Medical Center's 
contest-related expenditures totalling $2,394.59 were unauthorized.  
Finally, we conclude that the officials for whom VA has requested 
relief are not liable for the improper payments.  

BACKGROUND

During the period covered by the IG's investigation, the Medical 
Center purchased a variety of novelty items for distribution in 
connection with its recruiting efforts.[2]   Specifically, the Medical 
Center separately purchased holiday rope pens, folding scissors, and 
shoe laces imprinted with the Medical Center's logo or slogan 
totalling $2,507.10 for potential nurse recruits at three colleges 
where VA maintains adjunct facilities.[3]  In addition, the Medical 
Center purchased $275.11 worth of patches for the local Explorers 
Post.

During the same period, the Medical Center purchased three gift 
certificates for local restaurants and a silk plant, totalling 
approximately $80.00, for distribution as prizes during Women's 
Equality Week, 1990.  The Medical Center also made three expenditures 
totalling $2,314.60 in connection with the 1991 Presbyterian Hospital 
Corporate Challenge, a local athletic event in which Medical Center 
personnel participated.  Specifically, the Medical Center paid a 
$1,200.00 sponsor fee, purchased t-shirts for Medical Center 
participants, and rented a tent for the event.  According to Medical 
Center officials, participation in the Corporate Challenge enhanced 
employee morale and publicity for the Medical Center and demonstrated 
the Medical Center's emphasis on "networking with other . . . leading 
corporations."[4] 
Payments for these items were made from VA's appropriations for 
"Veterans Health Service and Research Administration, Medical Care" 
for fiscal years 1990 and 1991. The appropriations were available, 
among other things, for necessary expenses for the maintenance and 
operation of hospitals, nursing homes, and domiciliary facilities and 
for furnishing inpatient and outpatient care and treatment to VA 
beneficiaries.  Title I of the Departments of Veterans Affairs, 
Housing and Urban Development and Independent Agencies Appropriations 
Act, 1991, Pub. L. No.
101-507, 104 Stat. 1351, 1352-1353 (1990); Title I of the Department 
of Veterans Affairs, Housing and Urban Development and Independent 
Agencies Appropriations Act, 1990, Pub. L. No. 101-144, 103 Stat. 839, 
840-841 (1989).

DISCUSSION

Under 31 U.S.C.  sec.  1301(a) (1994), appropriated funds are available 
only for authorized purposes.  During the period covered by the IG's 
investigation, VA did not have express authority to make the types of 
recruitment and contest-related expenditures at issue here.  Since the 
expenditures were not expressly authorized, they were permissible only 
if reasonably necessary or incident to the proper execution of an 
authorized purpose or function of the agency.  71 Comp. Gen. 527 
(1992).  The application of the "necessary expense rule" is, in the 
first instance, a matter of agency discretion.  However, agencies do 
not have unfettered discretion.  Therefore, when we review an 
expenditure to determine whether it falls within an authorized purpose 
or function, we consider whether, under the circumstances, the 
relationship between the authorized function and the expenditure is so 
attenuated as to take it beyond the agency's legitimate range of 
discretion.  B-257488, 
Nov. 6, 1995.

Expenditures for Recruitment

Under the "necessary expense rule," an agency may purchase items in 
the nature   of gifts or souvenirs only where there is a direct link 
between the items and the purpose of the appropriation to be charged.  
In B-234241, May 3, 1989, and           B-230062, Dec. 22, 1988, we 
found such a direct link.  Those cases involved the Army's purchase of 
framed recruiting posters for distribution as prizes at national 
conventions of medical professionals and student organizations.  We 
observed in those cases that the Army was statutorily required to 
"conduct an intensive recruiting campaign . . . ."  Further, the Army 
used the posters to induce convention attendees to provide recruiters 
with personal information and thus facilitated the Army's recruiting 
efforts.  Therefore, the Army's expenditure was directly related to 
the accomplishment of its statutory mandate.  In contrast, in 
B-236763, 
Jan. 10, 1990, we addressed a proposal to distribute pen and pencil 
sets at job fairs as favorable reminders of the agency.  The pen and 
pencil sets could not have served as a means of advertising since they 
would have been presented only to those already in attendance at the 
job fairs and they could not otherwise be justified as a "necessary 
expense."  See also B-260260, Dec. 28, 1995 (Department of Energy's 
purchase of baseball caps for personnel recruitment purposes not 
authorized given the absence of a direct relationship between the 
purchase and the Department's recruiting efforts).
    
The record contains no suggestion that the shoelaces, pens, and 
scissors distributed to potential employees served as anything other 
than favorable reminders of VA.  Unlike the posters at issue in 
B-234241 and B-230062, the items at issue here did not facilitate VA's 
acquisition of information necessary to its recruiting efforts.  Nor 
did they provide recipients with essential information about VA or the 
Medical Center not commonly available.  Cf. 62 Comp. Gen. 566 (1983) 
(approving the Army's purchase of wall calendars containing 
information about the services provided by the Chaplain's Office and 
Army Community Services for military personnel and their families).  
Rather, the shoelaces, pens, and scissors contained only a slogan or 
logo to remind the recipient of his or her contact with the VA 
recruiters.  Finally, the record contains no evidence that, like the 
situation in B-247563.2, May 12, 1993, VA needed to use promotional 
items to advertise the nurse recruiter's availability to attract 
potential employees.  To the contrary, like the situation in B-236763, 
the availability of VA recruiters was likely known among students 
interested in medical careers at the colleges where VA maintained 
adjunct facilities and the availability of promotional items likely 
had little discernable effect on the VA's ability to attract 
prospective employees.

Similarly, the Medical Center's purchase of patches for the local 
Explorers Post was not authorized under the "necessary expense rule."  
The Explorers Program is an affiliate of the Boy Scouts.  However, the 
record contains no evidence of a relationship between the Medical 
Center's purchase of patches for young people involved in the 
Explorers Program and legitimate recruiting efforts.  

Congress has acknowledged VA's need for explicit authority to purchase 
items like those at issue here in light of the "necessary expense 
rule" applied in our prior decisions.  Section 203 of the Veterans 
Medical Program Amendments of 1992, 
Pub. L. No. 102-405, 106 Stat. 1983, 1984 (1992), added subsection (f) 
to 38 U.S.C. 
 sec.  7423, authorizing VA to "purchase promotional items of nominal value 
for use in the recruitment of [health care personnel]."  Considering 
the provision that became section 203, the House Committee on 
Veterans' Affairs observed that VA needed specific authority to 
purchase promotional items in light of our decisions and those of VA's 
General Counsel.  See H.R. Rep. No. 130, 102d Cong., 1st Sess. 13-14 
(1991) (discussing section 203 of H.R. 2280, the Veterans' Health Care 
and Research Amendments of 1991, which was ultimately passed as part 
of the 1992 legislation).  Thus, Congress recognized that the 
purchases at issue here were neither explicitly nor implicitly 
authorized when they were made.[5]      
 
Contest-Related Expenditures

Agencies are authorized to sponsor contests and provide prizes under 
the "necessary expense rule" when the expenditures for the contest 
bear a reasonable relationship to carrying out an authorized activity.  
E.g., 70 Comp. Gen. 720 (1991) (approving a proposal to pay cash 
prizes to selected fishermen providing needed information to the 
National Oceanic and Atmospheric Administration).  Federal agencies 
and employees, like all Americans, were encouraged by the President to 
observe Women's Equality Day[6] with appropriate programs, ceremonies, 
and activities.  See 26 Weekly Comp. Pres. Doc. 1253 (August 14, 
1990).  However, in its submission and in response to our subsequent 
requests for information, Medical Center officials have failed to 
establish how awarding three gift certificates to local restaurants 
and a silk plant in connection with a contest advanced its celebration 
of Women's Equality Week.  Given the Medical Center's failure to 
explain the relationship of these gifts to its observation of Women's 
Equality Week, we have no basis to conclude that the Medical Center's 
purchases of these contest prizes was a reasonable exercise of its 
discretion under the "necessary expense rule."  

The Medical Center's three expenditures incident to the Corporate 
Challenge were also clearly unauthorized under our decisions.  An 
agency may only use appropriated funds to pay a contest entry fee 
where the agency's participation in the contest will further the 
purposes of its appropriation.  See, e.g., B-164467, 
Aug. 9, 1971 (approving the Bureau of Mines' use of appropriated funds 
to enter a Bureau film in an annual film contest on the grounds that a 
winning film would broaden public awareness of mine safety issues 
consistent with the Bureau's mission).   

In B-256194, June 1, 1994, we considered the Department of Energy's 
expenditure of appropriated funds for registration fees of employees 
participating in a local athletic event.  We concluded that 
competitive fitness events are essentially personal activities and 
that the costs of such activities must be borne by the participants.  
The athletic event in which Medical Center employees participated was 
virtually indistinguishable from the contest at issue in B-256194.  
Therefore, the expenses incurred by the Medical Center incident to the 
Corporate Challenge, i.e., the sponsor fee, t-shirts, and tent rental, 
were also personal to the participants. 
Accordingly, despite its assertions that the expenditures were for 
advertising and morale enhancement, the Medical Center was not 
authorized to use appropriated funds for those expenses.
 
Liability of VA officials 

VA has asked that we indicate "what type of accountability applies" to 
various agency officials when improper payments are made."[7]  
Ordinarily, an agency is not authorized to assess pecuniary liability 
against its officials for losses resulting from errors in judgment 
unless a statute provides for such liability or the agency has issued 
administrative regulations specifically providing for such liability.  
65 Comp. Gen. 177 (1986); B-241856.2, Sept. 23, 1992.  We know of no 
such statute or regulations applicable to VA employees.  

In contrast, officials designated as accountable officers are 
financially liable for losses and improper payments of public funds.  
Specifically, certifying officers are liable to the United States for 
the amount of any illegal, improper, or incorrect payment resulting 
from any false, inaccurate, or misleading certificate made by them, as 
well as for any payment prohibited by law or which does not represent 
a legal obligation under the appropriation or fund involved.  31 
U.S.C.  sec.  3528(a)(4).  Disbursing officers, including cashiers, are 
responsible for examining vouchers to verify their propriety, and are 
liable to the United States for illegal, improper, or incorrect 
payments, as well as for physical losses of government funds.  31 
U.S.C.  sec.  3325(a)(2), 3527.  This Office is authorized to relieve 
certifying and disbursing officers from liability for improper 
payments when applicable criteria are met.  
See 31 U.S.C.  sec.  3527, 3528(b).  

Authorized certifying officers located at VA automated finance centers 
rely on the integrity of the automated payment system as a whole and 
do not physically examine hard copy payment documentation (vouchers) 
in each and every case.  Although the use of an automated payment 
system does not alter the basic concepts of accountability for 
certifying officers, the reasonableness of a certifying officer's 
reliance on an automated payment system to continually produce legal 
and accurate payments is a factor that we consider when addressing the 
officer's liability for illegal or improper payments.  69 Comp. Gen. 
85 (1989).  Further, we have set forth criteria that agencies whose 
certifying officers rely on automated payment systems should satisfy.  
Specifically, certifying officers should be provided with information 
showing that the system on which they rely is functioning properly and 
reviews should be made at least annually to determine that the 
automated system is operating effectively and can be relied upon to 
make accurate and legal payments.  Id. 

VA's certifying officers necessarily rely on various participants in 
the procurement and payment process to ensure that only legal and 
accurate payments are made.  However, these officials, including 
contracting officers and voucher auditors, do not become certifying 
officers subject to liability for improper payments merely because 
certifying officers rely on their review or approval of purchases or 
payments.  
See B-201965, June 15, 1982 (explaining that officials who negligently 
authorize erroneous transactions under an automated payment system are 
not liable as certifying officers for erroneous payments).  Therefore, 
while officials other than certifying officers may be subject to 
administrative sanctions, our Office has never looked to them for 
reimbursement in cases of illegal or improper payments.  
See 55 Comp. Gen. 297 (1975); B-201965 at 4.  Moreover, designation as 
a certifying officer requires a written authorization from the head of 
the agency.[8]  See 31 U.S.C.  sec.  3325; Treas. Financial Manual, vol. I,  sec.  
2040.30d (T. L. No. 496).  Accordingly, unless the other officials 
have also been designated as certifying officers, only the authorized 
certifying officer is financially liable for illegal or improper 
payments.

Many of the expenditures questioned by the VA IG were made under the 
Department of the Treasury's (Treasury) "third party draft system."  
See 1 T.F.M. 
 sec.  3040.70.  Under this system, agencies obtain instruments known as 
third party drafts from contractors[9] and use them for the same types 
of purchases that they could make with imprest funds.[10]  The 
contractors process the instruments as they are presented for payment 
by vendors of goods or services and subsequently provide agencies with 
listings of the cleared instruments, i.e., those paid by a 
contractor's financial institution.  Agencies then reimburse the 
contractors for payments made.

Like imprest fund purchases, purchases made with third party drafts 
may only be made by authorized officials and do not require prior 
certification by an authorized certifying officer.  However, in 
contrast to imprest fund cashiers, issuers of third party drafts are 
not financially liable for improper purchases made with third party 
drafts since government funds are not disbursed when a third party 
draft is issued. 
1 T.F.M.  sec.  3040.70; GAO, Policy and Procedures Manual for Guidance of 
Federal Agencies, tit. 7,  sec.  6.8 (T.S. No. 7-43, May 18, 1993).  
Rather, as the only accountable officers involved in the transactions, 
those who certify reimbursements to contractors are the only officials 
financially liable for improper payments.  Further, Treasury's 
guidance requires agencies to reimburse third party draft contractors 
for the full amount of all properly payable instruments that have been 
paid and states that a "properly payable instrument" is one issued 
over the genuine signature of an authorized payment agent, bearing a 
genuine or authorized endorsement, and with no alterations.  1 T.F.M.  sec.  
3040.70(c).  Therefore, Treasury's guidance advises agencies to 
"establish sufficient internal controls to permit the certifying 
officer to make prompt reimbursements while exercising reasonable 
diligence in reviewing the contractor's request for reimbursement."  1 
T.F.M.  sec.  3040.70(c).

The Medical Center's use of third party drafts for a number of 
questionable and unauthorized payments has led us to question how the 
use of third party drafts relates to the system of individual 
accountability critical to the protection of government funds.  Third 
party drafts may be used for a variety of small purchases.  Further, 
reimbursements required under the third party draft system may be 
automated.  Authorized certifying officers may have little or no 
opportunity to question the legality of such reimbursements and the 
underlying purchases before payment is made.  Rather, they must rely 
on others, particularly those authorized to issue third party drafts, 
to ensure that purchases are consistent with governing statutes, 
regulations, and decisions of this Office regarding the proper uses of 
appropriated funds.  In our view, this division of responsibility and 
liability in connection with transactions amounting to constructive 
payments of government funds contravenes basic principles of 
accountability and poses an unacceptable risk to the safeguarding of 
those funds.  Accordingly, we recommend that agencies designate 
individuals authorized to issue third party drafts as accountable 
officers or issue regulations under which such individuals would be 
financially liable for improper payments.

We now turn to VA's specific requests for relief.  VA has identified 
an imprest funds clerk as the official who purchased the patches for 
the local Explorers Post and the three gift certificates and silk 
plant in connection with Women's Equality Week.  As an imprest funds 
clerk, the individual issued third party drafts for each of those 
items.  As discussed above, issuers of third party drafts are not 
accountable officers subject to financial liability for unauthorized 
purchases, unless otherwise so designated.  Therefore, we need not 
consider VA's request for relief.
  
VA has also requested relief from liability for three officials 
involved in the three expenditures made for the Corporate Challenge:  
a visual information specialist and two voucher examiners.  The visual 
information specialist designed and developed the t-shirts for contest 
participants.  She also approved the purchase request and forwarded it 
to a purchasing agent.  Payment was ultimately made through VA's 
finance center in Austin.  While she clearly participated in the 
procurement of the  t-shirts, the visual information specialist was 
not an accountable officer with respect to this unauthorized purchase.  
Therefore, she is not financially liable for the unauthorized use of 
appropriated funds and we need not grant her relief.  

A voucher examiner reviewed the documents associated with the Medical 
Center's rental of a tent and another voucher examiner carried out the 
same function with respect to the sponsor fee paid in connection with 
the Corporate Challenge.  Following their reviews, each "certified" 
invoices for the tent rental and sponsor fee for payment through the 
Austin center.  We understand that as voucher examiners, both reviewed 
all payment documentation for the services received by the Medical 
Center incident to the Corporate Challenge and approved the payments.  
In this regard, their activities supported the certification 
ultimately made by an authorized certifying officer at the automated 
system level.  Further, several documents included in VA's submission 
refer to their "certifications" or their role as "certifying 
officers."  However, in response to our inquiries, VA advised that 
neither had been designated as a certifying officer.  Consistent with 
the above discussion of liability of agency officials other than 
accountable officers, we conclude that neither is liable for the 
unauthorized expenditures of appropriated funds in connection with the 
Corporate Challenge.  Accordingly, we need not consider VA's requests 
for relief.  

VA requested relief from liability for seven Medical Center officials 
in connection with 52 of the Medical Center's 72 questionable 
expenditures[11] and we have addressed VA's request with respect to 
the expenditures made for the Explorers Program, Women's Equality 
Week, and the Corporate Challenge.  However, these payments, as well 
as those for the shoelaces, pens, and scissors, were also approved by 
authorized certifying officers.  Since VA's expenditures in connection 
with Women's Equality Week and the Corporate Challenge, as well as 
four of the eight recruiting-related expenditures, were improper and 
authorized certifying officers are strictly liable for improper 
payments, we now consider whether the relevant certifying officer(s) 
should be granted relief from liability.

This Office may relieve a certifying officer from liability for an 
improper payment where "the obligation was made in good faith; no law 
specifically prohibited the payment; and the United States Government 
received value for the payment."  
31 U.S.C.  sec.  3528(b)(1)(B).  Under this criteria, we conclude that we 
may grant the relevant certifying officer(s) relief from liability for 
the improper payments discussed above. 

We have previously observed that an important factor in determining 
whether a certifying officer acted in "good faith" is whether the 
certifying officer had, or reasonably should have had, doubt regarding 
the propriety of the payments. 
See, e.g., 70 Comp. Gen. 723 (1991).  Whether the certifying officer 
reasonably should have been in doubt in any particular case depends on 
a weighing of all surrounding facts and circumstances.  Id. at 726. 
 
All of the improper payments at issue here, whether reimbursements for 
third party drafts or direct payments on invoices, were ultimately 
made by the finance center in Austin.  As discussed previously, 
certifying officers at the Austin finance center were in no position 
to question individual expenditures made by the Oklahoma City Medical 
Center.  Rather, they relied on reviews conducted by other VA 
officials, such as approving officials and voucher examiners.  
Although the record suggests that individuals serving in various 
capacities may have required additional training and may have made 
faulty judgments, it does not indicate that the system under which 
invoices were processed and payments were made was unreliable as a 
whole.  Therefore, we cannot conclude that the certifying officer(s) 
should have had doubt about the propriety of the expenditures 
certified.    

The certifying officer(s) in this case meet the second and third tests 
contained in 
31 U.S.C.  sec.  3528(b)(1)(B) as well.  No statute specifically prohibited 
the expenditures at issue.  See B-191900, July 21, 1978 (pointing out 
that this element refers to statutory prohibitions of payments for 
specific items or services).  Finally, there is no suggestion in the 
record that the United States government did not receive value for the 
payments made by VA.  Accordingly, we grant the certifying officer(s) 
who approved the payments at issue here relief from liability.  

CONCLUSION

VA's medical care appropriation was not available for several of the 
purchases identified in the IG's report on the Oklahoma City Medical 
Center.  Since none of the officials specifically identified by VA in 
connection with the unauthorized expenditures were accountable 
officers, they are not liable for these payments.  However, to enhance 
accountability and help safeguard public funds, VA should designate 
those authorized to issue third party drafts as accountable officers 
or otherwise provide for financial liability for improper payments 
made with such instruments.  Finally, relief is granted to the 
authorized certifying officer(s) who approved the payments.

/s/Robert P. Murphy
for Comptroller General
of the United States  

ATTACHMENT                                           ATTACHMENT

Recruitment - 8 expenditures

PO#          Amount                Description         

A07539       936.00                Stick Matchbooks         
A16327       2717.00               Balloons, ID Kits, Buttons
A17674       2961.50               Jar Grip Openers                      
IF1109       700.00                Booth at Oklahoma State Fair 
A11050       575.00                Holiday Rope Pens                    
A13199       900.00                Folding Scissors                     
A15757       1032.10               Shoelaces with Logo           
IF1217       275.11                Explorer Patches                     

Total -  $10,096.71

Contests - 7 expenditures

PO#          Amount                Description         

IF0351       20.00                 Gift Certificate                     
IF0350       20.00                 Gift Certificate                     
IF0349       20.00                 Gift Certificate                 
IF0367       19.99                 Silk Plant                           
A17378       814.60                T-shirts for Corporate Challenge     
C16211       300.00                Tent Rental for Corporate Challenge 
C15930       1200.00               Sponsor Fee for Corporate Challenge

Total- $2,394.59 

1. An attachment to this decision identifies the recruitment and 
contest-related expenditures addressed.

2. Four of the eight recruitment-related expenditures were associated 
with the Medical Center's activities at the 1991 Oklahoma State Fair.  
We previously concluded that VA's medical care appropriation was 
available for three of these expenditures.  B-247563.2, May 12, 1993 
(regarding the Medical Center's rental of a booth and its purchases of 
matchbooks and jar openers).  In this request, VA also asks whether 
the medical care appropriation was available for its purchase of 
balloons, ID kits, and buttons imprinted with the VA seal and the 
Medical Center's telephone number.  Since there is no meaningful 
distinction between the expenditure for balloons, ID kits, and buttons 
and the other Fair-related expenditures addressed in our prior 
decision, we conclude that VA's medical care appropriation was 
available for this fourth expenditure as well.     

3. VA asserts without explanation that these items were also used by 
Medical Center staff performing their day-to-day duties and in 
conjunction with the Medical Center's awards program.  

4. According to the IG's report, the Medical Center director asserted 
that the
t-shirts purchased for the competition were also used throughout the 
year in connection with various awards programs.

5. The items distributed would appear impermissible under VA's 
guidance implementing 38 U.S.C.  sec.  7423(f).  The guidance provides as 
follows: 

        "To serve as a recruitment aid, the item will include a 
permanent display of:

        "The Department's VA logo and/or the name of either the 
Department or VHA facility purchasing the item.

        "A telephone number and/or address to provide potential 
        applicants with a VA point of contact for recruitment 
        followup; and space permitting, a recruitment slogan or 
        message."  

MP-4, Part V, Change 206,  sec.  3A.13.1a(3).   

6. The Medical Center's observation of Women's Equality Week was 
presumably an outgrowth of the national observation of Women's 
Equality Day.

7. VA uses the word "accountability" to refer to pecuniary liability 
and the phrase "improper payment" to refer to expenditures that are 
impermissible under statutes, regulations, and decisions of this 
Office regarding the purposes for which appropriated funds may be 
used.   

8. In response to the IG's report, the Medical Center updated the 
position descriptions for its voucher auditors to include the 
following statement: 

            "[A]s a certifying official, you are personally 
            accountable and individually responsible for verifying 
            that [f]ederal [g]overnment payments made under your 
            jurisdiction are legal, proper, and correct.  You are 
            pecuniarily liable if any payment that you have certified 
            is found to be illegal, improper, or incorrect."

The Department of the Treasury requires agencies to take additional 
action when  designating employees as certifying officers, 
specifically the completion of a signature/designation card.  See 1 
T.F.M.  sec.  2040.30d.  

9. Three contractors provide third party draft services to federal 
agencies.  Two of the entities are themselves financial institutions 
and the third clears third party drafts under an arrangement with its 
financial institution.

10. The 1995 modification to the Treasury Financial Manual expanded 
the use of third party drafts to purchases of up to $10,000.  See 1 
T.F.M.  sec.  3040.70(a) (T.L. No. 553, April 1995).

11. VA's submission came in two parts.  The first contained VA's 
requests for our views on 52 expenditures and relief for seven 
officials associated with those expenditures.  The second contained 
VA's request for our views on 20 additional expenditures, but did not 
include any requests for relief.