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.