BNUMBER:  B-258357
DATE:  January 3, 1996
TITLE:  [Letter]

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B-258357

January 3, 1996

Mr. Darold D. Foxworthy
Authorized Certifying Officer
Washington Office, Forest Service
Department of Agriculture

Dear Mr Foxworthy:

In your letter of August 26, 1994, you requested that imprest fund 
cashier Bonnie J. Luckman "be relieved of the responsibility to 
reimburse" her imprest fund for a shortage that resulted from the 
physical loss of subvouchers from the fund.  You indicated that Ms. 
Luckman had been billed for the loss because United States Department 
of Agriculture (USDA) "was unable to show that she was not negligent" 
in the loss of the subvouchers.  You further stated that you believed 
"that the government has not sustained a monetary loss but a loss of 
documenation."  You conclude that "it would not be in the best 
interest of the government or in good conscience" to require Ms. 
Luckman to repay her imprest fund shortage because the government did 
not sustain an actual monetary loss.

For the reasons indicated below, we are unable to free Ms. Luckman of 
the responsiblity to repay the shortage in her imprest fund.  Further, 
because USDA has been unable to find that the shortage was not the 
result of Ms. Luckman's fault or negligence, we are unable to relieve 
her of liablity under 31 U.S.C.  3527(a).

Background

On August 14, 1992, Bonnie Luckman, imprest fund cashier at the 
supervisor's office, Sawtooth National Forest, Twin Falls, Idaho, 
reported the loss of a blue folder containing subvouchers (receipts) 
that she was processing for payment to the National Finance Center.  
The folder also contained a cashier subvoucher register, which Ms. 
Luckman had been using as a subvoucher log to permit reconstructing 
the file in case of loss.  Ms. Luckman indicated that at the time the 
folder disappeared she had been carrying it with her during a fire 
situation at the forest awaiting an opportunity to complete reporting 
payments.  An extended search over more than two months failed to 
locate the folder.

Ms. Luckman has indicated that the subvouchers represented purchases 
that she made for the national forest.  However, because her 
subvoucher log as well as the subvouchers were lost, Ms. Luckman's 
attempt to reconstruct her account proved unsuccessful.  She was only 
able to identify a small proportion of the purchases she made.  
Further, although Forest Service budget and accounting officer Jerry 
Gibbons indicates that he saw the subvouchers and the subvoucher log 
in the folder, he apparently cannot verify the amounts and the payees 
represented by the subvouchers.

A Forest Service investigation indicated there was a shortage of 
$1,967.81 in       Ms. Luckman's account.  On February 22, 1994, the 
Forest Service determined that Ms. Luckman was responsible for paying 
back the shortage in her account.

Discussion

Government accountable officers, including imprest fund cashiers, are 
insurers of the public funds in their custody and are strictly liable 
for any losses of those funds.  48 Comp. Gen. 566 (1969).  This Office 
may relieve an accountable officer of liability for a loss if we agree 
with the determination by the head of an agency that (1) the officer 
was carrying out official duties when the loss occurred, and (2) the 
loss was not the result of fault or negligence by the officer.  31 
U.S.C.  3527(a).

As we indicated above, however, you are not requesting that we relieve             
Ms. Luckman of liablity under 31 U.S.C.  3527(a).  Rather, you are 
requesting that we determine that she is not liable because you say 
the government sustained no loss.  We cannot grant your request.

A cashier must fully account for the money with which he or she has 
been entrusted.  See 4 Treasury Financial Manual  3040.80.  If the 
cashier has made cash payments from an imprest fund he or she must 
have sales slips, invoices or some other receipts to support those 
payments.  Id. [1]  Without some documentary evidence to support 
payments from the fund, an unexplained shortage exists in the fund.

The USDA investigation indicates that there is a shortage of $1,967.81 
in            Ms. Luckman's imprest fund.  Although Ms. Luckman claims 
that she spent all the missing money purchasing items for the Forest 
Service and that the Forest Service received these items, she has no 
documentation to support her assertion.  She is unable to reconstruct 
her account to establish any record of purchases with the missing 
money.  She is liable for the shortage in her account and we have no 
authority to free her of that liability.  Moreover, since USDA has not 
(and apparently cannot) determine that the loss in her account did not 
result from Ms. Luckman's fault or negligence, we cannot relieve her 
under 31 U.S.C.  3527(a).

Sincerely yours,

Gary L. Kepplinger
Associate General Counsel
B-258357

January 3, 1996

DIGEST

GAO cannot relieve an imprest fund cashier "of the responsibility to 
reimburse" the imprest fund for a shortage resulting from the loss of 
receipts.  A cashier must fully account for the money with which he or 
she has been entrusted.  If payments have been made from the fund, the 
cashier must have sales slips, invoices, or some other receipt to 
prove the validity of the payments.  Without documentary evidence to 
support the payments the fund has an unexplained loss for which the 
cashier is liable.

1. The Manual of Procedures and Instructions for Cashiers in effect at 
the time of the Ms. Luckman's loss indicates that obtaining a receipt 
is a condition that must be met before a cashier may make a cash 
payment.  See Chapter 7, pp. 23-24 (1985).