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SGM No. 89-01
Date: May 3, 1989

FROM: Associate Director
Office of Administration and Management, IHS

SUBJECT: SGM 89-1 Certifying Officers Roles and Responsibilities

To: Associate Directors, Indian Health Service
Area Directors, Indian Health Service
Service Unit Directors, Indian Health Service

The attached Special General memorandum (SGM 89-1 is being transmitted to you for your immediate distribution to each office within your organization.  Please post SGM 89-1 where public information is posted.

/Edgar R. Caster for/
Milburn H. Roach

SGM 89-01
Date: APR 27, 1989

FROM: Director

SUBJECT: Certifying Officers Roles and Responsibilities
To: Area Directors
Indian Health Service

This memorandum is to remind you of the important role and responsibilities of the Certifying Officers of public funds within the Indian Health Service (IHS).  Certifying Officers that certify vouchers upon which a disbursement of public funds is made must provide a most important defense against possible waste, fraud and abuse.  The IHS Area Directors must assure that the Certifying Officers are allowed to operate independently and free from fear of reprisals when carrying out their responsibilities and efforts to protect government funds.

The Official authority to designate Certifying Officers has been delegated to the Director, Division of Fiscal Services Health Resources and Services Administration.  I have attached a copy of "Certifying Officers, Your Role, Duties and Responsibilities" as a guidance document issued by this office.

In addition, IHS employees (contracting officers, financial management officers, personnel officers, etc.) who have specific administrative authority will not be inhibited or discouraged by higher level officials from performing their official duties in accordance with relevant laws, regulations and policies.

Please address any concerns or questions regarding this policy to Mr. Milburn H. Roach, Associate Director, Office of Administration and Management on FTS-443-7493.

/Everett R. Rhoades, M.D./
Everett R. Rhoades, M.D.
Assistant Surgeon General




"Certifying Officers, Your Role, Duties and Responsibilities"

  1. Designation and Termination of Certifying Officers
    1. The official authority to designate Certifying Officers is the responsibility of each Agency head.  Currently, this authority has been redelegated to the Director, Division of Fiscal Services (DFS), HRSA.  The official designation of a Certifying Officer is accomplished by submitting original copies of SF-210, Signature Card for Certifying Officers.  The SF-210 shows the official signature of the Certifying Officer, the class of voucher or other approved form authorized to be certified, the signature and title of the authorizing official. The completed SF-210 forms must be sent to DFS, HRSA for the signature of the Director, Division of Fiscal Services before being processed to Treasury.
    2. Authorization issued to designated Certifying Officers are deemed to be in effect until officially terminated, revoked or amended with the effective date of such action and the signature of the authorizing official.
  2. Role of Certifying Officer

    In a civilian agency responsibility or "accountability" for payments rests with the certifying officer who certifies voucher payments.  It is the "certification," of a duly designated certifying officer, upon which a Treasury Disbursing Officer relies and disburses public funds.  It is this function that makes the certifying officer an "accountable" officer.

    An accountable officer is any Government officer or employee who by reason of his or her employment is responsible for or has custody of Government funds.  59 Comp. Gen. 113, 114 (1979); B-188894, September 29, 1977.  Accountable officers encompass such officials as authorized civilian and military disbursing officers, certifying officers, collecting officers and other employees who by virtue of their employment have custody of Government funds.

    Unlike a disbursing officer or a collection officer, a Certifying Officer has no public funds in his possession.  He is, however, accountable for and required to make good to the United States only the amount of any illegal, improper, or incorrect payment resulting from any false, inaccurate, or misleading certification made by him, as well as any payment prohibited by law or which did not represent a legal obligation under the appropriation or fund involved.  Until an improper payment based upon the inaccurate certification is made, there is no pecuniary liability on his part nor "accounts" requiring settlement by the General Accounting Office.

  3. Duties and Responsibilities
    1. An Act entitled "To Fix the Responsibilities of Disbursing and Certifying Officers, and for Other Purpose," was approved December 29, 1941, and amended 31 U.S.C. 82C and 82F.  This Act states that the officer or employee certifying a voucher for payment shall except as hereinafter provide:
      1. Be held responsible for the existence and correctness of the facts recited in the certification or otherwise stated on the proposed payment under the appropriation or fund involved; and for correctness of the computations therein.
      2. Be held accountable for and required to make good to the United States the amount of any illegal, improper, or incorrect payment resulting from any false, inaccurate, or misleading certificate made by him, as well as for any payment prohibited by law or which did not represent a legal obligation under the appropriation or fund involved.
    2. The liability of a certifying officer is different from that of other accountable officers because the certifying officer does not actually have public funds in his possession.  The certifying officer's liability derives from the nature of his function, to certify a voucher upon which a disbursement of public funds will be made.  Thus, a certifying officer who certifies a voucher for payment in the full amount claimed, disregarding the fact that the records before him indicate a possible indebtedness to the Government against which the sum claimed is available for offset is accountable for any resulting overpayment.  28 Comp. Gen. 425 (1949).  The certifying officer's accountability includes the correctness of the computations of certified vouchers.  31 U.S.C. 82f.
    3. A certifying officer is not liable until an improper payment is actually made on the basis of the certified voucher.  The liability arises automatically at the moment of the improper payment, and this is true whether the certification involves a matter of fact, a question of law, or a mixed question of law and fact.  55 Comp. Gen. 297, 298 (1975) and cases cited therein.  Under 31 U.S.C. 82d, a certifying officer may obtain a decision of the Comptroller General on any questions of law involved prior to certifying a voucher.  The Act further provides that the liability of the certifying officer or employee shall be enforced in the same manner and to the same extent as provided by law with respect to enforcement of the liability of disbursing and other accountable officers.
    4. Certifying officers are not held reliable for overpayments made for transportation furnished on Government bills of ladding and transportation requests when overpayments are due to the use of improper transportation rates or classifications, or the failure to deduct proper amounts under equalization and other agreements.
  4. Certifying Officers' Right to Advance Decisions
    1. In enacting legislation for the operation of the Government, the Congress is faced with the impracticality of providing specifically for all possible situations that may arise.  In consequence, provisions of law are necessarily stated in general terms.  Also, the Congress frequently writes in limitations respecting program obligations and expenditures.  Therefore, numerous questions arise as to the legality of expenditure.  These questions must be answered conclusively so that the propriety of individual payment and/or the legality of entire programs can be established.
    2. Certifying officers are provided with a means of protection against the certification of vouchers for payment which could subsequently prove to be illegal.  They have the right to apply for and obtain an advance decision from the Comptroller General.  The Comptroller General of the United States is required to render decisions in advance of payment of specific vouchers when there is doubt concerning the legality of payment.  The Department of Health and Human Services has provided procedures to be followed in resolving doubtful claims.  The full procedures are contained in the HHS Voucher Examination Manual (Chapter 5-10).  The applicable part of these procedures are included in IV. C and D.
    3. Procedures for Filing Doubtful Claims

      A claim is doubtful when in the exercise of reasonable prudence either a person having final responsibility for deciding appropriate administrative action or the person who, in accordance with applicable statutes, will be held accountable if the claim were paid and then found to be incorrect, illegal, or improper, is unable to decide with reasonable certainty the validity and correctness of the claim.

      Use of Precedents in Determining Propriety of Payments.  To keep agencies informed, the General Accounting Office provides daily synopses of decisions by the Comptroller General that are of general interest or application.  These decisions are published in both monthly and annual volume.  Unpublished decisions also are made available.  The Office of the General Council, GAO, maintains an index of both published and unpublished decisions and furnishes research service to authorized officials of agencies.  Such service may be used, when necessary, to supplement research materials maintained by an agency and to aid in determining appropriate administrative action in the disposition of claims.

      Routing and Doubtful Claims.  All claims must be sent through usual channels to the Chief Financial Officer of the POC/Agency responsible for making the payment.  It is the responsibility of that officer to determine whether payment may be made or disallowed, or if the claim should be sent to the General Accounting Office for direct settlement.  Claims originating in regional offices will be submitted to the POC/Agency to which the funds involved have been made available.

      Transmittal Letter.  The originating office should prepare an undated letter to the Claims Division, General Accounting Office, Washington, D.C. 20548.  This letter should be prepared for the signature of the Chief Financial Officer of the POC/Agency.  The letter should contain:

      1. A statement setting forth all the reasons for doubt pertinent to the claim, and
      2. The administrative recommendations as to desired action, and copies of all related correspondence, contracts, purchase orders, and any other papers having a bearing on the claim, for consideration by the Chief Financial Officer.

      If the Chief Financial Officer determines that the claim should go forward to the GAO, he should sign the transmittal letter and return it with the claim to the originating office.

      If, however, the Chief Financial Officer determines that the claim is proper for settlement by the originating office, he should return it to the originating office setting forth the basis upon which he is recommending payment be made.

    4. Appeals or Protests

      All appeals or protests against the action taken by the Chief Financial Officer should be sent to him giving the following:

      1. Reason for appeal or protest.
      2. The unsigned but complete SF-1166, Voucher and Schedule of Payments.

      When this has been done, the Chief Financial Officer will then either:

      1. Certify the SF-1166 and (a) return it to the originating office for processing or (b) certify the SF-1166 and pay it, then transfer the charge by Intra-Office Transfer Voucher, or
      2. Forward the claim to the GAO for settlement, and advise the originating office that claim was sent to the GAO.
  5. General Voucher Audit Requirements

    Although each type of voucher varies in the individual examination requirements, certain verifications are common to all.  The general requirements are to determine that:

    1. Computations and extensions are mathematically correct and that all information, such as payee's name and address, has been supplied.
    2. The amount and items claimed are in agreement with the basic documents authorizing the expenditure.
    3. The materials or service for which the voucher is submitted were received or furnished as authorized.
    4. The voucher does not represent a duplicate claim for which a voucher was previously submitted and paid.
    5. The voucher is in compliance with all applicable laws, regulations of the General Accounting Office, Treasury, and Office of Management and Budget, as well as administrative policies of the Department of Health and Human Services.
    6. All permissible cash, trade, quantity or other discounts are being taken, and is not, the reasons therefore is shown on the appropriate document.
    7. All applicable deductions are taken and credited to proper accounts in correct amounts.
    8. The appropriation or fund from which payment will be made is available for that purpose.
    9. The proper forms of documentation are being used.
    10. Special certificates, if needed, are furnished.

    Certifying officers should return payment vouchers that are deficient in documentation to the appropriate administrative officials for proper administrative approvals and supporting documents.  (Comp. Gen. Decision B-1719916, March 11, 1974.)

  6. Relief of Certifying Officers
    1. It is important to distinguish between liability and relief.  The basic legal liability of an accountable officer is strict, automatic, and is not affected by any lack of fault or negligence on his part.  To restate, while lack of fault or negligence may be relevant in determining whether relief may be granted, it is not relevant with respect to the officer's legal liability.  54 Comp. Gen. 112 (1974); B-167126, August 28, 1978.  Lack of fault or negligence may be provided as a basis for relief under one of several statutes.
    2. In addition to prescribing liability, 31 U.S.C. 82c, informally known as the Certifying Officer's Relief Act, also establishes a mechanism for relief.  The Comptroller General, in his discretion may relieve a certifying officer from liability for an illegal, improper, or incorrect payment certified by him if the Comptroller finds either:
      1. that the certification was based on official records and that the certifying officer did not know, and by reasonable diligence and inquiry could not have ascertained, the actual facts; or
      2. that the obligation was incurred in good faith, that the payment was not contrary to any statutory provision specifically prohibiting payments of the character involved, and that the United States received value for such payment.
    3. Unlike 31 U.S.C. 82a-1 and 95a, 31 U.S.C 82c does not require determination by the agency.  The determination under 82c must be made by the Comptroller General.  Also, the determinations under 82c are stated in the alternative - relief may be granted if either of the two determinations can be established.  There is no special form of request under 82c.  Relief may be requested by the agency on behalf of the certifying officer, or by the certifying officer himself.  (31 Comp. Gen 653(1952).)
    4. Both the responsibility and accountability of the Certifying Officer are modified where statistical sampling is used in the certification of vouchers for payment.

      The Comptroller General will relieve accountable Officers of liability for illegal, improper or incorrect payments passed without specific examination under an audit sampling plan that is established to meet the Comptroller General's requirements, provided that the officer acted in good faith and that he/she and the Agency have diligently pursued collection action to recover the illegal, improper or incorrect payment in accordance with prescribed collection procedures.

  7. Use of this Summary Document
    1. It is extremely important that each Certifying Officer recognize and become familiar with the role, duties and responsibilities of effectively carrying out the statutory requirements of this function.  It is recommended that this summary be used as an orientation and briefing document for currently assigned and newly appointed Certifying Officers.  This summary is not designed or intended to replace or supplement statutes, laws, regulations or Comptroller General Decisions.
    2. The following references are provided to assist Certifying Officers in researching specific questions that might arise in connection with determining the propriety of voucher verification certifications.
      1. An Act entitled "To Fix The Responsibilities of Disbursing and Certifying Officers, and for other Purposes".  The Certifying Officers' Act (31 U.S.C. 82).
      2. Chapter 10 - Liability and Relief of Accountable Officers Principles of Federal Appropriations Law, Office of the General Council, The United States General Accounting Office, First Edition, June 1982.
      3. General Accounting Office (GAO Policy and Procedures Manual for Guidance of Federal Agencies, Titles III (Audit) and Title IV (Claims) and Comptroller General Decisions; 23 Comp. Gen. 131: 23 Comp. Gen. 953; 39 Comp. Gen 548 and 55 Comp. Gen. 388.
      4. Chapter 2500, Department of Treasury Fiscal Requirements Manual (TFRM) and
      5. Chapters 1-20; 5-10; and 5-20 HHS Voucher Examination Manual.



  1. NAME (last, first, and middle):__________________________________________
  2. GS GRADE/SERIES:_________________________________________________
  3. BUSINESS TELEPHONE:_____________________________________________
  4. BUSINESS ADDRESS:________________________________________________
  5. PRIMARY DUTIES (Attach supplemental pages if necessary.)
  6. DATE EMPLOYED (give month and year): From_____________ To____________
  11. Is the nominee an imprest fund cashier?______________________________________
  12. Is the nominee a contracting officer or does the nominee hold delegated procurement authority?_______   If yes, Please attach a memorandum of explanation.
  13. SIGNATURE:_________________________________________________________
  14. DATE SIGNED (month, day, and year):______________________________________
    I certify that, o the best of my knowledge and belief, that all of my statements are true, correct, and complete.
  15. NOMINATING SIGNATURE:____________________________________________



  1. State name - (last, first, ad middle)
  2. State - (GS) grade and classification series.
  3. State - business phone (including FTS numbers area code, number and ext.)
  4. State - complete business address of organization (including zip code, if known.)
  5. Description of primary duties in current position should be clear and brief.
  6. State - date employed (give month and year).
  7. State any relatives that are employed by the U.S. Government: (a) name and location, (b) position title, (c) grade and classification series.
  8. Record all training which the nominee has received that relates to the duties and responsibilities of a Certifying Officer.
  9. List dates served as Certifying Officer.
  10. Record any present outside employment or position with any volunteer organization which has a connection with any agency of the U.S. Government.
  11. Self explanatory.
  12. Self explanatory.
  13. Signature, requires original signature in ink.
  14. Date block (month, day and year in ink).
  15. Signature of Executive Officer or Area Director.  (Other signatures are not acceptable.)