# DLAD PGI

- SUBPART 13.4 – Fast Payment Procedures

- PGI 13.402 Conditions for Use

SUBPART 13.4 – Fast Payment Procedures

PGI 13.402 Conditions for Use

(f)(1)(91)(A) Use of fast pay requires a true and complete documentary reconciliation process by which receipt documentation (receipt acknowledgement or receiving report) is compared with contracting (purchase order or requisition) and accounting and payment data (invoice), after payment has been made by the Defense Finance & Accounting Service (DFAS). That is, actual receipts must be compared with order/contract requirements and actual payments to determine whether the vendor was paid properly. While 100-percent matching of these transactions for verification purposes may not be feasible, lack of adequate reconciliation could constitute an Anti-Deficiency Act violation. Therefore, the minimum acceptable verification (that is, post-disbursement matching) is review of a statistically valid sample of acquisitions valued up to $100,000, and of OCONUS subsistence transactions up to $200,000, for which fast pay has been used. Every non-subsistence transaction in fast pay acquisitions with values greater than $100,000 and, for subsistence, greater than $200,000, must undergo this reconciliation process; sampling is not permitted for these acquisitions. Except for tires, OCONUS subsistence and OCONUS medical, fast pay shall not be used for transactions greater than $100,000. Fast pay shall not be used for transactions where the underlying contract does not contain FAR clause 52.213-1 and DLAD clause 52.213-9009 (both titled “Fast Payment Procedure”) and, for commercial item acquisitions, DLAD clause 52.212-9001.

(B) Acquisition specialists, with the assistance of DLA customer account specialists and Order Fulfillment resolution specialists, are to perform fast-pay validations. The contracting personnel are responsible for resolving delinquent contract lines; Order Fulfillment specialists deal with sales order closures. The debt-collection aspect of fast-pay reconciliation (for a contractor’s failure to repair, replace, or correct supplies that were lost, damaged, or not conforming to purchase requirements) is the responsibility of the contracting officer. This is an essential part of the overall contract closeout process, even for simplified acquisitions. Assistance may also be requested from financial customer liaisons and other Financial Operations (J-8) personnel (who track down missing receipts), and from DFAS, as required.

(C) Verification shall be performed by each Supply Chain on a quarterly basis beginning with the start of the fiscal year. Every fast-pay payment for transactions valued at $100,000 ($200,000 for OCONUS Subsistence) or less that has been made since the last verification period shall have an equal opportunity of being included in the random sample for reconciliation. That is, for each quarter, all such fast-pay payments made over that quarter shall be included in the pool from which the sample is selected for verification. To the extent that fast pay is featured in automated, as well as manual, transactions, both automated and manual transactions shall be included in the universe from which the random sample is selected. As stated in subparagraph (f)(1)(91)(B), above, all transactions valued at greater than $100,000 ($200,000 for OCONUS Subsistence) shall be individually reconciled (that is, all BRAC tire acquisitions, any Medical OCONUS DVDs, and OCONUS Subsistence awards greater than $200,000); they shall not be included in the universe for random sampling purposes. Note that the pool from which transactions will be selected for verification is not limited to those on which non-receipts and non-conformances have previously been brought to the contractor’s attention for resolution, or which are otherwise problematic (e.g., orders for which the customer never sent in a receipt acknowledgement). In other words, sampling shall not be performed on a “management by exception” basis. On the other hand, consideration should be given to increasing the sample size or performing a 100% review for suppliers/customers with a problematic record.

(D) DCAA’s “E-Z Quant” methodology constitutes a standardized sampling plan that satisfies the requirements for randomness, confidence, and statistical validity, and that provides for sampling on an automated or manual basis. Use of this method will produce an appropriate sample for submittal to the reconciliation process.

(i) Once the sample has been obtained via E-Z Quant, contracting personnel shall perform receipt validation on each of the orders in the sample. The preferred method of receipt verification is evidence of a Material Receipt Acknowledgement (MRA). The MRA is a systems driven transaction generated when the receiving activity’s accountable record is updated. For the purposes of fast pay validations, evidence of an MRA signifies delivery of the requisitioned material by the vendor. Supply Chains may pull MRA data as part of a comprehensive data pull to support fast pay verifications or they may utilize the EBS report entitled “Missing Goods Receipt for Fast Pay Orders.” Those with missing or partial MRAs must be further researched to determine whether the customer received the items.

(ii) Past experience has shown that there are systemic issues which may prevent the MRA from posting in SAP, thus, contracting personnel must have the ability to validate customer receipt through alternative means. When an MRA is not available, contracting personnel may validate receipt via a Receiving Report in Wide Area Workflow (WAWF), Proof of Delivery (POD) from the transporter, acknowledgement of receipt by the requisitioner or through some other means of verifying that the customer has received the material. The method of validation must be noted in the verification reports provided to J-71.

(F) Reconciliation results shall be reported by each supply chain to J-7 (attention: J-71) within 45 days of the close of the verification period. Reports will follow a one quarter lag. For example, the verification report for the first quarter (OCT-DEC) will be due to J-71 45 days after the close of the second quarter verification period. The lag is intended to allow for sufficient time for customer receipts to post. J-71 will review the results for negative trends and assess the need for potential corrective actions. J-71 will also share results with J-73 for inclusion in the “Acquisition Integrity Dashboard” and as supporting data to Procurement Management Reviews.

(i)If the reconciliation exposes discrepancies (including, but not limited to, unmatched disbursements, overages, underage’s, or uncorrected goods nonconformance’s) between the actual customer receipts and either vendor invoices or receipts generated by the system, or both, in more than 5 percent of the sample, an additional sample, of the same size as the original group subjected to reconciliation, and excluding the transactions previously sampled, shall undergo the verification process. If more than 5 percent of this second sample is also discrepant, J-7 may require verification of additional or all transactions.

(G) In addition to the post-payment verification reports to be performed by each Supply Chain, proper application of fast payment procedures (i.e. all conditions met and clauses included) and documentation of the contract files as required by (f)(1)(90)(3) will be a part of all regular Procurement Management Reviews.