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Chapter 4

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Chapter 4 outlines the closure process and includes information regarding certificate transactions and closure inhibitors once the certificate reaches DFAS Indianapolis. This chapter also documents the verifications required for post-closure transactions, contract closeout, the Case Closure Suspense Account (CCSA), reopening cases, zero value closures and closure of leases.

Section Title
A7.C4.1. Chapter Overview
A7.C4.2. Organizational Roles And Responsibilities
A7.C4.3. Closure Checklists
A7.C4.4. Contract Closeout
A7.C4.5. Financial Closeout
A7.C4.6. Closure Certificate
A7.C4.7. Closure Transactions
A7.C4.8. DFAS Indianapolis Zero Case Closure Value Procedures
A7.C4.9. DIFS Closure Inhibitors
A7.C4.10. Undercollected Payments For Cases Pending Closure
A7.C4.11. Disposition Of Excess Funds
A7.C4.12. Case Closure Suspense Account (CCSA) (AKA ULO Account)
A7.C4.13. Post-Closure Transactions
A7.C4.14. Interim To Final Closure Processing For ACCP Cases
A7.C4.15. Reopening And Reinstating Activity On FMS Cases
A7.C4.16. Foreign Military Financing (FMF) Commitments
A7.C4.17. Closure Impact On FMS Billing Statements
A7.C4.18. Closure Of Leases
A7.C4.19. Closure Of Zero Value Grant Excess Defense Articles (EDA) Cases
A7.C4.20. Systems Interfaces
A7.C4.21. Closure Manpower Funding
A7.C4.22. General POC Matrix
A7.C4.1. Chapter Overview

A7.C4.1.1. Once a case is SSC and the requisite verification steps noted in Appendix 7, Chapter 3, are completed, the case is eligible to be submitted for closure. As prescribed in the DoD FMR, Volume 15, Chapter 6, a closed FMS case may still remain open from a DoD accounting perspective. Case closure is the final phase of the FMS life cycle and is extremely important to the USG and purchaser. The benefits of case reconciliation and closure are numerous, but the most important benefit is that it ensures a country has received all the deliverables outlined in the FMS case, as well as, providing final billing and the return of any unutilized funds. Reconciliation for closure involves extensive communication between various logistics, financial and contract organizations to ensure associated closure transactions are completed. It is imperative that case/line reconciliation (elaborated in Appendix7, Chapter 2 and Chapter 3) is initiated upon implementation of the LOA to ensure the closure process is overall less cumbersome. By reconciling during case execution, case closure becomes an event instead of a process. When a case is reconciled according to procedures for the appropriate closure method, it is then submitted for closure. This chapter addresses reconciliation surrounding the following processes: closure transactions, closure inhibitors, underpaid cases, Case Closure Suspense Account (CCSA), post closure transactions, verifications, contract closeout, reopening/reinstating activity, FMF commitments, billing and lease closure.

The following serves as a general categorization of closure functions by organization:

A7.C4.2.1. IA performs all case closure functions prescribed in DoD FMR, Volume 15 and the SAMM, reconciles cases, ensures data integrity, performs annual case reviews and reconciliations in accordance with the requirements for closed cases as shown in Figure A7.C2.F6, prepares cases for closure. For ACCP cases, to the maximum extent possible, this involves preparing the case for direct final ('C3') closure, coordinates internal case closure actions with appropriate organizations, issues the closure certificate and processes requisite closure transactions and analyzes cases for transition from interim to final (and final to interim) closure status, to include post-closure reconciliation efforts. In addition, the IA consults with DFAS, as appropriate, to ensure integrity between logistical and financial records, meets with purchasers to resolve issues, ensures closure status consistency between IA systems and DIFS, validates, liquidates, and adjusts the ULO value as appropriate and reopens FMS cases as appropriate.

A7.C4.2.2. DSCA is responsible for publishing, updating, and updating reconciliation and closure policies, and the master list of ACCP participants to include any special requirements for specific countries (See Table A7.C3.T1. or the SAMM). DSCA oversees process of transitioning cases from interim to final closure, approves quarterly refunds from purchaser CCSA, serves as final arbiter for case closure issues raised by IAs and DFAS Indianapolis, provides approval for requests to reopen cases previously closed, and meets with purchasers to resolve issues.

A7.C4.2.3. DFAS Indianapolis works with IAs on closing cases, performs all accounting functions as prescribed in DoD FMR Volume 15 and the SAMM, meets with purchasers to resolve issues, collects final payments due from/refunds excess funds to purchasers, maintains the CCSA, effects quarterly ULO account refunds based on DSCA guidance, ensures prompt and accurate transition of cases between implemented and various closure categories, provides systemic feedback reporting to IAs, maintains case closure inventory in DIFS, reconciles financial data and validates FMS case closure values, closes FMS cases, ensures closure status consistency between IA systems and DIFS, reopens FMS cases, as authorized and reflects closure activity on DD Form 645, "Foreign Military Sales Billing Statement" and applicable holding account statements.

A7.C4.2.4. DCMA, when assigned as the Administrative Contracting Officer (ACO), performs contract administrative functions (including contract closeout) as prescribed in the Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS).

A7.C4.2.5. DCAA performs contract audit functions as prescribed in the FAR and the DFARS, including final overhead rate audits necessary to "final" close FMS cases.

A7.C4.2.6. Purchasers advise IAs/DSCA on which cases are desired for closure, and those cases to be kept open, coordinate closure decisions between Ministry of National Defense (MND)/equivalent level and Service/program office level, and secure final payment in a prompt fashion for cases that are undercollected and awaiting closure.

A7.C4.3.1. Tables A7.C4.T1. and A7.C4.T2. are checklists for preparation for ACCP interim to final closure (closure type '2' to '3') and for direct final closure of both non-ACCP closure type '1' and ACCP closure type '3'.

Table A7.C4.T1. Checklist for ACCP Interim To Final Closure (Closure Type '2' to '3')

Table A7.C4.T2. Direct Final Closure (Closure Type '1' and Closure Type '3')

A7.C4.4. Contract Closeout

To facilitate the closure of cases, depending on the closure type, the following are the steps applicable to determining the disposition of contracts and for contract closeout. Cases can be closed if no ULO exists on ACRNs on the contract associated to the case, even if the supporting contract remains open. These functions are performed by the Administrative Contracting Officer (ACO).

A7.C4.4.1. Time Standards. The FAR 4.804 sets specific time periods for contract closeout. Only the ACO/DCMA can enforce the time standards; the IA has no authority to do so. The time period for contract closeout is based upon both the type of contract and date of physical completion. A contract is considered to be physically complete when the contractor has completed the required deliveries and the Government has inspected and accepted the supplies, performed all services and the USG has accepted these services, all option provisions, if any, have expired and USG has provided the contractor a notice of complete contract termination. Facilities contracts and rentals, use and storage agreements are considered to be physically complete when the USG has given the contractor a notice of complete contract termination and the contract period has expired.

A7.C4.4.1.1. Files for contracts using simplified acquisition procedures should be considered closed out when the contracting officer receives evidence of receipt of property and final payment, unless otherwise specified by agency regulations.

A7.C4.4.1.2. Files for firm-fixed-price contracts, other than those using simplified acquisition procedures, should be closed out within six months after the date on which the contracting officer receives evidence of physical completion.

A7.C4.4.1.3. Files for contracts requiring settlement of indirect cost rates should be closed out within 36 months of the month in which the contracting officer receives evidence of physical completion. (Cost-Reimbursement Contracts including Time and Material (T&M) and Labor Hour (LH) contracts).

A7.C4.4.2. Closeout of the Contract. If all contract terms and conditions are met, and all payments have been made to the correct ACRNs, the contract should be easy to close out and the process is completed.

A7.C4.4.2.1. Following the FAR 4.804-5, "Procedures for Closing Out Contract Files", at the outset of this process, the ACO must review the contract funds status and notify the contracting office of any excess funds the contract administration office might de-obligate (Refer to the FAR 4.804-5 for a list of the actions required).

A7.C4.4.2.2. Once all applicable actions are completed, the contracting officer administering the contract signs the Contract Closeout Checklist, if applicable.

A7.C4.4.2.2.1. If the contract is in MOCAS, the contracting officer also signs the Notice of Last Action (NLA) and processes the Final Payment NLA in MOCAS. MOCAS sends a contract completion statement (PK9) electronically to the contracting office and one is placed in the appropriate contract management office file.

A7.C4.4.2.2.2. For contracts not in MOCAS, the ACO has to ensure that a contract completion statement (DD Form 1594) has been completed (Refer to the DCMA Contract Closeout Guidebook for details on preparing the form). For contracts not in MOCAS, the original contract completion statement must be sent to the contracting office and a copy placed in the appropriate contract administration file.

A7.C4.4.3. Quick Closeout. The quick closeout procedures identified in FAR 42.708 offer an alternative to holding contracts open until the determination of final direct costs and indirect rates. When it becomes apparent that there is a delay in the settlement of final direct costs and indirect rates, it is recommended that the IA encourage the appropriate contracting officer to consider utilizing quick closeout procedures, where applicable. To help facilitate quick closeout, DCMA established a Contract Management Team (CMT) Locator hyperlink, as follows: https://pubmini.dcma.mil/CMT_View/CMT_View_Search.cfm. Specifically, quick closeout procedures may be used if the contract is physically complete and the amount of final direct and indirect costs to be allocated to the contract is relatively insignificant. Cost amounts will be considered relatively insignificant when the total unsettled direct costs and indirect costs to be allocated to any one contract, task order, or delivery order does not exceed the lesser of $1,000,000 or 10 percent of the total contract, task order, or delivery order amount. The contracting officer is required to perform a risk assessment and determine that the use of the quick-closeout procedure is appropriate. The risk assessment shall include consideration of the contractor's accounting, estimating, and purchasing systems; other concerns of the cognizant contract auditors; and any other pertinent information. The determinations of final direct and indirect costs under quick closeout procedures are final for the contracts it covers and no adjustments are made to other contracts for over or under recoveries of costs allocated or allocable to the contracts covered by the advance agreement. Indirect cost rates used in the quick closeout of a contract are not considered a binding precedent when establishing the final indirect cost rates for other contracts.

A7.C4.5.1. Contract Information Sources. When reconciling the status of a contract that relates to an FMS case the information available may vary depending on when the basic contract was awarded or the FMS case start date. The following table provides an overview as to what case information is available at a particular point in the FMS case process.

Table A7.C4.T3. FMS Case-Related Contract Information Sources

A7.C4.5.2. Discontinued Research. An excerpt from the DoD FMR Volume 3, Chapter 11, addresses research requirements and provisions where discontinued research may be authorized. Efforts must first be made to obtain a final document status report regardless of the document type or the year of issuance. It is recommended that final documents are requested within six months after receipt of the material or work completion date has expired. This effort eliminates the possibility of reopening cases at a later date after unidentified charges are later located. The following procedures apply to closing out FMS contracts/funding documents when documentation to support the final expended value is no longer available.

A7.C4.5.3. These procedures apply to cases funded with FMS and other appropriated funds. FAR subpart 4.804, provides time standards and responsibilities for closing out contract files. The DCMA Guidebook outlines specific steps that must be taken prior to certifying the physical and financial completion of contracts by issuance of a Contract Completion Statement (DD Form 1594/PK9). PCO, ACO and paying office records for many older contracts are incomplete or non-existent and records of contract closeout action are unavailable. The following policy guidance pertains to the removal of ULO balances in the official accounting system.

A7.C4.5.3.1. Procedures and Requirements for Contracts Not Closed, but Physically Completed. For contracts requiring closeout in the payment system and/or accounting system, (e.g., Cost-Plus-Fixed-Fee and Fixed-Price-Incentive-Fee), perform the following, if possible:

A7.C4.5.3.1.1. Complete the Contract Status Questionnaire shown in Figure A7.C4.F1. to record/verify the current status of the contract; i.e., is the contract still open?; when shall the closeout process begin? If research reveals that the contract is not finalized, the questionnaire should remain with the investigating office. The questionnaire is intended to assist program offices in developing uniform procedures regarding contract status. Figure A7.C4.F1. is intended to assist program offices in developing uniform procedures regarding contract status.

Figure A7.C4.F1. Contract Status Questionnaire

A7.C4.5.3.1.2. Obtain a Contract Completion Statement (DD Form 1594 or PK9) to confirm that the contract is closed out. Issuance of a DD Form 1594/PK9 does not signify that the contract is closed out in MOCAS. Follow-up may be necessary in cases where the contract is still open in MOCAS to obtain status of pending audit and estimated close out date.

A7.C4.5.3.1.3. Confirm accounting system obligations match contractual funding documentation for each ACRN.

A7.C4.5.3.1.4. Confirm accounting system disbursements match paying office, or when paying office records are not available, match to Treasury (DCAS) disbursements for each ACRN.

A7.C4.5.3.2. Procedures and Requirements for Closed Out Contracts vary based on the type of contract.

A7.C4.5.3.2.1. On contracts for which required documentation to fully confirm contract closeout is unavailable, use the following approach to certify that closeout has been completed.

A7.C4.5.3.2.2. For contracts requiring closeout in the payment system and/or accounting system, (e.g., Cost-Plus-Fixed-Fee and Fixed-Price-Incentive-Fee), accomplish the following if possible:

A7.C4.5.3.2.2.1. Complete the Contract Status Questionnaire in Figure A7.C4.F1. to record/verify the current status of the contract; i.e., if the contract still open or when shall the closeout process begin. Table A7.C4.T4. shows the steps used to verify contract closeout. If research reveals that the contract is not finalized, the questionnaire should remain with the investigating office.

A7.C4.5.3.2.2.2. Obtain a Contract Completion Statement (DD Form 1594 or PK9) to confirm that the contract is completed. Issuance of a DD Form 1594/PK9 does not signify that the contract is closed in MOCAS. Follow-up may be necessary in cases where the contract is still open in MOCAS to obtain status of pending audit and estimated close out date.

A7.C4.5.3.2.2.3. Confirm that the accounting system obligations match contractual funding documentation for each ACRN and confirm accounting system disbursements match paying office records. When paying office records are not available, match accounting system disbursements to Treasury (DCAS) disbursements for each ACRN.

Table A7.C4.T4. Steps Required To Verify Contract Closeout

# Actions

1

Identify contractor, ACO, and paying office, using sources including:

  1. Contracts Directorate files for Headquarters contracts

  2. MOCAS research

  3. DCMA web site

  4. Acquisition Manager files

  5. Comptroller files

  6. Field activity files

 

2

Determine closeout status. Sources for closeout information include MOCAS, ACOs/PCOs, Contractors and Contracts Directorate files. If a contract has been closed out, obtain documentation. The following hierarchy of acceptable documentation includes:

  1. Contract Completion Statement (DD Form 1594) (should include final mod/ invoice/ULO amount)

  2. Memorandum for the Record from ACO or PCO

  3. Copy of final mod(s)/final DD Form 250

 

3

If a contract has not been closed out - determine actions remaining before DD Form 1594 issued which may include:

  1. Litigation pending

  2. Existence of supply/service complete posting. MOCAS: Estimated completion date or Overage date.

  3. Overhead rates have been audited by DCAA for cost plus contracts

  4. Contract re-determination, if required, has occurred

  5. Contractor/subcontractor final invoices have been received and paid

  6. Contractor signed release form

  7. Government Furnished Material disposition instructions have been issued

 

4

Use/maintain copies of Contract Status Questionnaire.

5

Determine contract financial closeout status:

  1. Compare contractual obligations (hardcopy modifications) to the accounting system and prepare funding spreadsheet identifying obligation variances by ACRN.

    • For DFAS Columbus paid contracts, compare MOCAS records to the accounting system.
    • For non-MOCAS paid contracts, obtain manual record (e.g., DFAS Germany) or contractor record of obligations.

     

  2. Compare contract payment records to Accounting System expenditures.

    • MOCAS/paying office ledger sheets/vouchers
    • Accounting System/Treasury expenditures - For FMS appropriation, treasury expenditures are required. For Domestic appropriations, treasury expenditures are only required when paying office records are not available.

     

  3. Identify variances and prepare Problem Disbursement package with supporting documentation for contracts still open in MOCAS.

 

6

Submit Contract Status Certification (See Figure A7.C4.F2.) to Comptroller and obtain concurrence.

7

Maintain copies of certifications in central file.

Figure A7.C4.F2. Contract Status Certification

A7.C4.5.4. Case Reconciliation and Closure EXCOM. Refer to Section A7.C6.3.3. for detailed information on how the EXCOM is used as a tool for promoting FMS case reconciliation and closure efficiency. When attempts to obtain final statements are unsuccessful, and discontinued research is determined as the only remaining effective course of action, the IA is required to submit to the EXCOM a statement showing the original funding amount agreed to by the activity per phone conversation, or documentation regarding IA receipt of disbursement (Refer to Figure A7.C6.F1.). If no work was conducted, the IA must provide the EXCOM with a statement of confirmation for the non-performance of material or services in order that committed or obligated balances may be recouped.

A7.C4.6.1. With transmittal of the 'C1I' closure transaction (refer to Figure A7.C4.F5.), the IA submits the closure certificate via (format in Figure A7.C4.F4.). For interim closures, the ULO supporting documentation attachment must be sent with the case closure certificate.

Figure A7.C4.F3. ACCP Case Closure Preparation Actions for Cases with Unliquidated Obligations (ULO)

Figure A7.C4.F3. ACCP Case Closure Preparation Actions for Cases with Unliquidated Obligations (ULO)

 

Figure A7.C4.F4. FMS Case Closure Certificate

Upon certification of the closure value, the 'C1I' closure transaction is generated by the IA system and transmitted to DIFS (Refer to Figure A7.C4.F3.). The 'C1I' signifies IA completion of its actions necessary for DFAS Indianapolis to close the case. This transaction is required for all closure submissions, except force closures.

A7.C4.7.1. The 'C1I' transaction processes through the Positive Transaction Control (PTC) subsystem, invoking numerous edits and validations.

A7.C4.7.1.1. Data Elements for the 'C1I' Transaction. The primary data elements are date submitted, case designator, certificate values including CAS and LSC, articles/services disbursed (not including CAS or LSC) and closure type request code (Non-ACCP 'C1", ACCP interim 'C2', or ACCP direct final or ACCP interim to final 'C3').

A7.C4.7.2. The 'C1F' transaction is fed from DIFS to the IA system to acknowledge acceptance or rejection of the 'C1I'. If accepted by DIFS, the 'C1I' transaction is converted into a DIFS '2A' transaction resulting in a case closure certificate appearing on the Case Closure Certificate Inventory (CCCI) Inquiry screen (FII1). If rejected by DIFS, the IA receives a Transaction Reply Code (TRC) with the reason for rejection. In coordination with DFAS Indianapolis, the IA initiates whatever action is necessary to correct the condition before generating a new 'C1I' transaction.

A7.C4.7.3. DIFS assigns closure status/inhibitor codes to all cases appearing on the CCCI. A list of DIFS inhibitor codes is provided in Table A7.C4.T5.

A7.C4.7.4. Each time a case closure certificate is added to the closure inventory for a ULO case, a new DIFS "ULO Required" value is computed as the difference between certified deliveries and the sum of certified disbursements and CAS/LSC disbursements in DIFS. This value is stored in the Case Control Summary Master File, and appears in all Case Control Summary output and on the CCCI Inquiry screen. It is expected to support all post-closure financial activity reported against the case.

A7.C4.7.5. Other Related Closure Transactions include the 'C4I', which is generated by the IA system to rescind the 'C1' transaction and related certificate of closure and the 'C5I', which serves two purposes:

  1. to reopen non-ACCP cases in DIFS and

  2. to revert cases from final to interim closure status (closure type '3' to '2').

The 'C5I' transaction is, generally, generated by the IA system and fed to DIFS. It is converted into a DIFS 'CF' transaction that changes the applicable case status in the Case Control Summary Master File of DIFS. The DIFS force closure 'C8' transaction is used to force close a case in DIFS.

A7.C4.7.6. Once a case is closed in DIFS, a 'C3I' transaction is sent to the IA as notification that the case is closed in DIFS. Once all inhibitors are cleared in DIFS, a DIFS 'C8' transaction is submitted which closes the case in DIFS and sends a 'C3I' closure notification to the IA system. The IA system uses this transaction to update its closure status.

Figure A7.C4.F5. C1/C3 Closure Transactions

Figure A7.C4.F5. C1/C3 Closure Transactions

 

Figure A7.C4.F6. DIFS Case Closure Certificate Inventory Inquiry

Figure A7.C4.F6. DIFS Case Closure Certificate Inventory Inquiry

 

Upon case implementation, the DIFS Admin Fee Subsystem transfers the required amount of the FMS Administrative Surcharge (usually 50 percent) of the case FMS Administrative Surcharge ordered value from available funds in the Country Trust Fund to the FMS Administrative Surcharge Cost Clearing Account. This transfer is reflected on the DD Form 645 as a portion of the Column 10, Work In Process. The presence of this progress payment on the Case Control Master File prevents the processing of a closure transaction (C8) for the cases closed at zero delivered value. When a cancellation fee is assessed for cases to be closed at zero delivered value, the system allows the case to be closed only if the ordered admin is reduced to equal assessed admin. Refer to Section A7.C3.11. for a description of the process used to determine whether the case should close at a zero dollar value.

A7.C4.8.1. DFAS Indianapolis should not process zero case closure value requests unless they have been documented by DSCA in a DSAMS case remark and adequately documented as part of the case closure certification.

A7.C4.8.2. For cases closed at zero delivered value without a cancellation fee, DFAS Indianapolis processes a Change Case Detail ('CD') transaction to reduce the line level ordered admin cost to zero. This CD transaction causes the Admin Fee Subsystem to refund any money previously transferred and clears any 'progress payment admin'. As part of the 'CD' transaction, DFAS Indianapolis includes Amend-Type 'C' and MOD-NBR '99', if the case has no previous closure actions to satisfy the requirements of the Case Amendment Control. If the case had a previous closure action, either do a correction to the C-99 line if adjustment is part of the original closure, or use C-98, 97, ext. as needed. DFAS Indianapolis processes a 'CS' transaction to reduce case summary totals by the amount of admin reduced. The line level administrative surcharge percent established in Case Control is not changed or deleted. Upon successful processing of the 'CD' and "CS' transactions, a 'C8' transaction is processed to close the case.

A7.C4.8.3. If the case is subsequently reopened, the 'CD' and "CS' transactions must be reversed to reflect the values on the LOA in affect at the time of case closure.

A7.C4.8.4. For cases closed at zero delivered value with cancellation fee, DFAS Indianapolis processes an 'NF' flat charge transaction in the amount of the cancellation fee and closes the case in accordance with normal case closure procedures.

A7.C4.9.1. Closure inhibitors applicable once the 'C1' transaction is sent to DFAS Indianapolis are shown in Table A7.C4.T5.

Table A7.C4.T5. DIFS Closure Inhibitors

A7.C4.10.1. The DIFS CCCI reflects an 'L' inhibitor code whenever a case that is pending closure requires additional payment from the purchaser. In this situation, DFAS Indianapolis notifies the purchaser on the next quarterly billing statement of the amount owed to close the case. Fifteen days after the bill due date, if payment has not been received, DFAS Indianapolis prepares a report of all the "Billed yet still Undercollected Cases" and provides it to DSCA (Business Operations Directorate, Country Financial Management Division). In addition, DFAS Indianapolis will change the CCCI inhibitor code to 'A' to indicate that responsibility for resolution resides with DSCA (Business Operations Directorate, Country Financial Management Division).

A7.C4.11.1. When a case is being closed, any excess funds (as defined by collections less the closure value) are transferred by DFAS Indianapolis to the appropriate holding account. National funds remain in the holding account unless/until the purchaser requests a transfer, refund or have an automatic refund arrangement in place. Generally, credit funds remain in the holding account until they are applied for required payments on other credit funded FMS cases.

A7.C4.12.1. Background. The CCSA was established in 1992 with the onset of ACCP. The account holds funds for all IAs for all participating countries and is maintained by DFAS Indianapolis in DIFS at country level and accounted for at case level. Prior to closure, the IA forwards the ULO value (including CAS) to DIFS (i.e., 'NA' performance transaction). The ULO value appears in the DIFS Case Summary query in the "ULO REQD" field at interim closure. The sum of "ULO-REQD" and "ULO-EQUITY" fields at case level equal the country level balances in the CCSA. See Figure A7.C4.F7. for steps on how to update the CCSA. See Section A7.C5.4. for additional information regarding the CCSA statement.

Figure A7.C4.F7. Case Closure Suspense Account (CCSA)

Figure A7.C4.F7. Case Closure Suspense Account (CCSA)

 

A7.C4.12.2. DIFS ULO Summary Costs. At interim closure, the total ULO certified value appears in the "ULO REQD" field found in DIFS Case Control Summary query. This amount is added to the CCSA country level balances. The "ULO REQD" amount is adjusted based on post closure EA/Disbursement activity. The "ULO DISB" is the liquidating costs received against the "ULO REQD" amount. The "ULO-EQUITY" field contains the amount of funds in the country level CCSA that had to be applied to the case to make up for a shortfall in the "ULO REQD" amount as a result of post closure EA/Disbursement activity against the case. The sum of "ULO-REQD" and "ULO-EQUITY" amounts for all cases is the available balance in the CCSA at the country level. The DIFS Case Control Summary fields show ULO summary costs on the DIFS Case Control Summary query in Figure A7.C4.F8.

Figure A7.C4.F8. DIFS Case Control Summary Query

Figure A7.C4.F8. DIFS Case Control Summary Query

 

A7.C4.12.3. ULO Reporting Process. Incoming EA requests may either increase or decrease the CCSA balance. EA requests for credits will increase a CCSA balance while EA requests for debits will have a negative effect on the CCSA balance. Any unused ULO funds remain in the CCSA for subsequent use or refund. DFAS Indianapolis monitors the account to ensure there are sufficient funds to process additional disbursements. Once the ULO is fully liquidated/de-obligated, the case can be submitted for final closure. DSCA (Business Operations Directorate) and DFAS Indianapolis review the CCSA balances to determine if the country is eligible for a refund. Refer to Appendix 7, Chapter 5 for the CCSA statement lexicon and sample.

A7.C4.12.4. CCSA Refunds. The greater the accuracy of the estimated ULO at the time a case is being prepared for interim closure under ACCP, the less likely CCSA excesses will occur. The purpose of CCSA refunds are to release excess funds based on account balances at the country level, as a result of post-closure financial activity against cases, to optimize the utility of purchaser funds. The successful execution of CCSA refunds is dependent on a closely coordinated effort between DSCA (Business Operations Directorate), DFAS Indianapolis and IAs, when appropriate. CCSA refunds are deposited into the appropriate holding account, which includes 7QQ for cash-financed cases, 5QQ for FMS Credit-financed cases, and 2QQ for MAP Merger-financed cases.

A7.C4.12.4.1. Refunds are made on both interim closed and final closed cases. The process differs for each refund type.

A7.C4.12.4.1.1. Interim Closed Cases. The process of reviewing for potential CCSA refunds occurs on a quarterly basis and refunds are processed before the end of the month in February, May, August, and November. IAs review proposed refunds on interim closed FMS cases using the Interim Case Closure Refund tool in the Security Cooperation Management Suite (SCMS) and update recommendations for DSCA (Business Operations Directorate, Financial Policy and Analysis Division). DSCA (Business Operations Directorate, Financial Policy and Analysis Division) provides a list of refunds to DFAS Indianapolis with input from DSCA (Business Operations Directorate, Country Financial Management Division) and DFAS Indianapolis (Customer Accounting Branch). DFAS Indianapolis creates and processes the refund voucher and inputs the cash transfer transactions into DIFS to move excess funds to the appropriate holding accounts; posts the credit ULO EA adjustments to the corresponding cases; and processes corresponding progress payments at the line item level for each case that received a refund. The last action ensures that ‘ND’ performance reporting match disbursements to facilitate final closure.

A7.C4.12.4.1.2. Final Closed Cases. The process for reviewing for potential CCSA refunds occurs on a quarterly basis and refunds are processed before the end of the month in March, June, September, and December. DFAS Indianapolis provides various reports and data to DSCA (Business Operations Directorate, Financial Policy and Analysis Division) on ULO balances. DSCA (Business Operations Directorate, Financial Policy and Analysis Division) forwards to DSCA (Business Operations Directorate, Country Financial Management Division) and DFAS Indianapolis its comprehensive report, produced by the DSCA Final Closed Case Refund tool, identifying all countries for which excess CCSA funds appear to exist, along with its recommendation on the excess funds eligible for refund. The report details the specific cases comprising the country-level CCSA excess funds total. DSCA (Business Operations Directorate, Country Financial Management Division) and DFAS Indianapolis review and coordinate on the identified refunds. DSCA (Business Operations Directorate, Financial Policy and Analysis Division) provides direction to DFAS Indianapolis on the amount of CCSA refunds. Due to limitations within DIFS, DFAS Indianapolis temporarily moves the case to an interim closure status (‘C2’) which allows for transactional processing of refunds. However, before such action is taken, DFAS Indianapolis reviews the suspended transaction file and removes any transactions that would impact the movement of the case back to final closure status (‘C3’). DFAS Indianapolis then creates and process the refund voucher and inputs the cash transfer transactions into DIFS to move excess funds to the appropriate holding accounts; processes corresponding progress payments at the line item level for each case that received a refund; and returns the case to a final closure status (‘C3’).

A7.C4.12.4.2. Disposition of funds originating from cash-funded cases requires DFAS Indianapolis to transfer funds originating from cash-funded to the FMS Trust Fund holding account 7QQ. This holding account serves as a temporary repository of those funds and provides an appropriate audit trail for monitoring CCSA refunds. DSCA (Business Operations Directorate, Country Financial Management Division) requests that purchasers respond within a reasonable time frame with their authorizations to transfer these funds to more desired repositories. Options for disposing of these funds include: cross-leveling to active FMS cases for the purpose of liquidating arrearages or minimizing future outlay requirements; transferring to other holding account(s), perhaps for the purpose of further segregating excess funds by In Country Service (ICS) and/or refunding directly to the purchaser.

A7.C4.12.4.3. Disposition of funds originating from FMS Credit and MAP Merger-Funded cases begins when DFAS Indianapolis transfers the refunds to the ‘5QQ’ (Credit) or ‘2QQ’ (MAP Merger) holding account, whichever is identified in the comprehensive refund report. DSCA (Directorate of Business Operations, Country Financial Management Division) records into the FMS Credit System database an offsetting commitment entry (i.e., a negative ‘RA’ transaction) using pseudo case identifier Q-ULO as the audit trail for monitoring these transactions. This action increases the purchaser’s FMF uncommitted balance by a corresponding amount. Funds are de-committed from pseudo case Q-ULO to finance LOAs as they are presented for funding.

A7.C4.12.4.4. Refunds are reflected in the purchaser’s applicable holding accounts statements and the CCSA statement provided with the quarterly DD Form 645, “Foreign Military Sales (FMS) Billing Statement”.

A7.C4.13.1. Interim Closure Status. Once the case has reached interim closure (closure type '2') status, only obligation ('R' series) work in process performance reporting 'ND' and disbursement/EA ('S' series) transactions relating to post-closure charges can process (Refer to Figure A7.C4.F9.). All delivery performance ('NA') transactions shall reject during interim closure. ACCP allows charges that exceed the ULO to process programmatically (certain restrictions apply for individual ACCP participating countries). When charges exceed the ULO value assessed at interim closure by $100,000 or more or they will reduce the CCSA balance of the purchaser by more than 75%, DSCA (Business Operations Directorate, Financial Policy and Analysis Division) may authorize the case to be reopened in order to process the additional charges. Based on the specific transaction, funds may be withdrawn from or deposited into the CCSA (refer to additional details in Appendix 7, Chapter 5). Table A7.C4.T6. illustrates transactions to process charges received while a case is interim closed:

Table A7.C4.T6. Post-Closure 'ND' Performance Transactions

Contract Related Performance Transaction Price Code Delivery Source Code REIMB Code CAS DIFFS

Yes

'ND'

N

DE

D

Yes

Progress Payment Reported

No

'ND'

Blank

DF

S

No

Progress Payment Reported

Figure A7.C4.F9. ‘ND’ Post Closure WIP Performance Transaction Processing

Figure A7.C4.F9. ‘ND’ Post Closure WIP Performance Transaction Processing

 

A7.C4.13.2. Final Closure Status. For processing additional disbursement, obligation and expenditure authority transactions, ACCP cases previously in final closure status (closure type '3'), must revert to interim closure status (closure type '2'). When charges exceed the ULO value assessed at interim closure by $100,000 or more or they will reduce the CCSA balance of the purchaser by more than 75%, the IA shall consult with DSCA (Directorate of Business Operations, Financial Policy and Analysis Division) before moving a case to interim closure status. DSCA will determine if the IA should proceed with the closure type change or if the case should be reopened. Any non-ACCP transactions require the case to be reopened.

A7.C4.13.3. Post Closure SDRs. All case closure types require that any SDRs be finalized prior to submitting a case for closure. (Refer to the SAMM Chapter 6, for detailed policy guidelines on SDRs.) However, while it is rare, SDRs may be received after a case is closed. Post-closure SDRs must be validated and approved by the normal SDR approval authority prior to any further action on the closed case (Refer to Figure A7.C4.F10.). An SDR received against a closed case is processed as follows:

A7.C4.13.3.1. ACCP Cases. Valid SDRs will be processed against interim closed cases (closure type '2'). A final closed case (closure type '3') must revert to interim closure status to process an SDR. DIFS accepts only 'ND' and 'S' series transactions during interim closure. After the SDR processes, the 'ND' performance transaction draws from or is applied to the CCSA (credits return funds to the CCSA; debits withdraw funds from the CCSA). Upon completion of SDR actions, and provided all other inhibitors are cleared, the case may be final closed.

A7.C4.13.3.2. Non-ACCP Cases. Cases must be reopened to process an SDR. Normal processing of the SDR occurs once the case is returned to an "implemented" status. An 'NZ' SDR transaction is forwarded to report the SDR to DFAS Indianapolis and is recorded in DIFS. Upon completion of the SDR actions, the case can be re-closed.

A7.C4.13.3.3. Submittal of SDRs. The MILDEP points of contact for receipt of SDRs are:

A7.C4.13.3.3.1. Army Cases. U.S. Army Security Assistance Command, 54 M Avenue, Suite 1, New Cumberland, PA 17070-5096

A7.C4.13.3.3.2. Navy Cases. NAVSUP Weapons System Support, Deputy Commander for International Programs, 700 Robbins Ave, Bldg 4B, Code P762, Philadelphia, PA 19111-5098

A7.C4.13.3.3.3. Air Force Cases. AFLCMC/WFIUB, 5454 Buckner Rd, WPAFB, OH 45433-5337

Figure A7.C4.F10. SDR Processing Against Closed Cases

Figure A7.C4.F10. SDR Processing Against Closed Cases

 

A7.C4.14.1. In those instances where a case must first close in an interim closure status, it is important that they are monitored on a continual basis to progress the case to a final closure status as early as possible.

A7.C4.14.2. Review of DIFS case summary includes the review of all payments and funds receipts. A DIFS case summary review will show the case as closure type '2', for interim closed. To consider a case for final closure the review must include the DIFS values and associated IA systemic balances, the contract status/type, receipt of all final disbursements, review of all remaining values (to include OA), progress payments reported ('ND' transactions), post closure problem disbursements, cost closure SDRs, CCSA refund that that have occurred and a validation of accessorial charges.

A7.C4.14.3. Review ULO data and take any necessary actions to liquidate or deobligate any unneeded amount in the IA systems.

A7.C4.14.3.1. When refunds occur during interim closure, certain variances will result on the case. Specifically, interim refunds will cause progress payments to exceed liquidating deliveries by the amount of the interim refund. In addition, interim refunds will result in a disbursement variance between DIFS and the IA by the amount of the refund. These conditions should be taken into consideration when certifying an interim closed case for final closure. However, these specific conditions should not prevent the final closure certification of the case.

A7.C4.14.4. In order to verify contract/other funding document status the reviewer must review ULO supporting documentation provided with interim closure certificate (Refer to Figure A7.C4.F4.), review the entitlement system (e.g., MOCAS), contact the CM/CAO, ACO or PCO to obtain date for finalization of contract/other funding document (Refer to Table A7.C4.T3. for an inventory of possible sources), and ensure obligations are posted in accordance with the contract/other funding document. If obligations were not posted and the additional obligations exceed $100K, the case may need to be reopened. In addition the reviewer must obtain the amount of final expenditure for each ACRN on the contract/other funding document. Obtain the date when final expenditures are expected or were incurred.

A7.C4.14.5. DIFS Performance reporting during interim closure will not accept 'NA' (delivery) as well as LSC and liquidating CAS (NA) performance transactions. However, 'ND' transactions reflecting work-in-progress and progress payment CAS, as well as, obligations ('R' series), and disbursements ('S' series) will continue to process. Prior to final closure all performance rejects must be cleared. CCSA adjustments (including credits/SDRs) will occur via the 'ND' performance and 'S' series transactions.

A7.C4.14.6. Post-interim closure expenditures can be less than, greater than or equal to the ULO estimate calculated at interim closure. If no ULO exists and expenditures are greater than or less than the remaining program value by $100K, request DSCA written permission to reopen the case and process a LOA modification. Reopening procedures are discussed in Section A7.C4.15.

A7.C4.14.7. To validate obligations reported to DIFS, the reviewer must review DIFS (FIF2) obligations, resolve all outstanding reporting differences and adjust obligations (i.e., de-obligate) in the IA systems, if necessary.

A7.C4.14.8. To validate performance values DIFS delivered articles and services value must equal IA performance values. (The formula: Add articles/services expenditures plus Estimated ULO CAS and LSC/Stock Fund expenditures, then subtract ULO CAS costs and any ULO adjustment amounts.) For DIFS performance to match, liquidating deliveries must equal progress payments, or the difference equates to the unused ULO (ULO-REQD plus ULO-Equity). See Figure A7.C4.F11. In this example, item 1 equals item 2 plus item 3.

Figure A7.C4.F11. DIFS Performance Reconciliation

Figure A7.C4.F11. DIFS Performance Reconciliation

 

A7.C4.14.9. Validate DIFS disbursement values by ensuring DIFS cash accounting and articles/services disbursement values equal IA performance values. Compare DIFS cash accounting CAS, LSC, ULO, accessorial and administrative disbursement transfers to case summary values. Total deliveries (DIFS FIC1) less total disbursements (DIFS FIS2) must equal ULO-REQD value. If a CCSA refund will be given, or was recently given, to the purchaser, this may cause a disbursement difference between DIFS and the IA system.

A7.C4.14.10. Validate remaining ULO values by researching and documenting LOA line numbers, funding documents, requisition numbers, articles/services obligated value, articles/services expended value, ULO value (excluding CAS) and the reason for ULO. It is important to note that the following information mirrors the ULO supporting documentation section of the interim case closure certificate as noted in Figure A7.C4.F4., provided earlier in this chapter. If no ULO remains, proceed to remaining steps in this section. If valid ULO remains, the case must stay interim closed.

A7.C4.14.11. To submit a case for final closure the IA forwards the case for closure when the case is both logistically and financially complete. The steps noted in Section 4.14.2. through Section 4.14.10. above must be completed. Following completion of those steps the IA sends 'C1' transaction to DIFS, IA sends final case closure certificate to DFAS (Refer to Figure A7.C4.F4. of this chapter for the case closure certificate format), the case closure certificate is approved by DFAS and final closed in DIFS, DIFS closure type transits to '3', and DIFS sends a 'C3' transaction to IA system. This prompts the case to be closed in the IA system. After final closure, DIFS will not accept any further transactions, other than the 'C5' (case reopen) transaction.

Reopening a closed FMS case is performed on an exception basis only. Reinstating activity applies to a case not yet closed, but which is in the closure process or, at a minimum, is not currently active from a logistical perspective. The following describes the reopening and reinstating processes. Cases may be reopened or reinstated for additional processing, e.g., disbursements or SDRs. Figure A7.C4.F12. and Figure A7.C4.F13. illustrate these concepts.

A7.C4.15.1. Reopening FMS cases. In general, reopening for the purpose of resuming logistical activity is discouraged. Normally, either establishing a new case or amending an existing case is preferred. The purchaser (normally, an official with at least LOA signature authority; but, higher approving authority may exist) must confirm that reopening the FMS case is the only viable course of action. Also, there are situations when a case must be reopened to process valid financial transactions. When it appears that the correct course of action is to reopen a FMS case, the IA must send a written request (e-mail), through the IA focal point for case closure, when one exists, to DSCA (Business Operations Directorate, Financial Policy and Analysis Division) for approval. If the request action is denied, the case shall remain closed. If the requested action is approved, the IA coordinates with DFAS Indianapolis to reopen the case and also advises the purchaser of reopening criteria (e.g., the timeframe in which activity must resume). Reopening allows a case be returned to an implemented status or reverted to interim status in order to process additional disbursements/SDRs.

A7.C4.15.1.1. The 'C5' case reopen transaction is used by the IA to either reopen non-ACCP final closed (closure type C1) cases to implemented status; reverse ACCP final closed (closure type C3) cases to an interim closed status (closure type C2); or with DSCA approval move an ACCP interim closed case to implemented status. If an ACCP case is final closed, two consecutive 'C5' transactions are necessary to move the case to implemented status. The 'C5' transaction may take up to two working days to process in DIFS. If The 'C5' transaction includes the date on which the case was reopened.

A7.C4.15.1.2. Reopening a final closed case to an implemented status is done manually by DFAS Indianapolis upon DSCA (Business Operations Directorate, Financial Policy and Analysis Division) approval of an IA request.

A7.C4.15.1.3. Once a case is re-opened and returns to implemented status, generally, a 'C4' transaction is submitted to cancel the closure certificate record in the DIFS CCCI. This is necessary as any additional financial activity will require the submission of a new closure certification.

A7.C4.15.1.4. For additional processing against ACCP cases, a Direct Final or Final after Interim closed case returns to interim closure status. However, when charges exceed the ULO value assessed at interim closure by $100,000 or more or they will reduce the CCSA balance of the purchaser by more than 75%, the IA shall consult with DSCA (Directorate of Business Operations, Financial Policy and Analysis Division) before moving a case to interim closure status. DSCA will determine if the IA should proceed with the closure type change or if the case should be reopened.

A7.C4.15.2. Once all charge processing is complete, the case may be resubmitted for closure via a 'C1' transaction. A revised certificate is required.

Figure A7.C4.F12. Reopening and Reinstating Activity on FMS cases

Figure A7.C4.F12. Reopening and Reinstating Activity on FMS cases

 

Figure A7.C4.F13. Reopening a Closed Case/Reverting from Final to Interim Closure

Figure A7.C4.F13. Reopening a Closed Case/Reverting from Final to Interim Closure

 

A7.C4.15.3. Reinstating Activity. Reinstatement allows a case that is pending closure to return to its previous status. The process for reinstating activity on cases differs, depending on the status of the case when the reinstatement request is received from the FMS purchaser (Refer to Figure A7.C4.F14.).

A7.C4.15.3.1. If the case is at DFAS Indianapolis for closure (i.e., it is recorded in the DIFS case closure certificate inventory (CCCI), reinstatement is generally discouraged. By this juncture, the case already has been in the closure process for quite some time; for this reason, other alternatives such as using another case must be considered. The purchaser (normally, an official with at least LOA signature authority; but, higher approving authority may exist) must confirm that retraction of the closure certificate is desired. If the purchaser confirms that reinstatement is the solution, the IA must send a written request (e-mail) to DSCA (Business Operations Directorate, Financial Policy and Analysis Division) for approval to cease closure actions and to allow for activity to resume. If the request is denied, closure actions shall proceed. If the request is approved, the IA retracts the closure certificate from DIFS. The IA then advises the purchaser of reinstatement criteria (e.g., the timeframe in which activity must resume).

A7.C4.15.3.2. The 'C4' cancel closure certificate transaction is used by the IA to rescind/cancel an active case closure certificate before the case is actually closed by DFAS Indianapolis. When the 'C4' transaction processes, the DIFS CCCI record is deactivated and removed from the active CCCI, and the computed ULO-REQD value is zeroed out in DIFS. At this point, the IA should reverse any ULO 'NA' deliveries previously submitted. Once a case is closed in DIFS, the certificate cannot be rescinded or cancelled; the case must be reopened. Further, if an interim closed case is certified for final closure, the final closure certificate cannot be cancelled. Instead, the case must be final closed, then the IA may submit a 'C5I' transaction to revert the case status to interim closed. This action causes a cancellation of the final closure certificate.

A7.C4.15.3.3. If the case is neither at DFAS Indianapolis for closure, the IA decides whether to approve the purchaser's request. If the IA denies the request, actions continue to prepare the case for closure. If the IA approves the request, the purchaser is notified accordingly and provided conditions, if appropriate (e.g., the timeframe for resumed activity).

Figure A7.C4.F14. Cancelling a C1I Closure Transaction

Figure A7.C4.F14. Cancelling a C1I Closure Transaction

 

When a case is received into the DIFS CCCI, DFAS Indianapolis verifies the funding source(s) for the case. If FMF (FMS Credit, FMS Credit (non-repayable), MAP Merger) was reserved for the case, DFAS Indianapolis must coordinate adjustments to the FMF commitments with DSCA (Business Operations Directorate, Country Financial Management Division). An FMF-financed case is not considered closed for accounting purposes until the commitment adjustment process is completed.

A7.C4.16.1. DFAS Indianapolis sends a request to the DSCA (Business Operations Directorate, Country Financial Management Division) for a commitment adjustment to the FMF-financed case awaiting closure. The request should not be made until the CCCI status for that case is 'I', indicating that no further reconciliation issues are anticipated. If the CCCI status is other than 'I', that indicates that additional reconciliation actions should occur, thereby making the commitment request premature.

A7.C4.16.2. DSCA (Business Operations Directorate, Country Financial Management Division) confirms that the revised commitment value equals the anticipated closure value. If the case is partially financed with FMF the revised commitment value must equal the final FMF collections as recorded in DIFS. The FMF commitments are then adjusted for that case. DSCA (Business Operations Directorate, Country Financial Management Division) consults with DFAS Indianapolis if any imbalances or other problems arise that preclude the adjustment transaction. For example, if the FMF commitments must increase to reflect the closure value, yet insufficient FMF funds remain, DSCA (Business Operations Directorate, Country Financial Management Division) must coordinate actions with the purchaser. (At times, those actions may result in other cases being de-committed to avail sufficient funds for the case being closed. At other times, the purchaser may have to remit cash to cover the funding shortfall.)

A7.C4.16.3. DSCA (Business Operations Directorate, Country Financial Management Division) sends a written notice (usually via e-mail) to DFAS Indianapolis confirming the commitment actions taken.

Closure of a case impacts the official billing statements sent by the USG to the purchaser. Discussion of its impact on the DD Form 645 (Foreign Military Sales Billing Statement) and Special Billing Arrangement (SBA) is contained below.

A7.C4.17.1. Impact on the DD Form 645. The DD Form 645 is sent quarterly to all purchasers. When a case has been closed during the quarterly period covered by an individual billing statement, an asterisk (*) appears to the left of the case designator. This indicates that the case was closed during that quarter. If residual funds were realized at the time of closure, or if funds were transferred to the case so that collections equaled the case value, those transactions appear on the appropriate holding account statement. Refer to the DD645 sample in Figure 6-3 of the FMS Customer Financial Management Handbook.

A7.C4.17.2. Impact on the Special Billing Arrangement (SBA). Normally, the SBA does not contain any closure information. An exception is if a case is pending closure at DFAS Indianapolis, but additional funds are needed from the purchaser to align collections with the case closure value. In this instance, the SBA cites the cases and payment amounts needed for closure to occur. This information should be gathered by DFAS Indianapolis and transmitted to DSCA (Business Operations Directorate, Country Financial Management Division) as the SBA is being prepared for issuance. Usually, amounts needed to close cases are additive to the calculations for working capital requirements for the period covered by the SBA.

The authority for leases is contained in Section 61 of the AECA. Please refer to SAMM Section C11.10. for detailed lease program information. The administration of leases is delegated to the IA logistically responsible for the defense articles being leased. It is necessary for each IA to ensure that leases under their cognizance are properly closed. A lease cannot be closed until the equipment is returned, all related costs are recovered under FMS procedures (such as costs for restoration), and the lease rental payments are paid in full.

A7.C4.18.1. If a lease expires and the leased material has not been returned, there is no mechanism in place by which the USG can recoup the rental payments not being collected. The lease must be extended prior to lease expiration if an item is to remain in country after expiration of the lease. This allows the USG to charge rental payments to the leasing party and to ensure that the country remains bound to the legal terms and conditions of the lease.

A7.C4.18.2. If a lease expires and the material is returned or disposed of, but the rental payments have not been paid in full, the lease cannot be closed. The IA must ensure that the lease is financially closed. The IA should work with DFAS Indianapolis and DSCA (Business Operations Directorate, Country Financial Management Division) to resolve outstanding payments.

A7.C4.18.3. Section 61 of the AECA states that leases "shall be for a fixed duration of not to exceed five years." If the lease is not closed within five years of the date the lease was implemented, the IA is in violation of this statute.

A7.C4.18.3.1. In the event a lease is not closed within five years of the date the lease was implemented, the IA must prepare a new lease to recoup the additional depreciation charges that accrue for the duration the equipment remains in country after the expiration date of the original lease.

A7.C4.18.4. Section 62 of the AECA states that Congress must be notified of "any agreement with a foreign country or international organization to lease any defense article... for a period of one year or longer." If a lease with a duration of less than one year is not properly closed, and no action is taken to extend the lease (to include proper coordination and congressional notification), the IA is in violation of this statute.

A7.C4.18.4.1. In the event a lease with a duration of less than one year is not properly closed, the IA must prepare a lease amendment to recoup the additional depreciation charges that accrue for the duration the equipment remains in country after the expiration date of the original lease and request DSCA/P3 notify congress of the lease amendment.

A7.C4.18.5. The IA is responsible for the following lease closure actions:

A7.C4.18.5.1. Lease closure procedures shall begin at least two quarters prior to the expiration or termination of the lease. Management Flags are generated by DSAMS to the Lease Case Manager prior to the lease expiration date (180 days, 90, 60, 30), when the lease is Expired, and 30, 60, 90, 120 and 180 days following Lease Expiration. The 'post-expiration' flags are generated unless the Lease has been closed.

A7.C4.18.5.2. Arrangements for return (to include restoration to original condition) or disposal of the leased material shall be completed prior to the expiration of the lease.

A7.C4.18.5.3. Upon return of the items to US custody, the IA posts the item Actual Return Date for each Lease Line in DSAMS. Once all line items have been returned and inspected, the Lease Detail window Lease Tab (I version) should be updated to indicate all items have been returned. Select "subject-open-lease-detail" (I version) and enter the Actual Return date in the Shipment Tab. The Lease Detail Actual Return Date is the date that appears in the DSCA Quarterly Report. The IAs are responsible for entering the Actual Return Dates to both the Lease Line window and the Lease Detail window (when all lines have been returned).

A7.C4.18.5.4. All rental payments and related costs must be collected before lease closure. A notification needs to be made to DFAS when the items are returned so that DFAS Indianapolis can initiate financial closure of the Lease. In DSAMS, select "subject-open-lease-detail," enter the lease designator (I version) and go to the Lease Tab. Select "Tools-Update Implemented Lease". Click on the Text Type Add button and select DFNOT from the drop down list. Enter a title "DFAS Notification" and enter a date in the comments field. ONLY a date should be entered, e.g., 1 Dec 2003. Once the IA updates DSAMS a management flag is produced notifying DFAS to close the lease case.

A7.C4.18.5.5. Once the Lease is closed in DIFS, the IA opens the lease detail window "I" version, select "Update Implemented Lease" and update the Lease Condition Code in the Summary Tab. The normal condition code is TR (Termination and material Returned). Other selection options are TS (Termination and material scrapped), TP (Termination and an LOA is in process for Purchase), and TG (Termination and Grant in Process).

A7.C4.18.5.6. The final step in Lease processing is for the IA to close the Lease. Select "subject-open-lease-milestone." Enter the Lease Designator and click OK. In the Lease Milestone List window, select "tools-MILDEP options-Close Lease." This posts the closure milestone to the lease and also updates the lease status (from Open to Closed).

The authority for granting of EDA is contained in Sec 505, FAA. Please refer to the SAMM Section C11.3. for detailed grant EDA program information. The management of EDA Grant cases is delegated to the appropriate IA. It is necessary for each IA to ensure that Grant EDA cases under their cognizance are properly closed. Most IAs have the capability to certify zero value Grant EDA cases for closure using standard procedures. For those IAs whose management systems do not support the use of standard procedures, the following alternative closure process exists.

A7.C4.19.1. Once the zero value Grant EDA case is ready for closure, the IA will load the (CLSEDAGRNT) milestone to the 'I' version of a Grant EDA case in DSAMS, which will trigger a management flag (CLSEDAGRNTMF) to DFAS Indianapolis informing them that the case is ready for closure.

A7.C4.19.2. DFAS Indianapolis will take action to close the Grant EDA case in DIFS based on receipt of the management flag.

A7.C4.20.1. Table A7.C4.T7. lists the systems interfaces that occur prior to and during case closure.

Table A7.C4.T7. Systems Interfaces

A7.C4.21.1. Table A7.C4.T8. reflects manpower funding guidelines pertaining to closure efforts:

Table A7.C4.T8. Closure Manpower Funding

Closure Function Funding Source

Closure efforts for SSC cases, to include non-ACCP and ACCP closures.

FMS Administrative surcharge.

Expedited case closure efforts requested by the purchaser beyond normal financial management standards.

A line on a new or existing case is preferred, although a line on a non-SSC case being reconciled could be used as well.

A7.C4.22.1. Table A7.C4.T9. lists the primary POCs for active case reconciliation and closure issues.

Table A7.C4.T9. General POC Matrix

Organization Office

DSCA (Policy)

DSCA Financial Policy and Analysis (FPA)

Army

USASAC New Cumberland (AMSAC-LAL-CS)

Navy

NAVY IPO (240C)

Air Force

AFLCMC/WFCQ

DFAS Indianapolis

DFAS-IN/JAX

DCMA

DCMA-FB