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Chapter 03 – Agent Cashier Accountability Policy

Volume VIII - Cash Management

Date Approved: November 16, 2023

Financial Documents

Volume VIII - Cash Management

Chapter 03 – Agent Cashier Accountability Policy

Questions concerning this policy chapter should be directed to:

0301 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policies for authorized agent cashiers.

Key points covered in this chapter:

  • Agent cashiers, as authorized per 31 U.S.C. § 3321, will be designated to disburse and collect funds;
  • Treasury Financial Manual (TFM), Volume 1, Part 4a, 5, and 6, as well as the Treasury Agent Cashier Manual, contain government-wide policy for agent cashier activities;
  • VA will establish an agent cashier fund (per 31 C.F.R. § 202.4) at each field facility;
  • Agent cashiers will be responsible and must account for all cash and undeposited collections as well as fund replenishment actions; and
  • Agent cashiers will ensure the Agent Cashier Depositary Account Reconciliation (VA Form 10235) and the Cashier’s Reimbursement Voucher and/or Accountability Report (OF 1129) are submitted monthly to the Financial Services Center (FSC) and the Facility Director.

0302  Revisions

SectionRevisionOfficeReason for ChangeEffective Date
030501Targeted change to provide guidance on designation for Authorization OfficialOFP (047G)Add requirement on the use of the form FS 2958 for Authorizing OfficialNovember 2023
030516Targeted change to provide guidance on internal controls related to agent cashier activitiesOFP (047G)Provide clarification to the readerNovember 2023
See changelog for previous policy revisions.

0303 Definitions

Accountability Report – A reconciliation document that is used to verify the status of cash in the cashier fund.

Accommodation Exchange – The authorized exchangeof equivalent monetary values in different forms to authorized persons; for example, cash in exchange for a check.

Agent Cashier – A Federal Government employee, designated as a cashier by an authorizing official and authorized to disburse cash or carry out other cash-related activities. There are two types of cashiers:

  • Class “A” Cashiers- authorized to make disbursements and may advance funds only to an alternate cashier. Class “A” Cashiers may not advance funds to other disbursing officials or cashiers other than the alternate cashier.
  • Class “B” Cashiers – authorized to make disbursements and may also advance funds to an alternate cashier or other disbursing official (e.g., VA employee designated to take money to a Veteran).

Alternate Cashier – A cashier, officer, or employee who has been designated in the same manner as a principal agent cashier to disburse cash or carry out other cash-related activities.

Authorizing Official – All Federal Agency Heads, Designees, or Facility Directors have been delegated the authority by the Bureau of Fiscal Service to appoint agent cashiers.

Bank Signature Card – A record maintained by financial institutions to verify a customer’s signature. This document is signed by the account holder when an account is opened and by new account holders when they are added to the account.

Cashless Agent Cashier – An agent cashier operation that does not have a cash advance from the agency.

Contaminated Currency and Coins – A note damaged by or exposed to a contaminant to the extent that it cannot be processed under normal operating procedures or may pose a health or safety risk.

Convenience Checks – Convenience checks are a payment and/or procurement tool intended only for use with merchants that do not accept purchase cards. Convenience checks are used as a payment method of last resort, when no alternate merchant is available who accepts the purchase card.

Electronic Funds Transfer (EFT) – Electronic transmission of funds to financial institutions.

Interim Receipts – Documents used to support the transfer of accountability for a portion of an advance.

Irregularity – Irregularity is any variance from actual amount of the established agent cashier advance. Irregularities may arise from different circumstances (e.g., shortage due to physical loss, giving too much change, shortage due to illegal actions, fraud, forgery, alteration of vouchers, overages, and other improper practices).

Over the Counter Network (OTCnet) – A web-based application that integrates Check Capture and Deposit Reporting functionalities into one system. OTCnet’s design accommodates check capture and deposit reporting using electronic collection mechanisms instead of paper-based processing.

0304  Roles and Responsibilities

Under Secretaries, Assistant Secretaries, Chief Financial Officers, Fiscal Officers, Chief Accountants, and Other Key Officials are responsible for ensuring compliance with the policies set forth in this chapter.

Financial Services Center (FSC) is responsible for:

  • Providing operational support related to agent cashier activities;  and
  • Reviewing and maintaining the agent cashier’s accountability reports (e.g., VA-10235 and OF 1129) received electronically from the facility or provided on the FSC Agent Cashier Accountability (ACA) portal.

Facility Directors are responsible for oversight of local agent cashier activities.

Finance Offices are responsible for oversight of agent cashier activities.

Authorizing Officials are responsible for designating agent cashiers.

Certifying Officers are responsible for approving payment schedules transmitted to Treasury for disbursements and ensuring voucher schedules are processed correctly and timely.

Agent Cashiers are a category of disbursing officers that are authorized to make payments from advanced funds. Principal agent cashiers who make disbursements may be either Class “A” or Class “B” cashiers.

Principal Agent Cashiers are the primary agent cashiers at the local facility.

Alternate Agent Cashiers are responsible for performing agent cashier duties only during the absence of the principal agent cashier. Where the volume of transactions requires both principal and alternate to act simultaneously, the principal will advance funds based on a receipt signed by the alternate.

0305  Policies

030501 Appointing Agent Cashiers

  1. An agent cashier must be a VA employee. Contractors may not serve as agent cashiers.
  2. Certifying Officers (CO) cannot be agent cashiers. CO requirements are discussed in Volume VIII, Chapter 1 – Certifying and Disbursing Officials/Officers.
  3. Authorizing Officials will be appointed on Bureau of Fiscal Service Form 2958 (FS2958). Refer to Volume VIII, Chapter 1 – Certifying and Disbursing Officials/Officers, for additional information on designation of authorizing officials.
  4. An Authorizing Official will appoint an agent cashier using VA Form 0901, Request for Change or Establishment of Imprest Fund.
  5. VA Form 0901 will specify class and type of cashier (i.e., Class A or Class B cashier).
  6. VA Form 0901 will be digitally signed and sent via email to FSC at VAFSCAgentA@va.gov for processing.
  7. Alternate agent cashiers will be designated at facilities where the volume of small purchases is too large to be effectively handled through the principal agent cashier or where the distance between the finance office and the Acquisition and Material Management Office is considerable. Alternate agent cashiers will also be assigned to cover the cashier operation during the absence of the principal agent cashier.
  8. Principal agent cashiers and alternate agent cashiers who issue convenience checks will complete the online Purchase Card training courses and a delegation of authority (VA Form 0242c) to issue convenience checks per Volume XVI, Chapter 1C, Government Convenience Checks.

030502 Change in Agent Cashier Personnel.

  1. When a replacement principal agent cashier is selected/delegated:  
    1. All funds including prior advances will be verified.
    2. Funds will be counted and verified by two disassociated parties (i.e., those without a vested interest). Field Service Receipts will also be inventoried and verified by the parties.
    3. All interim receipts must be returned to the outgoing principal agent cashier. If the alternate agent cashier has interim receipts documenting the advance funds, the interim receipts should be returned to the outgoing principal agent cashier. If new interim receipts are required, it must be reissued by the new incoming principal agent cashier. These interim receipts are used to calculate the total advanced funds.
    4. The outgoing principal agent cashier will prepare an OF 1129 in his or her name and complete the Status of Funds section. Any overage or shortage in the advance will be noted in the OF 1129 Status of Funds section. On the certification section of the form, a notation shall be made that indicates what has been transferred by including the name of the incoming principal cashier and annotating the date.
    5. The incoming and outgoing principal agent cashier and the two disinterested persons sign the OF 1129 as evidence of the count.
    6. The outgoing principal agent cashier shall claim reimbursement for all unscheduled sub-vouchers (vouchers for each of the alternate’s) on OF 1129.
    7. The entire advance including sub-vouchers will be given to the new principal agent cashier.
  2. When the new principal agent cashier has not been designated before the outgoing principal agent cashier leaves, the alternate cashier will be accountable until a new principal agent cashier is designated, and accountability is transferred.
  3. During the transition period (i.e., from one agent cashier to another), a designee whose name is on the bank signature card shall fulfill the responsibility of writing a check, changing orders, and accessing the EFT bank account.
  4. The facility will complete a VA Form 0901 to revoke an agent cashier designation electronically and it will be signed by the authorizing official.

030503 Establishing/Adjusting the Cashier Advance

  1. VA will establish and maintain only one agent cashier disbursing fund per field facility for use by agent cashiers.
  2. FSC will record advances from Treasury in VA’s agent cashier disbursing account (i.e., Fund 0160X4 in FMS, Fund 0160XDD in iFAMS, GL 112000, Imprest Funds).
  3. The facility finance office will maintain a record of each cashier and the amount of cash advanced to them.
  4. Facility Directors will limit the size of the agent cashier account to the minimum amount of cash required to meet the normal operating needs of the Veteran population serviced by the facility.
  5. Facility Directors may authorize requests to increase/decrease the size of the agent cashier account using VA Form 0901. Completed forms will be submitted to the FSC via VAFSCAgentA@va.gov. For additional information on increasing and decreasing funds, refer to Appendix A: Adjusting Agent Cashier Fund Advances.
  6. The FSC Disbursing Officer’s signature is required on VA Form 0901 when there is an increase or decrease of a facility’s agent cashier advance.
  7. For emergency increases, the facility will complete the Electronic Certification System (ECS) Same Day Advance Request form, which must also accompany VA Form 0901.

030504 Cashier Bank Accounts

  1. Facility Directors are authorized to establish a depositary demand account under 31 C.F.R. § 202 and 31 C.F.R. § 208 for the principal agent cashier and/or the finance office for agent cashier account replenishment purposes.
  2. In order to establish and maintain a VA cashier account, the financial institution must meet the eligibility requirements contained in 31 C.F.R. § 210.8. Banks, credit unions and savings and loan institutions are eligible to serve as government depositories under this regulation.
  3. The bank account chosen must be either an interest-bearing savings account or a checking account that provides the minimum insurance coverage amount of $250,000 provided by the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Share Insurance Fund (NCUA) and the Savings Associated Insurance Fund (SAIF). Any service charges or other related fees are paid by the facility and then replenished. Any net interest earned from the account is recorded by the facility via OTCnet into the appropriate general ledger in VA’s accounting system and the funds (i.e., FMS Fund 1435 and iFAMS Fund Code 1435CU) are deposited to Treasury.
  4. To establish a deposit account:
    • The Facility Director will initiate the establishment of the deposit account by providing a letter to the financial institution. The letter will specify that deposits are official funds of the U.S. Government and that overdraft protection is not required for the account;
    • The local facility will obtain three bank signature cards. One each for the Facility Director, Chief Financial Officer (CFO)/or a designee that holds a management position within finance, and Principal Agent Cashier. For more information on bank signature cards, contact FSC at VAFSCAgentA@va.gov; and
    • The local facility will ensure the three individuals named on the bank signature cards are the only authorized persons to withdraw funds to replenish the cashier account;
  5. To begin processing reimbursements via EFT the bank must be vendorized. Agent cashiers will complete VA Form 10091 and forward it and a copy of the director’s letter to FSC at VAFSCAgentA@va.gov for review and vendorization.

030505 Replenishment and Maintaining Agent Cashier’s Fund

  1. The agent cashier must monitor and ensure the agent cashier’s fund is replenished.
  2. Agent cashier bank accounts will only be used to replenish the agent cashier’s funds. Any remittance received by the agent cashier will not be deposited into these accounts.
  3. Agent cashiers will perform a complete verification of the facility’s advance (using OF 1129) prior to requesting account replenishment, which should occur daily if necessary.
  4. Treasury has limited cash payments (in favor of EFT) activities per 31 C.F.R. § 208.3 and the Treasury Imprest Fund Policy Directive. Therefore, VA will replenish agent cashiers by EFT.
  5. Purchase cards and/or convenience checks will not be used to establish, maintain, or replenish a cashier account.
  6. For additional information, refer to Appendix B: Replenishing and Maintaining the Agent Cashier’s Fund.

030506 Agent Cashier Advances to Others

  1. The principal agent cashier may advance funds to other designated employees (i.e., alternate agent cashier, other disbursing officers). Advanced funds will be signed for by the recipient on an interim receipt. Advances must be returned upon the revocation of the associated designation.
  2. The following individuals may be advanced funds:
    • Alternate agent cashiers;
    • Other disbursing officers; and
    • Employees designated by the Facility Director to make authorized expenditures in the interest of VA.
  3. Other disbursing officers (e.g., social workers), who handle small amounts of money ($50-$200, petty cash) are not considered agent cashiers. They may be appointed and revoked via memorandum by the Facility Director. Other disbursing officers are subject to the same liabilities and restrictions as an agent cashier.

030507 Collections

  1. There are various reasons why VA may receive a collection, such as:
    • Debt Collections;
    • Personal Funds of Patients (PFOP) Collections;
    • Loan Guaranty Collections; and
    • Field Facility Insurance Collections.
  2. To align with Treasury guidance to reduce paper checks, agent cashiers are encouraged to use EFT to collect from Veterans or VA employees. The use of checks will be the last resort for collection.
  3. Agent cashiers will issue a receipt for all collections, regardless of the type of instrument (e.g., cash, checks, bank drafts, traveler’s checks, money orders, credit card, etc.) received.
  4. To safeguard receipt forms, the agent cashier will keep the entire supply of counter receipts (e.g., Receipt form number 4‑1027, Field Service Receipt – General, and Field Service Receipt – Patients Funds, receipt form number 4-1028) in his or her safe (or locked drawer for cashless agent cashier).
  5. Receipt forms may not have corrections, strikeovers, changes, erasures, or alterations. Therefore, when an error is made issuing a receipt the entire receipt and all copies must be voided.
  6. A field receipt is issued for checks drawn on banks of foreign countries. The space provided for “Amount” on field receipts will be left blank and the amount in terms of foreign currency will be entered in the block normally reserved for deferred credit.
  7. Agent cashiers will collect fee for service payments from employees for service as a juror or witness for deposit to the salary appropriation charged for the affected employee’s salary. Court payments to the employee may combine payment for service with reimbursement of the employee’s expense for parking, transportation, or meals. Employees must cash the court’s check and then limit payment to VA to the daily fee for service amount for days charged to court leave during that service. Agent cashiers may not accept the court check which includes an employee expense reimbursement component.
  8. Agent cashiers will carefully examine all bills $50 or higher before acceptance.
  9. Agent cashiers will familiarize themselves with currency security features published by the U.S. Department of the Treasury, Bureau of Engraving and Printing.
  10. Agent cashiers will obtain UV lights and counterfeit bill detector pens to verify the presence of the security thread and watermark.
  11. When officials (e.g., chaplains, cemetery directors, field staff) other than the agent cashier receive collections, donations, etc., the funds received will be given to the agent cashier as soon as possible, preferably on the same day. If same-day delivery is not possible, reasonable efforts must be made to secure the collections temporarily until the funds can be turned over to an agent cashier. For example, collections can be safeguarded by locking them in the official’s desk drawer/file cabinet or another secured area.
  12. Agent cashiers will redirect salary-related debt payments from current VA employees for submission through pay.gov or their servicing payroll office.
  13. Agent cashiers will collect current employee non-payroll debts and separated employee debt.
  14. Agent cashiers are authorized to accept Treasury checks for full payment of a debt owed to VA by employees or Veterans. The agent cashier cannot commingle such receipts with the agent cashier fund advance.
    1. Agent cashiers will accept the Treasury check in payment of a debt when the Treasury check matches the full debt amount; separately maintain the check from the agent cashier disbursing fund; and forward the check to the finance office for proper deposit to VA accounts.
    2. When the Treasury check exceeds the amount of the debt, agent cashiers will pay the debtor the difference out of the agent cashier disbursing fund, then forward the accepted check to the finance office for proper deposit to VA accounts. The disbursing fund will be replenished for the difference paid to the debtor.
    3. The agent cashier will ensure the individual presenting the check is the rightful payee prior to accepting the Treasury check to pay for indebtedness. A field service receipt will be issued for money withheld to apply against the indebtedness.
  15. Funds found on VA premises (including funds found by Veterans, employees, caregivers, etc.) with unknown ownership will be accounted for in the Budget Clearing Account (Suspense).
    1. If ownership is not established within 90 days, as prescribed by 38 C.F.R. § 12.24, the funds will be transferred to the General Post Fund.
    2. If ownership is established to the satisfaction of the Facility Director, the funds will be released by completing VA Form 2064, Authority to Release and Ship Effects, and Funds.
  16. All checks received via U.S. Mail will be submitted to the agent cashier within 24 hours for deposit. Checks shall not be kept in any safe or secured office for more than 24 hours unless it is the agent cashier area.
  17. Collections received via mail will be delivered by the mail-unit directly to the agent cashier in the envelope in which they were received. The agent cashier will retain the remittance intact until its disposition is discovered.
  18. Agent cashiers will forward checks that are not related to agent cashier fund activities to the appropriate office. Examples include:
    • Checks from volunteer organizations for the purpose of paying for insufficient postage on beneficiaries’ incoming mail;
    • Checks collected and received by Veterans Canteen Service (VCS) activities;
    • Checks, Certified checks, cash, or U.S. government bonds received in sealed envelopes plainly marked to show a connection with a sealed contract bid; and
    • Checks for insurance items.
  19. In the case of collections identified as insurance items, the envelopes and any correspondence pertaining to the items will be attached to the copies of the applicable VA receipt forms and forwarded with VA Form 24-1551, Transmittal Schedule of Insurance Collections, to the VA insurance office, Collection Staff.
  20. Funds received by the agent cashier will not be deposited into agent cashier bank account as that bank account is only used to replenish the agent cashier’s fund.
  21. Funds received by the agent cashier, which are subsequently determined not to be due to the U.S will be deposited, and if in excess of $25, refunded to the remitter by check. Amounts less than $25 will not be refunded unless requested. A logbook showing the amount, date returned, name, and address of the remitter will be maintained by the agent cashier. For additional information on refunds, refer to Vol II, Chapter 7G, Refunds Issued by VA.
  22. Agent cashiers will not routinely accept personal checks, in excess of $100, for deposit to the Personal Funds of Patients (PFOP) accounts. The facility director or designee has the authority to waive the limitation if circumstances warrant. Checks and other negotiable instruments for patients that have been deemed  “incompetent” should be made payable to the Director, VA Medical Center (location) for credit to the account of (name of Veteran, patient account number).
  23. All payments received for the Medical Care Collection Fund (MCCF) program will be secured in the agent cashier’s office and sent as certified or insured mail to the servicing Consolidated Patient Account Center (CPAC) within 24 hours. All accompanying documentation shall accompany checks sent to the CPAC. The CPAC agent cashier will take the appropriate action to deposit the check(s).
  24. Agent cashiers are authorized to accept the following valid negotiable instruments for competent hospitalized and domiciled beneficiaries:
    • Checks drawn on the United States Treasury;
    • Checks drawn by State Government Agencies;
    • Certified checks;
    • Travelers checks;
    • Money orders;
    • Bank drafts; and
    • Cashier’s checks.

030508 Endorsements of Remittances – Checks and Other Negotiables

  1. Agent cashiers will endorse checks and other negotiable instruments upon receipt, making them non-negotiable.
  2. VA’s standard endorsement is as follows:
    • Deposit symbol (agency location code);
    • For credit to Treasury, (date); and
    • Deposited by the agent cashier, Department of Veterans Affairs (Central Office Regional Office, Medical Center or Domiciliary), City, State, ZIP Code.
  3. FSC will use VA’s agency location code (ALC) (36001200 in FMS and 3600104 in iFAMS) as the deposit symbol when the collection relates to a receivable for which the FSC has accountability.
  4. Checks received on behalf of an incompetent Veteran patient will be given a restrictive endorsement: “Pay to the Director, VA Medical Center (location) for credit to the account of (Name of Veteran, patient account number).”
  5. Checks and other negotiable instruments cashed as an accommodation exchange to Veterans must contain as part of the endorsement “Accom Exch”.
  6. Checks received from Treasury require a VA official to endorse the check.
  7. A deferred credit period will be endorsed on each field service receipt covering a remittance submitted in the form of a personal check for all deposit(s), so the credit will not be recorded until it has been paid by the bank on which it is drawn.
  8. The deferred credit period will ordinarily be ten working days for paper checks processed in OTCnet Deposit Module and two working days in OTCnet Check Processing Module.
  9. The exact deferred credit period will be shown by the following entry: “Credit deferred until (date).”
  10. The deferred credit period will be waived on remittances in the form of personal checks when the facility Director or designee so authorizes, based upon a determination that circumstances are sufficiently emergent to justify such action.
  11. The deferred credit period is not required in those cases where personal checks are received from custodians of patients’ funds at other Federal hospitals for the credit of transferred patients.

030509 Shipment of Cash, Negotiable Instruments, Valuables, etc.

  1. When cash, negotiable instruments, valuables, etc. must be shipped, the principal or alternate agent cashier shall prepare the shipment, maintain shipment records and prepare necessary reports (e.g., report on losses incurred relative to shipments).
  2. The principal agent cashier will count and enclose in a sealed envelope all funds for mailing or deposit in the presence of another employee who serves as a witness to the content of the shipment in case it is lost. Collections will be carried to designated depositaries and registered or certified mail will be used for cash, checks, drafts, and money orders. The employee witness for these shipments will be routinely rotated.
  3. When valuables need to be mailed or shipped, the agent cashier will prepare and retain VA Form 1011 Record of Shipment of Valuables. A copy of form 1011 and other relevant documents will be placed in the sealed package. This document will be the official record to support the establishment of debts, adjustment of accountable property records and financial records.
  4. Shipments will be made by certified/insured mail through a U.S. Post Office or a courier (e.g., FEDEX, UPS, etc.).
  5. The agent cashier will insure a shipment based on the value of the cash and negotiable instruments in the package. A package will not be insured if the declared value is less than the fee to insure it.
  6. Before being shipped, all negotiable instruments must be restrictively endorsed.
  7. A security escort is required when valuables are transported by VA personnel. The security escort must be rotated routinely.

030510 Deposits

  1. VA will comply with Treasury’s deposit procedures as specified in TFM Volume I, Part 5, Chapter 2000, Depositing Domestic Checks and Cash Received in Over the Counter (OTC) Collections.
  2. VA will adhere to TFM, Volume III Part 2, Chapter 1000, Deposits for Credit to Treasury’s General Account (T/L) and Part 3, Chapter 1000, Maintaining Treasury’s General Account (T/L3) and ensure funds received are deposited into Treasury accounts in a reasonable timeframe.
  3. Timeliness is determined by the daily dollar amount of funds received by the agent cashier. Daily receipts totaling $5,000 or more will be deposited each day. Receipts less than $5,000 may be accumulated and deposited when the total reaches $5,000 for Over-the-Counter bank deposit; however, a deposit must be made by Thursday of each week, even if the $5,000 limit is not reached.
  4. Agent cashiers will complete required standard forms (e.g., SF 215, Deposit Ticket (Optical Character Recognition)) for making a deposit. VA will deposit foreign currencies to the appropriate depositary along with the associated deposit ticket. See Appendix C: Deposit Procedures, for additional information.
  5. VA will use the OTCnet web-based platform to process paper checks and make deposits to Treasury. VA will scan checks daily even if the $5,000 limit has not yet been reached when using OTCnet Check Capture. For additional information on how an agent cashier can make deposits using OTCnet, refer to Treasury’s website and Appendix C: Deposit Procedures.
  6. VA will adhere to the guidance provided by Federal Reserve Banks (FRB), for handling contaminated currency and coins. Documentation will be maintained relating to the dollar value of the funds involved.
  7. The agent cashier will deposit monies received for donations (i.e., cash or checks received by chaplains, cemetery directors, or officials other than the agent cashier) into the General Post Fund or Cemetery Gift Fund and must also be informed about the purpose for which the money was intended. Directed donations will be used in accordance with the donor’s instructions, if provided.
  8. Agent cashiers will prepare and maintain records of deposits coming from OCONUS and make the necessary entries in OTCnet.
  9. When a check proves to be uncollectible, the depositor will prepare an SF 5515, Debit Voucher, and promptly charge the amount of the unpaid item to the bank account, except when special arrangements are made between the depositary and the depositor to defer the immediate charging of the accounts. Under such an arrangement, the uncollectible check is automatically reprocessed for collection by the depositary, returned to the depositor to be presented again, or replaced by a new check. The SF 5515 will not be prepared in such cases until the elapse of time mutually agreed upon by both parties.
  10. Non-Sufficient Fund check fees will be charged against the account of the U.S. Government by the specific depositary and the adjustment will be recorded in OTCnet.
  11. If a check is tendered in support of an offer to compromise an existing indebtedness, the check will not be deposited prior to VA issuing a decision to accept the offer. The agent cashier will:
    1. Maintain copies of the local referral documents and the related checks.
    2. If the offer is rejected, return the check to the debtor unless the debtor has given a prior indication of consent to apply the amount of the check against the indebtedness.
    3. Routinely follow-up on the status of a decision, when a compromise offer has not been decided within 30 days following a referral (45 days for referrals to the Chief, Operations, Debt Management Center, St. Paul).
  12. If a check tendered in support of an offer to compromise is inadvertently deposited, before a decision is reached on the acceptance of the compromise offer by an authorized component of VA, the compromise offer will not be considered binding upon VA and the amount of the check shall be refunded.

030511 Irregularities and Lost Shipments

  1. When an irregularity in the agent cashier’s fund is identified:
    1. The local facility will notify FSC within 24 hours by phone or email.
    2. The agent cashier will immediately provide a verbal report to the appropriate supervisor followed by a written report within three business days.
    3. The supervisor will prepare a written follow-up within three days and submit it to the finance office.
    4. The local facility will investigate the irregularity in a timely manner.
    5. The Facility Director will determine any fault or negligence after the investigation is completed.
    6. When a loss has been identified, the local facility will report a “Loss” in the “Status of Fund” portion of the OF 1129 until relief has been granted or restitution has been made.
    7. The local facility will attempt to recover lost funds, identify potential risks related to the process that led to the loss, and make necessary changes to reduce the risk of and future loss of funds.
    8. Local facility will recover funds from an improper payee or recipient in accordance with the Federal Claims Collection Act, 31 C.F.R. Parts 901 § 901.1-901.5, VA Regulation 38 C.F.R. § 1.900–1.954, and Volume XII, Debt Management.
  2. VA will resolve agent cashier debts in accordance with the provision of the Federal Claims Collection Act at 31 U.S.C. § 3711. The Facility Director will refer to VA’s financial polices contained in Volume XII, Debt Management for guidance on adjudicating irregularities and physical losses. See additional guidance on compromise requests in Appendix E: Authority to Compromise/Waive Agent Cashier Debts.
  3. The Facility Director or designee will report all losses (regardless of the dollar amount) related to fraud (e.g., embezzlement or fraudulent acts by agent cashiers whether acting alone or in collusion with others) to the facility’s local law enforcement, VA Office of Inspector General (OIG), and FSC.
  4. Overages due to bank errors in the accounts of the agent cashier will be recorded in the proper general ledger account in VA’s accounting system.
  5. Lost shipments valued over $100 must be reported to the local law enforcement, local VA OIG, and the nearest U.S. Post Office or carrier that handled the shipment. In addition, the local facility must:
    1. Cooperate fully with any investigators;
    2. Place a tracer on the shipment;
    3. Notify the FSC, at VAFSCAgentA@va.gov, providing the following information:
      • Date of shipment;
      • Amount and Description of loss (i.e., amount of PFOP, insurance co-pay);
      • Name and address of the consignee;
      • Registry receipt number when applicable; and
      • Statement of the cause of loss, if known.
    4. Immediately upon discovery of the loss, destruction, or damage take action to stop payment or delivery on negotiable instruments.
  6. VA will comply with 40 U.S.C. § 17303 and use the appropriate revolving fund established by Treasury to pay for losses incurred during shipment.

030512 Treasury Checks

  1. The agent cashier will perform the following actions to process a returned Treasury check (e.g., undeliverable or unnegotiated check):
    1. Issue VA Form 4-5602, Receipt for Returned Treasury Check, to the individual returning the check in person and provide a copy.
    2. Complete VA Form 1409, Transmittal-Checks Returned to Agent Cashier and forward it to the physical address listed below.

      U.S. Department of the Treasury
      Bureau of the Fiscal Service
      P.O. Box 51316
      Philadelphia, PA  19115

  2. Agent cashiers will work with FSC to ensure Treasury checks are cancelled.
  3. Benefit checks for Veterans and beneficiaries who fail or refuse to provide a current mailing address to VA will have their benefit checks delivered to the principal agent cashier of the closest Regional Office to the Veteran’s last known geographical location. This may include unclaimed checks for compensation, pension, and survivors’ benefits and educational benefits. Unclaimed checks will be retained for 30 days, then returned to Treasury.

030513 Disbursement Actions

  1. VA encourages all payments to be made electronically in accordance with the Debt Collection Improvement Act of 1996 and 31 C.F.R. § 208.3.
  2. Agent cashiers may use an alternative disbursement mechanism, such as cash, only when a payment meets the EFT waiver requirement. Some acceptable waiver conditions include:
    • When an individual was born prior to May 1, 1921 and was receiving payment by check on March 1, 2013;
    • Payments for which Treasury does not offer delivery to an account. In such cases, those payments are not required to be made by electronic funds transfer, unless and until such payments become eligible for deposit to an account; and
    • Payee is ineligible for an account because of suspension or cancellation of the individual’s account by the Financial Agent.

      For additional information on wavier requirements, refer to Volume VIII, Chapter 2, Disbursements.
  3. Agent cashiers will never issue a payroll-related disbursement, regardless of the reason.
  4. Agent cashiers may under very limited circumstances issue convenience checks instead of paying for goods/services via the government purchase card or an EFT payment. Use of convenience checks is discouraged and must conform with Volume XVI, Chapter 1C, Government Convenience Checks.
  5. Agent cashiers will arrange with the employee to deliver any salary checks that have been forwarded to the cashier’s office. Any checks that are determined to be undeliverable will be returned to the Disbursing Office within five days of receipt by the agent cashier. If it is determined that an employee is on leave, or there is a specific reason why the check should be held, it may be held for up to 30 days after receipt by the agent cashier.
  6. Agent cashiers may make disbursements on a wide range of financial transactions related to Veteran benefits check, research study programs, social work services, compensated work therapy, etc.
  7. In order to accurately track disbursements agent cashiers will issue sequentially numbered vouchers for each disbursement and maintain a master voucher number register to ensure completeness of disbursement records.
  8. Agent cashiers will keep a listing of all officials authorized to approve reimbursement claims. This listing must be updated whenever authorizing officials change. Signatures on disbursement requests must be verified against the listings before issuing funds to claimants.
  9. Agent cashiers may cash Treasury checks for non-hospitalized homeless Veterans as long as cashing the check will not deplete the agent cashier fund to the point of interfering with operations.
  10. Agent cashiers may make accommodation exchanges for inpatient, homeless Veterans, and non-hospitalized Veterans (e.g., VA benefit checks mailed in care of the principal agent cashier).

030514 Disbursements During Declared Emergency

  1. A VA-declared emergency occurs when the Secretary of VA, or designee, issues a statement of “Declared Emergency” noting the time the emergency is declared and the VA facilities covered by the declaration. For additional information on declared emergency, refer to Volume XIII, Chapter 6, Accounting During Declared Emergencies.
  2. VA shall properly track expenditures, account for costs, and maintain documentation for its funds during a declared emergency.
  3. During an emergency when a Veteran is unable to use a selected financial institution, the agent cashier may coordinate with FSC to increase the agent cashier funds to serve the needs of Veterans.
  4. The authorized delegated official shall notify field facilities of the appropriate procedures to use if EFT payments cannot be processed.
  5. If the funds needed during an emergency exceeds the amount in the agent cashier’s fund, the facilities finance official may contact FSC to request direct assistance from Treasury (i.e., replenishment via Fedwire).
  6. VA’s payroll provider, Defense Finance and Accounting Service (DFAS), has established payment guidance for issuing salary payments during emergencies. Salary payments cannot be issued by the agent cashier even during a declared emergency.

030515 Reconciliation and Reporting Process

  1. The agent cashier will prepare an OF 1129 EOM accountability report covering all cash items held by the agent cashiers. The report will be prepared in the morning of the first workday of the following month. The OF 1129 EOM report must include: 
    1. A notation that this is the EOM accountability report.
    2. The pending reimbursement amount, including any prior month reimbursement that has not been received. Pending reimbursements will be listed by type, date, and amount, and are shown on the reverse side of the monthly accountability report.
    3. A completed Status of Funds section indicating total funds advanced including any losses, shortages, interim receipts, advances to other agent cashiers and any other employees authorized to hold cash from the principal agent cashier’s account.
    4. Supporting schedules containing:  
      • Paid replenishments received during the reporting month to the agent cashier’s replenishment bank account; and
      • List of alternate agent cashier and other disbursing officers, and amount of the advance signed for each on interim receipts.
    5. The number and amounts of accommodation exchange transactions. Agent cashiers will make a special note of those transactions to accommodate homeless Veterans (38 C.F.R. Part 1, § 1.710).
    6. The number of replenishments submitted during the month and the total value. This includes both regular and accommodation exchange replenishments.
  2. The EOM OF 1129 will be certified by the finance office and sent to FSC no later than the fourth workday following the end of the month.
  3. Facilities with an agent cashier will complete a monthly bank reconciliation using VA Form 10235, Agent Cashier Depositary Account Reconciliation.
  4. To avoid conflicts of interest and maintain segregation of duties, the agent cashier, cannot perform the bank reconciliation. The reconciler should obtain information necessary to complete the reconciliation from multiple sources, including but not limited to the bank, previously submitted OF 1129s, EFT register, and checkbook.
  5. The VA-10235 and the depositary statements must be retained by the agent cashier as part of the official records, which will be subject to review during unannounced audits.
  6. Facilities will submit the accountability report and bank reconciliation (i.e., OF 1129 and VA-10235) to FSC ACA portal. If unable to upload the report and reconciliation to FSC ACA portal, the facility will send an electronic copy via encrypted email to FSC via VAFSCAgentA@va.gov.
  7. Facilities will furnish a copy of the accountability reports to their Facility Director. The Facility Director will acknowledge receipt of the reports and notify the facility’s CFO that it has been reviewed.

030516 Internal Controls

  1. VA will comply with OMB Circular A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control, to implement effective internal controls that reduce/mitigate risk. Such controls include proper segregation of duties (e.g., agent cashiers will not fulfill the duties of PFOP clerks), periodic audits, and safeguarding cash related activities.
  2. Agent cashiers cannot have the ability to obligate funds.
  3. At a minimum, facilities with an agent cashier will ensure the following with regard to agent cashier operations:
    • Duties are properly segregated;
    • Fund security measures are in place;
    • Agent cashier will be escorted by security or VA personnel designated by the Facility Director or CFO to withdraw funds from their bank account to replenish the agent cashier’s fund;
    • Procedures to address foreseen and unforeseen cashier absences exist;
    • Periodic audits are conducted; and
    • Records are properly maintained and complete.
  4. Alternate agent cashiers may not work for more than one principal agent cashier.
  5. A principal agent cashier at one field location cannot be an alternate at another field location.
  6. VA Administrations and Staff Offices shall comply with VA Handbook 0730/1, Security and Law Enforcement, Appendix B (see VA Handbook Safe Specs in Authorities and References).
  7. VA Administrations and Staff Offices will adhere to General Services Administration (GSA) Class 5 safe or equivalent security standard used for the agent cashier function which is assigned to the principal agent cashier and alternate agent cashier. For VA Administrations that have a cashless agent cashier function, the same standards are not required, and a reasonable lockbox will suffice.
  8. VA will not accept, under any circumstance, funds received that are not part of VA’s official business.
  9. VA will always have a safe, vault, or cash drawer locked when not in use.
  10. The facility will place the combination to a safe/vault and duplicate keys to cash boxes in sealed envelopes that are signed, dated and secured in the director’s safe. The sealed envelope will contain the following:
    • A copy of the combination to the safe or vault;
    • A key or access code to the agent cashier’s office; and
    • A second key to each of the cash boxes.
  11. Keys to the agent cashier’s office will only be kept in the Facility Director’s safe.
  12. Facilities will transfer responsibility and accountability, from the principal agent cashier, to the alternate agent cashier at least annually. The transfer will be for a period of two consecutive weeks.
  13. If both the principal agent cashier and alternate agent cashier are expected to be absent for a prolonged period of time (e.g., over 2 weeks) a replacement must be designated, and VA Form 0901 will be completed to name a newly appointed designee over the fund.
  14. The local finance officer or designee will perform a monthly reconciliation of the agent cashier account.
  15. Facility Directors, or their designees, will ensure that, unannounced audits of the agent cashier’s advance and undeposited collections are conducted, on at least a quarterly basis. The audit frequency may be reduced for cashless agent cashiers to semi-annually. However, additional audits may be conducted when it is necessary.
  16. Unannounced audits must be conducted by two or more individuals, one of which cannot be an employee of the finance office. This individual must have a fiscal or audit skillset and cannot be part of the agent cashier operations.
  17. Unannounced audits shall have an element of surprise; therefore, care will be taken to prevent a pattern of regularity when conducting the audits.
  18. Irregularities discovered during the audit shall be addressed promptly by officials responsible for overseeing the agent cashier. Facility Directors will modify the level of cash advances as a result of any irregularities found. Refer to Appendix D: Unannounced Audits, for additional details for Unannounced Audits or Spot Checks.

0306  Authorities and References

0307  Rescissions

VA Volume VIII Chapter 3, Agent CashierAccountability Policy, June 14, 2023.

0308 Policy Approval

This policy was approved by the VA Chief Financial Officers on November 16, 2023.

Appendix A: Adjusting Agent Cashier Fund Advances

  1. Increasing Cash Advances  
    1. Field facilities submit VA Form 0901 to FSC requesting an increase in the facility’s cash advance. VA Form 0901 must be signed by the current Facility Director and be accompanied by an approved Fiscal Service form 2958, Delegation of Authority.
    2. FSC issues an EFT payment to the field office agent cashier if they approve the request for an increase in the advance. During emergency/disaster situations, FSC will expedite requests.
    3. The local finance office must adjust its accountability balance to reflect the increase by preparing and processing a Journal Voucher (JV) and entering it into VA’s accounting system. For additional information on JVs, refer to Volume II, Chapter 1A, VA Journal Vouchers.
    4. The facility’s finance office must send copies of the documents used to increase the advance via email to FSC Agent Cashier Accountability at VAFSCAgentA@va.gov.
  2. Decreasing Cash Advances  
    1. Field facilities submit VA Form 0901, to FSC requesting a decrease in the facility’s cash advance. VA Form 0901 must be signed by the current Facility Director.
    2. An SF 215 will be prepared with “Partial Return of Advance of Funds” as the purpose.
    3. VA Form 0901, and a copy of the SF 215, are forwarded to the facility’s finance office. A deposit is prepared, processed, and then entered into VA’s accounting system in the facility’s suspense account.
    4. The local finance office processes a JV to reduce the amount in the facility’s suspense account and increase the FSC’s suspense account in VA’s accounting system.
    5. The facility’s finance office must send via email to FSC Agent Cashier Accountability (at VAFSCAgentA@va.gov) copies of the documents used to reduce the advance (e.g., VA Form 0901, SF 215, a copy of the check/money order issued to decrease the original advance, and a copy of the journal voucher).

Appendix B: Replenishing and Maintaining Agent Cashier’s Fund

  1. The agent cashier will follow the steps below to replenish the agent cashier fund:
    1. The agent cashier will verify the facility’s cash advance and undeposited collections before submitting a replenishment voucher.
    2. When it becomes necessary to replenish the agent cashier’s fund, the agent cashier will prepare a list of all agent cashier vouchers and an OF 1129. If OF 1129 is not prepared and processed through FSC portal, the form will be prepared in duplicate.
    3. The agent cashier will replenish funds each business day if necessary.
    4. The OF 1129 will be signed in the space provided by the agent cashier.
    5. The Status of Fund section must always be completed.
    6. The agent cashier will forward the original OF 1129, along with the attached list of vouchers, to the Voucher Audit section for audit. Upon completion of the audit, the voucher will then be forwarded to a Certifying Officer.
    7. After review and certification, the documents must be forwarded to the Finance Office for necessary action. The agent cashier will retain one copy of the OF 1129 pending receipt of replenishment for recordkeeping purposes.

Appendix C: Deposit Procedures

  1. Deposit Preparation
    1. Deposits of collections will be made on the SF 215. Refer to Treasury Financial Manual (TFM), Volume 1, Part 5, Chapter 3000, for guidance on how to prepare and use the SF 215. Form SF 215 is located online at https://www.fiscal.treasury.gov/otcnet/resources.html and Treasury Reconciliation Section (TRS) can assist with the submission.
    2. SF 215 numbers will be system generated through the current application in OTCnet.
    3. Deposits made through an FRB will be accomplished through OTCnet check scanning.
      1. Deposit Preparation (Agent Cashiers)
        1. Deposit Preparer – Will prepare deposits in OTCnet Deposit Processing.
        2. Check Capture Operator/Lead Operator – Will prepare deposits in OTCnet Check Capture.
        3. Both Deposit Preparers and Check Capture Operators/Lead Operators must have VA Form 0901 on file with FSC ACA.
        4. Both Deposit Preparer and Check Capture Operator/Lead Operators will be assigned by FSC.
      2. Deposit Approval
        1. Deposit Approver – Will review hard copy documentation against OTCnet Deposit Processing deposit information and approve for submission to the Financial Institution.
        2. Check Capture Supervisor – Will review hard copy documentation to OTCnet Check Capture deposit information and approve for submission to FRB Cleveland.
      3. Accounting
        1. Local Accounting Specialist – Will map accounting codes to individual endpoints, maintain banking info in OTCnet deposit processing, and enter/update facility mailing address for deposit adjustments. Current year accounting codes will be added each October.
        2. Check Capture Administrator – Will configure OTCnet Check Capture functions, download firmware, and map accounting codes to individual endpoints. Current year accounting codes will be added each October.
    4. Principal agent cashiers use the processing schedule to allow deposits to reach the depositary before its cutoff time for posting.
    5. All comments will be entered directly in OTCnet.
    6. The agent cashier will deposit any “cashed” accommodation exchange instruments with the local depository or FRB, as appropriate, on an SF 215.
    7. All information will be retained electronically in OTCnet for the required retention period.
    8. Corrections or adjustments to deposits made in OTCnet will be submitted via an Adjustment, Correction, or Reversal Request.
    9. Deposit tickets for foreign currency and checks drawn on foreign banks payable in foreign currency will be completed in accordance with OTCnet procedures per the OTC website.
    10. Before making a deposit, the agent cashier must verify foreign deposit address with TRS by emailing vafsctreasuryr@va.gov and calling the Bank of America Foreign Trading Desk at 1-800-387-1012.
    11. Foreign currencies, other than Philippine pesos, must first be converted to the U.S. Equivalent (USE). For more information contact the Bank of America Foreign Trading Desk at 1-800-387-1012. The Treasury assigned five-digit client number, 37539, will be required as well as the Agency Locator Code (ALC). Bank of America provides self-sealing shipping bags and arranges for pickup by Brinks for currency deposits over $5,000 USE. The deposits are packaged securely with the deposit ticket(s) following the instructions in the TFM and addressed to:

      Bank of America
      2706 Media Center Drive
      Los Ángeles, CA 90065-1733

      Currency deposits of $5,000 USE or less will be accompanied by the deposit ticket(s) and be mailed following the instructions in the TFM to:

      Bank of America
      2706 Media Center Drive
      Los Ángeles, CA 90065-1733
  2. Depositors shall keep records of deposited cash and checks.
    1. Records related to deposited checks must include the following:
      • A cross-reference to the applicable SF 215;
      • Amount;
      • Name of the payor;
      • Name of the person from whom it was received (if other than the drawer);
      • Bank on which drawn;
      • Date drawn;
      • Check number (if cashier’s check or similar item);
      • Checking account symbol and serial number (if drawn on Treasury);
      • Serial number (if postal money order); and
      • Routing number.
  3. If a check or checks have been lost in transit, VA will identify each payer and request a replacement check for the lost item(s). VA shall keep copies of checks being deposited for reference.

Appendix D: Unannounced Audits

  1. Facilities will designate personnel to an auditor role in FSC ACA portal. The designated personnel will verify the facility’s advance, current turnover rate of the advance, current agent cashier designations, and the respective VA Form 0901. If the facility does not have access to FSC ACA portal, then an email should be sent to FSC Agent Cashier Accountability inbox, VAFSCAgentA@va.gov, requesting access.
  2. If the agent cashier has advanced funds to others, the audit shall include the accounts of these authorized employees.
  3. When performing the audit, all activities in the agent cashier’s cage shall be temporarily suspended. Auditors will take over all cash, vouchers, and receipts to establish a cutoff and these items shall be considered as applicable to the period being audited. In verifying the agent cashier’s advance, all replenishment received but not deposited will be considered part of the balance.
  4. The auditors will record all items under review on a worksheet and retain control over all items secured during verification of the cash.
  5. The audit includes a reconciliation between cash received in the mail and recorded in the registry log, and cash receipts issued by the cashier since the last audit.
  6. In recording the cash count on the worksheet, separate totals shall be developed for disbursement of cash and collection of cash as follows:
    1. When auditing disbursing cash, the auditor will make separate entries for all accountable items on hand. Memorandum receipts for cash advanced to employees, if any, will be examined for validity and recorded separately from memorandum receipts for advances to alternate agent cashiers, other disbursing officials, and any other authorized VA employee(s). These items shall be examined, and the advance will be verified by physical count. All accountable items in possession of any authorized employee(s) will also clearly be identified on the worksheets.
    2. Entries for receipted cash collections will consist of the amount and associated receipt numbers by type of receipt.
    3. Auditors shall ensure all collections (other than those awaiting disposition instructions and those destined for CARS and Hines) have proper receipts and are deposited as part of that day’s business. Collections that cannot be deposited the same day shall be listed and entered on a worksheet in sufficient detail to identify each collection. The worksheet will be retained as part of the supporting documentation of the audit performed and as a reference for future audits if required.
    4. Mail in original unopened envelopes that contain collections shall be omitted from the audit of collections.
    5. The last agent cashier voucher number verified in the cash account will be listed on the worksheets as well as the numbers of the last receipts issued by each person.
    6. In-transit items will be completely verified by reviewing the in-transit vouchers submitted and the applicable deposit tickets. When in-transit items become outstanding for longer than the normal time required to obtain replenishment, the auditors will contact the finance office, which shall verify the validity of in-transit items by comparing EFT replenishment deposits received by the agent cashier against the in-transit items.
    7. The worksheet will be dated and signed by the auditors and filed by the agent cashier. Before the start of the next audit, the auditors will obtain the previous worksheet and verify the collections were properly processed.
  7. If a shortage is detected, FSC will receive a signed copy of the unannounced audit report, annotate to show the shortage was acknowledged by the agent cashier, with recoupment made by the replenishing cashier.
  8. After the cash has been counted and numbers of the last receipts issued for each person in the Section verified, receipts and sufficient cash shall be released to carry on disbursing and collection activities.
  9. All unused field service receipts and counter receipts will be verified to ensure continuity of numbers. The last number for each type of receipt received by the finance office shall be determined and the auditors will verify continuity of receipt numbers between those received by the finance office and those unused still on hand.
  10. Irregularities involving receipts will be shown in the audit report and investigated by the finance office.
  11. During the unannounced audit, the last 3 consecutive months of cash disbursements shall be reviewed and analyzed to determine if the level of the cashier advance is adequate. The agent cashier’s advance account shall be limited to the minimum cash required to meet the needs of the Veteran population serviced by the facility.
    1. Monthly cash disbursements shall be determined by reviewing the OF 1129, and replenishment of accommodation exchange items.
    2. Facility Directors shall modify the level of cash advances available for agent cashiers based on the auditor’s calculation, as determined by methods described below.
      1. A facilities initial advance and 6 months of replenishment data. The cashier’s advance is based on a 3-week need, and the monthly usage target is 130 percent. The following are examples.
        1. An increase condition: See Figure D-1
        2. A decrease condition: See Figure D-2
  12. The unannounced audit report will contain audit findings and recommendations. A copy of the report will be routed to the Facility Director.

Figure D-1

Facility Usage
Adv.20,000
Nov49,043
Dec46,872
Jan41,264
Feb42,382
Mar50,522
Apr37,427
Total267,510
Avg44,585
Facility Usage223%

6-month average $44,585 ÷ 1. 3 (130 percent) = $34,296. Current advance of $20,000 is $14,296 less than adjusted average usage; the increasable amount is rounded to $14,300. The adjusted factor will be 131%.

Figure D-2

Facility Usage
Adv.55,000
Nov52,312
Dec54,144
Jan46,973
Feb52,704
Mar56,882
Apr53,020
Total316,035
Avg52,673
Facility Usage96%

6-month average $52,673 ÷ 1. 3 (130 percent) = $40,518. The current advance of $55,000 is greater than the adjusted average usage; the decrease amount is rounded to $14,500. The adjusted factor will be 130%. (Subject to approval, waivers (for advances $5,000 and below) from financial indicators will be granted to facilities.)

Rating factors are 130 percent or more (green); 129-0 percent (red).

Agent cashiers shall take the appropriate action to increase or reduce their advance when the above example indicates funds are insufficient or excessive.

Appendix E: Authority to Compromise/Waive Agent Cashier Debts

  1. 38 C.F.R. § 2.6(d) delegates SECVA authority to take appropriate action to collect civil claims owed to VA in accordance with the Federal Claims Collection Standards (FCCS)(38 C.F.R. § 1.900 et seq.) to the Assistant Secretary for Management (ASM/CFO). That authority is further delegated in VA regulation and policy. The Government Accountability Office (GAO) asserts that 31 U.S.C. § 3527 provides it with the sole authority to relieve accountable officers, to include agent cashiers, from liability. However, in a 2015 opinion, OGC analyzed a 1991 DOJ Office of Legal Counsel opinion that deemed the practice of the Government Accountability Office (GAO)/Comptroller General “relieving disbursing officials in the executive branch from liability under 31 U.S.C. § 3527 to be unconstitutional.” VAOPGCADV 5-2015.
  2. In response, OGC recommended modifying VA policy to reflect the DOJ opinion, to handle agent cashier debts without GAO involvement and to resolve agent cashier debts “in accordance with the provisions of the Federal Claims Collection Act at 31 U.S.C. § 3711 ….”. In accordance with the Federal Claims Collection Standards, if an Agent Cashier is found to be liable for a fund shortage, then a debt should be created. That debt would be a civil claim owed to VA and handled in accordance with Volume XII, Chapter 3, Employee Debt. Any compromise/waiver decision would be made through the employee debt process.

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