0101 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policies regarding the review and certification of invoices and payments. VA processes several different types of invoices and requests for payment (e.g., vendor, Veteran benefit, employee travel, salary payments, and other miscellaneous payments, etc.) and all are considered as “Invoices” for this policy.

Key points covered in this chapter:

• VA will adhere to the requirements of the Prompt Payment Act (PPA) (e.g., establish payment due dates, calculate applicable discounts or interest due);
• VA will review invoices as soon as practicable after receipt to determine whether the invoice is proper and return any improper invoices to the vendor timely;
• Certifying Officials are responsible for the verification and accuracy of facts stated on an invoice, payments, supporting documents, and records;
• Certifying Officers and Certifying Officials may be monetarily liable for any payments resulting from illegal, improper, or incorrect certifications; and
• VA may use alternative payment methods under specific conditions for payment processes that would create efficiencies in making payments and produce measurable savings with limited risks.

0102 Revisions

Section	Revision	Office	Reason for Change	Effective Date
0104	Clarified requirement for Certifying Officers, Certifying Officials, and Disbursing Officers to be Federal Government employees	OFP (047G)	For clarification	June 2023
010501	Clarified requirement for Certifying Officers, Certifying Officials, and Disbursing Officers to be Federal Government employees	OFP (047G)	For clarification	June 2023
010503	Added language to clarify inherently governmental functions	OFP (047G)	For clarification	June 2023

0103 Definitions

Certification – The act of verifying the accuracy and legality of an invoice and supporting records.

Fast Pay – A payment procedure under the Federal Acquisition Regulation Part 13.4, which allows payment under limited conditions to a vendor prior to the Government’s verification that supplies have been received and accepted.

Improper Payments – A payment that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements. The term improper payment includes; any payment to an ineligible recipient; any payment made for an ineligible good or service; any duplicate payment; any payments for a good and service not received, except for those payments authorized by law; and any payment that does not account for credit for applicable discounts. Improper payments include monetary and non-monetary loss improper payments.

Invoice – A written or electronically transmitted document requesting payment. A proper invoice meets the requirements of the Prompt Payment Act under 5 C.F.R. Part 1315. The term “invoice” also includes:

• Receiving reports and delivery tickets when contractually designated as invoices;
• Non-vendor payment requests (e.g., Veterans benefits, employee travel, salary, etc.)

Invoice Review – An examination of documentation prior to payment of an invoice.

Payment Review – Examination of a payment transaction after its occurrence. A post-payment review determines if VA’s policies and procedures have been properly followed.

Secure Payment System (SPS) – A Treasury system used by Federal Government agencies to schedule and certify payments securely.

Statistical Sampling – The selection of a subset of transactions from within a population that will be evaluated in order to estimate characteristics of the whole population.

0104 Roles and Responsibilities

Under Secretaries, Assistant Secretaries, Chief Financial Officers (Administration CFOs, other office CFOs), Finance Officers, Chiefs of Finance Activities, Fiscal Officials, Chief Accountants and Other Key Officials are responsible for ensuring compliance with the policies set forth in this chapter.

Approving (Authorizing) Officials are responsible for designating and managing the certifying officers.

Certifying Officers are Federal Government employees, authorized by 31 U.S.C. §§ 3321 and 3325, responsible for approving schedules of payments transmitted to Treasury for disbursements and are responsible only for errors made in the processing of the voucher schedule, such as the number of individual vouchers and total dollar amount of vouchers submitted to Treasury for payment.

Certifying Officials are Federal Government employees, authorized by 31 U.S.C. §§ 3321 and 3325, responsible for certifying each individual invoice for payment and for ensuring that the invoice is correct, accurate and in accordance with the related obligation document. Typically, a Contracting Officer Representative (COR) or their technical representative performs this function for invoices related to a contract.

Disbursing Officers are Federal Government employees authorized by 31 U.S.C. §§ 3321 and 3325 to perform financial transactions (deposit collections, disburse checks, and transfer funds between agencies). There are different types of disbursing officers, specifically there are Treasury Disbursing Officers (TDO), non-Treasury Disbursing Officers (NTDO) and NTDOs located overseas, also referred to as United States Disbursing Officers (USDOs).

0105 Policies

010501 General Policies

1. VA will process payments in accordance with 5 C.F.R. Part 1315 and the Prompt Payment Act (PPA).
2. VA will stamp or notate invoices with the date received (e.g., mark either manually or electronically with the date the invoice was received by VA).
3. VA’s financial and other related automated systems were designed to eliminate the majority of the manual processes historically associated with payment processing. Appendix B, Relevant Financial Systems, contains a list of the various systems used to process payments at VA.
4. VA will designate only Federal Government employees as Certifying Officers, Certifying Officials, and Disbursing Officers in accordance with 31 U.S.C. §§ 3321 and 3325.

010502 Initial Invoice Review

1. Vendors are required to submit invoices directly to the office identified in the terms and conditions of the obligating document.
2. VA will review invoices as soon as practicable after receipt to determine whether the invoice is proper. Per 5 C.F.R. Part 1315.9, a proper invoice under a non cost-reimbursement service contract contains:
   • Name of vendor;
   • Invoice date;
   • Government obligation number, or other authorization for delivery of goods or services;
   • Vendor invoice number, account number, and/or any other identifying number agreed to by contract;
   • Description (including, for example, contract line/subline number), price, and quantity of goods and services rendered;
   • Shipping and payment terms (unless mutually agreed that this information is only required in the contract);
   • Taxpayer Identifying Number (TIN), unless agency procedures provide otherwise;
   • Banking information, unless agency procedures provide otherwise, or except in situations where the EFT requirement is waived under 31 CFR 208.4;
   • Contact name (where practicable), title and telephone number; and
   • Other substantiating documentation or information required by the obligating document.
3. Per 5 C.F.R. Part 1315.9, a proper invoice under a cost-reimbursement service contract includes all the information required by the contract or VA.
4. In accordance with 5 CFR § 1315.4, VA will return incorrect or improper invoices (i.e., invoices not in accordance with the terms of the obligating document) to the vendor within:
   • 7 calendar days from receipt of invoice for general services or goods;
   • 3 days from receipt of invoice for meat products or fish; or
   • 5 days from receipt of invoice for perishable goods, perishable agricultural commodities, edible fats or oils, and food products prepared from edible fats or oils.
5. It is the responsibility of the designated agency office (when different from the payment office) to initially review invoices and ensure that invoices are routed and submitted to the designated payment office (e.g., Financial Services Center (FSC), VBA Regional Office).

010503  Invoice Certification

1. Certifying Officials are responsible for the verification and accuracy of facts stated on an invoice, payments, supporting documents, and records.
2. Certifying Official will review invoices to ensure that:
   • Goods have been received or services have been performed in accordance with the obligating (e.g., contract, purchase order, or agreement) document;
   • Prices, subtotals, and totals are accurate;
   • The invoice includes the obligation number;
   • The invoice aligns with the terms of the contract, purchase order or agreement;
   • The payee, vendor, and vendor code (as applicable) are correct and that a Tax Identification Number or Payee Identification Number is provided for each payee;
   • The invoice is not a duplicate or has not been paid previously; and
   • All applicable deductions were taken and credited to the proper account in the correct amount.
3. VA relies upon a system of automated and manual controls to ensure that payments are proper before disbursement. A key control of the process is the review and approval of all payments by certifying officials. Certifying Officers rely upon reviews by Certifying Officials to ensure the accuracy and validity of payments.
4. Certifying Officials will be knowledgeable of the subject matter, appropriations, accounting classifications, payment processes and the location of designated paying and accounting offices.
5. Before certifying the invoice, Certifying Officials must obtain a certification of receipt and acceptance from a federal employee who actually inspected the supplies or services. Acceptance of goods and services on behalf of the government is an inherently governmental function and must be performed by a Federal Government employee (FAR 7.503).
6. By manually, electronically, or digitally signing an invoice, a Certifying Official certifies to a Certifying Officer that the items listed are correct and proper for payment from the appropriation(s) identified on the obligation document or on the invoice and that the proposed payment is legal, proper, and correct. Manual certifications on invoices, will include the Certifying Official’s signature, typed or printed name, the title “Authorized Certifying Official,” date signed, date of acceptance, and dollar amount.
7. In the event of successive certification, the successive Certifying Official’s actions do not diminish the responsibility of the official who certified the original invoice. If the official who certifies an additional related invoice is different than the one who certified the original, the initial Certifying Official is responsible for the correctness of the original invoice, and the successive Certifying Official is responsible only for the additional related invoice. If an invoice is certified and subsequently changed (e.g., to take a discount, add interest penalties), the Certifying Official certifying the legality, propriety, and correctness of the changes is monetarily liable for only the payments based on those changes.
8. The invoice certification process may be different depending on the system being used to process the payment (e.g., VA’s accounting system, Invoice Payment Processing System (IPPS), etc.).

010504 Documentation Requirements

1. VA will ensure documentation of the invoice review, certification and payment process is maintained for audit purposes. Documentation should include items such as the:
   • Obligating document;
   • Receiving document;
   • Invoice;
   • Relevant approvals and dates; and
   • Verification of Accounting Codes.
2. Certified invoices and related documentation, information, data, or services used to support them will be kept for six (6) years or in accordance with the National Archives and Records Administration (NARA) guidance.

010505  Internal Controls

1. In accordance with Government Accountability Office (GAO), Standards for Internal Control in the Federal Government, Administrations and Staff Offices will ensure key duties and responsibilities are divided or segregated among different individuals to reduce the risk of error, misuse or fraud.
   
   This includes separating the responsibilities for authorizing, processing, recording and reviewing transactions, and handling any related assets so that no one individual will control all key aspects of a transaction or event.
   
   
2. VA facilities, stations, and finance offices will ensure that Certifying Officers and Certifying Officials reviewing and approving commercial invoices and payments are not responsible for other financial and accounting functions that conflict with their duties.

010506 Invoice and Payment Quality Assurance Reviews

1. In accordance with 31 U.S.C 3521(b), VA is authorized to establish statistical sampling programs within limitations prescribed by Comptroller General, for the examination of vouchers in support of their certification and payment. The Comptroller General has established a general limitation of $2,500 on vouchers that may be examined by sampling programs. VA will perform invoice, pre-payment, and post-payment reviews using statistical sampling methods to ensure the accuracy and validity of payment transactions. Refer to GAO Policy and Procedures Manual Title 7 – Fiscal Guidance for information on audit sampling methods for invoice and payment quality assurance reviews.
2. The type and depth of a quality assurance review conducted by VA personnel depends largely on the extent of automation of the system that computes and processes payments. Fully automated financial systems that perform reviews of all records through extensive edit checks and balances before payment can essentially replace manual invoice reviews. They may also negate the need to perform pre-payment audit reviews for population-trend identification. In such cases, post-payment audit sampling of invoice payments replaces the pre-payment reviews for validating the accuracy of the automated system calculations and ensuring that edit checks and balances are operating properly.

010507 Payment

1. VA will certify payments made from appropriated funds to individuals and commercial activities.
2. Contract payments will be made in accordance with the terms and conditions stated in the contract.
3. unless a longer payment period is called for in the contract. Office of Construction and Facilities Management (CFM) contracting officers are required to determine the adequacy of contract payment requests.
4. VA shall pay an interest penalty to the vendor/service provider for payments not made by the required due date.
   1. VA payments subject to PPA. Examples include:
      1. Payments to state, local governments, and vendors for goods and services authorized by a contract;
      2. Loan guaranty invoices for expenses associated with foreclosure, management, repair, sale of the acquired properties, and certain expenses associated with specially adapted housing grants;
      3. Travel reimbursement to VA employees for official Government travel;
      4. Payments to community nursing homes and contract hospitalization;
      5. Payments to healthcare entities or providers for care or services furnished in the community pursuant to a contract, agreement or other arrangement including:
         • Community Care Network (CCN); and
         • Veterans Care Agreements.
      6. Utility payments for which state, local, or foreign authorities do not impose late payment fees; and
      7. Progress payments on construction and architectural contracts; and
      8. Payments for meat, meat food products, fish, fresh eggs, dairy products, and other perishable agricultural commodities.
   2. VA payments exempt from PPA. Examples include:
      1. Payments to other Federal entities;
      2. Payments to beneficiaries, survivors, including travel reimbursements;
      3. Payments to individuals for personal services not covered by a contract;
      4. Advance payments, contract financing, progress payments (other than construction and architectural contracts);
      5. Utility payments for which state, local, or foreign authorities impose late payment fees;
      6. Payments of loan guaranty claims and property acquisitions; and
      7. Payments for community care not covered in a contract, agreement or other arrangement including:
         • Civilian Health and Medical Programs of the Department of Veterans Affairs (CHAMPVA) claims for reimbursement;
         • Spina Bifida Health Care Benefits Program (SBHCBP) claims for reimbursement;
         • Camp Lejeune Family Member Program claims for reimbursements;
         • Children of Women Vietnam Veterans (CWVV) Health Care Benefits Program claims for reimbursement;
         • Foreign Medical Program (FMP) claims for reimbursement;
         • Unauthorized emergency care for non-service connected Veterans at community facilities;
         • Unauthorized emergency care for service connected Veterans at community facilities; and
         • Pharmacy claims at non-network pharmacies.

010508 Accelerated Payment Processes

1. VA may use accelerated payment methods to pay invoices for the following types of payments in accordance with 5 C.F.R. § 1315.5:
   1. Payments may be made on a single invoice under $2,500 as soon as the contract, proper invoice, receipt and acceptance documents are matched except where statutory authority prescribes otherwise and except where otherwise contractually stipulated (e.g., governmentwide commercial purchase card). Vendors shall be entitled to interest penalties if invoice payments are made after the payment due date.
   2. Payments may be made to a small business when all proper documentation, including acceptance, is received in the payment office and before the payment due date. Such payments are not subject to payment restrictions stated elsewhere in 5 C.F.R. § 1315.5.
   3. Payments may be made for emergencies and disasters (as defined in the Robert T. Stafford Disaster Relief Act and Emergency Assistance, Pub. L. 93-288, as amended (42 U.S.C. § 5 121 et seq.); release or threatened release of hazardous substances (as defined in the Comprehensive Environmental Response Compensation and Liability Act of 1980, Pub. L. 96-510, 42 U.S.C. § 9606); and under a military contingency (as defined in 10 U.S.C. § 101(a)(13)) as soon as the contract, proper invoice, receipt and acceptance documents or any other agreement are matched. Vendors shall be entitled to interest penalties if invoice payments are made after the payment due date.
   4. Payments may be made for interim payments under cost-reimbursement service contracts earlier than seven days prior to the payment due date in accordance with agency regulations or policies.
2. VA may use alternative payment methods under specific conditions for payment processes identified below that would create efficiencies in making payments and produce measurable savings with limited risks in accordance with GAO Policy and Procedures Manual Title 7 – Fiscal Guidance, Chapter 7, Section 7.4D through F.
   1. VA may use “Fast Pay” procedures to pay vendor invoices prior to verifying that supplies have been received and accepted. Refer to FAR Subpart 13.4 and 5 C.F.R. § 1315.6 for additional details and specific conditions of the fast payment process.
   2. VA may use statistical sampling for vouchers on amounts not to exceed $2,500 in accordance with 31 U.S.C. § 3521(b). Within this maximum, VA is required to establish dollar limitations based on cost/benefit analyses of voucher examining operations. Any disbursing or certifying official relying in good faith on the statistical sampling procedure adopted by the agency to disburse funds or certify a voucher for payment will not be liable for losses to the government resulting from payment or certification of a voucher not audited specifically because of the use of the sampling procedure, provided that the agency has diligently carried out collection actions prescribed by the Comptroller General (31 U.S.C. § 3521(c)).
      
      In order to utilize a statistical sampling alternative payment method, VA must develop and implement a statistical sampling plan which includes at a minimum the following steps:
      1. Define the universe of vouchers to be examined by statistical sampling;
      2. Determine the size of the sample needed and how the sample items will be selected;
      3. Analyze the results of the sample using the appropriate statistical procedure and determine if any changes are needed to the sampling plan or whether to examine the entire universe; and
      4. Present the results to management with appropriate interpretation.
      5. Maintain records of all aspects of its sampling plan(s), including such elements as the specific sampling procedures, the statistical formulas or tables used, and the resulting calculations. Further, records of actual application of the plan, such as:
         • work sheets showing items selected for examination;
         • errors discovered;
         • total number and amount of vouchers in the universe;
         • projected error, including possible range of error in the universe;
         • whether the results were acceptable; and
         • other pertinent data, should be retained in order to document the implementation of the plan and any subsequent changes made based on the sample results.
   3. VA may utilize voucher examining plans that combine elements of fast pay and statistical sampling in appropriate circumstances. Such plans must provide for:
      1. audit emphasis commensurate with the risk to the government;
      2. sampling of all invoices not subject to complete audit coverage;
      3. effective monitoring; and
      4. a basis for the certification of payments (67 Comp. Gen. 194 (1987) and 68 Comp. Gen. 618 (1989)).

010509 Certifying Payment Schedules in Treasury’s Secure Payment System

1. After VA certifying officials review and certify an invoice for payment in IPPS, the information automatically interfaces into VA’s accounting system. VA’s accounting system establishes payment schedules based on the payment type and invoice due date.
2. VA’s accounting system will automatically send the payment schedule to Treasury’s Secure Payment System (SPS) based on payment due date.
3. FSC Certifying Officers will review and certify the payment schedules in SPS. Treasury will not release payments to recipients until they are certified in SPS. The payment schedule certification is a summary level effort confirming payment schedule counts and amounts by Treasury Accounting Symbols (TAS). FSC Certifying Officers will not be pecuniarily liable for inaccuracies of individual invoices and will only be responsible for the accuracy of the payment schedule. Refer to GAO Comptroller decision B-302789, Coast Guard – Electronic Certification Procedures.

010510 Monetary Liability

1. VA’s Certifying Officers and Certifying Officials may be monetarily liable for any payments resulting from illegal, improper, or incorrect certifications under 31 U.S.C. § 3528, and other applicable laws.
2. When a Certifying Officer or Certifying Official is found to be monetarily liable, a debt will be established. Refer to VA Financial Policy Volume VIII, Chapter 1, Certifying and Disbursing Officials/Officers for additional information.
3. In accordance with a 1991 DOJ opinion, as well as the 2015 VA OGC opinion, seeking relief from Comptroller General as required in 31 U.S.C. § 3528 is unconstitutional. Therefore, when an improper or incorrect payment is certified by a Certifying Officer or Certifying Official, a request for waiver of the related debt can be submitted by following the steps outlined in VA’s Financial Policy Volume XII, Chapter 3, Employee Debt. For additional details, refer to Appendix A and Appendix B in Volume XII, Chapter 3, Employee Debt.

0106 Authorities and References

• United States Code (U.S.C.)
  • 31 U.S.C. § 3321, Disbursing Authority in the Executive Branch
  • 31 U.S.C. § 3325, Vouchers
  • 31 U.S.C. § 3521, Audits by Agencies
  • 31 U.S.C. § 3528, Responsibilities and Relief from Liability of Certifying Officials
  • 31 U.S.C. §§ 3901–3907, Prompt Payment
• Code of Federal Regulations (C.F.R.)
  • 5 C.F.R. Part 1315, Prompt Payment Act
  • 38 C.F.R. Subparts 17.52-17.56, Use of Public or Private Hospitals
  • 48 C.F.R. Subpart 13.4, Fast Payment Procedure
  • 48 C.F.R. Part 32.9, Prompt Payment
• Comptroller General B-302789, Coast Guard–Electronic Certification Procedures, July 6, 2005
• Department of Justice’s Office of Legal Counsel Opinion (OLC) on the Authority of the Comptroller General to Relieve Certifying Officers from Liability
• Federal Acquisition Regulation (FAR) Website
• Government Accountability Office (GAO)
  • GAO, Policy and Procedures Manual for Guidance of Federal Agencies: Title 7 – Fiscal Guidance
  • GAO, Streamlining the Payment Process While Maintaining Effective Internal Control
  • GAO, Standards for Internal Control in the Federal Government
• OMB memorandum, Determination With Respect to Transfer of Functions Pursuant to Public Law 104-53, dated June 28, 1996 and December 17, 1996
• Public Law 111-204, Improper Payments Elimination and Recovery Act of 2010, July 22, 2010
• Treasury’s Bureau of Fiscal Service Certifying Officer Training
• VA Financial Policy
  • Volume II Appropriations, Funds and Related Information
  • Volume VIII, Cash Management
  • Volume VIII, Chapter 1, Appendix B (2015 VA OGC Opinion)

0107 Rescissions

VA Financial Policy Volume VIII, Chapter 1A – Invoice Review and Certification dated May 2023.

0108 Policy Approval

This policy was approved by the VA Chief Financial Officers’ Council on June 14, 2023.

Appendix A: Revision History

See changelog.

Appendix B: Relevant Financial Systems

A. The following table outlines VA financial systems used in invoice review, invoice certification, and issuing payment.

System	Administration or Staff Office	Description
Benefits Delivery Network (BDN)	VBA	Used for accounting and payment of certain educational, compensation, and pension benefits.
Centralized Administrative Accounting Transaction System (CAATS)	VBA and NCA	Used by VBA for invoicing, accounting, and issuing payment. Used by NCA for administrative-accounting functions.
“Corporate” and the five BETA test stations: Waco, Indianapolis, Newark, Roanoke, and Seattle (CWINRS)	VBA (Vocational Rehabilitation and Employment Division)	An automated case management system is used to track and manage caseloads and program costs.
e-Gov Travel System	All	Used for travel authorizations and expense reports (payments).
VA’s accounting system	All	Used for goods and services and some benefit payments.
Insurance General Ledger System (IGLS)	VBA	Used by VBA for accounting and payment of insurance claims.
Integrated Funds Distribution, Control Point Activity, Accounting, and Procurement (IFCAP)	VACO, VHA, and other select offices	Part of the Veterans Health Information Systems and Technology Architecture (VISTA) system used for accounting, budget, purchase card, or procurement.
Loan Guarantee Programs:   VA Loan Electronic Reporting Interface (VALERI)	VBA	Used to monitor servicing loans, generate loss mitigation recommendations, review adequacy of services, review non-routine claims and incentives, and conduct post audits. VALERI and VA’s accounting system interface to upload payment certification and bill of collection certification data to VA’s accounting system and download vendor file updates, payment status details, and cash receipts to VALERI.
Centralized Property Tracking System (CPTS)	All Staff Offices and Administrations, except VBA field offices	A web-based property tracking and oversight system. CPTS provides support for property contract or oversight activities and is used to review and process property contractor invoices for payment.
Invoice Payment Processing System (IPPS)	FSC (online certification system)	Used for invoice certification.
Station Inquiry System (SIS)	VBA	Used to search for vendor information, payment history, etc.
VETSNET FAS (Financial and Accounting Systems)	VBA	Used for accounting and payment of compensation, pension, and education claims, and recurring payments.
VISTA Fee Application Software	VHA	Used for authorization and payment of non-VA medical care claims.
Fee Basis Claims System (FBCS)		Used for a graphical user interface (GUI) with Vista Fee Application Software.

B. The following systems are operated by other agencies but used by VA to review, certify, and issue a payment.

System	Administration or Staff Office	Description
Department of Defense, Defense Finance and Accounting Service (DFAS)	Defense Civilian Pay System (DCPS)	Used in conjunction with VA HR and Payroll systems for employee salary and benefit payments.
Department of State (DOS)	DOS Financial System	Used in Manila for foreign payments. VA Manila office posts payments manually into VA’s accounting system to record transactions.
Department of Health and Human Services	Health and Human Services, Payment Management System (HHS/PMS)	Used for approval and issuance of grant payments.
U.S. Department of Agriculture (USDA) National Finance Center	USDA Payroll and Processing System	Used in conjunction with VA HR and Payroll systems for employee salary and benefit payments.