Volume III - Obligations

Chapter 02B – 1358 Obligations

Questions concerning this policy chapter should be directed to:

0201 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) policies for the proper use of VA Form 1358, Obligation or Change in Obligation.

0202 Policies

020201 VA Form 1358 (1358) is used strictly as an obligation control document and only for the approved uses listed in Appendix A. The 1358 will only be used while the Administration or Staff Office is using VA’s legacy accounting system, Financial Management System (FMS)¹. A 1358 will not be used for any other purpose and will only be used as an obligating document for FAR-based/Procurement transactions in limited circumstances when required by system or process limitations within VA. Obligations utilizing VA Form 1358 require the requesting service to maintain supporting documentation for each 1358 obligation in accordance with 31 U.S.C. § 1501, Documentary evidence requirement for Government obligations.

Appendix D, Obligation at Claims Approval Programs, contains specific requirements and guidelines for 1358 obligations utilizing the Obligation at Claims Approval methodology. These obligations are unique to the Veterans Health Administration (VHA) appropriations for hospital and medical services furnished at non-Departmental facilities.

020202 For the approved uses in Appendix A, the requesting agency/service will submit a completed 1358 along with the supporting documentation to the Chief of Finance Office or designee for review and to record the obligation in FMS at the time in which the obligation occurs.

Appendix B lists some examples of invalid uses of the 1358.
Appendix C lists the fields that are required to be completed on the 1358 for Appendix A approved uses, to include the vendor, contract number, period of performance, and purpose. This appendix also cross-references the approved uses in Appendix A to the drop-down list used in the Integrated Funds Control Point Activity, Accounting and Procurement (IFCAP) system and the manual 1358.²
Appendix E is a sample of a manual 1358 updated with the approved uses in a drop-down box.
Appendix F lists previous policy revisions to Volume III, Chapter 2B – 1358 Obligations.
Due to system constraints and costs for modifying IFCAP, IFCAP may not be updated to reflect modifications or clarifications to the approved uses listed in Appendices A, C or D.

020203 For Appendix A approved uses, only one obligation number will be assigned to the 1358 per contract or order throughout the fiscal year unless an exception (as noted in B below) is documented and approved by the finance office.

The same obligation number will be used on subsequent modifications to the original estimated 1358. The order or contract number will also be placed in the “Contract Number” section on the form. The requesting agency / service is responsible for determining whether an increase or decrease adjustment is necessary as new authorizations and/or entries are added or paid. Adjustments will be sent to the finance office for processing at least quarterly.
The exception to the single obligation number occurs when the maximum field or digits allowed by the accounting system is exceeded. For example, in the Financial Management System (FMS), Consolidated Mail Out Pharmacies (CMOP) frequently exceed the obligation dollar limits. A new 1358 will be established monthly or quarterly rather than adjusted on a monthly or quarterly basis.

020204 The use of “Miscellaneous Vendor” in the vendor field of the 1358 is not permitted. A temporary waiver to this requirement is being granted for the following approved uses:

#1 – Nursing Homes / Adult Day Health Care
#2 – Community Care, including Dental, Homemaker / Home Health Aid, and Community Hospitalization
#5 – Research Studies
#9 – Volunteer and Resident Meal Tickets, Volunteer Reimbursement, Honoraria, and Stipends
#10 – Incentive Therapy / Compensated Work Therapy
#11 – Beneficiary Travel and Direct Payments to Veterans from General Post Fund
#13 – National Cemetery Administration (NCA) Outer Burial Receptacle
#15 – Home Oxygen and Eyeglass Fabrication
#21 – Caregiver Support Program – Caregiver Stipend, Respite, and Oversight programs

This waiver is required due to FMS system limitations or processes within the Administrations and Staff Offices. The use of “Miscellaneous Vendor” on these types of purchases will not be permitted once the VA Administrations and Staff Offices are transitioned to the new accounting system, the Integrated Financial and Acquisitions Management System (iFAMS). As Administrations and Staff Offices move into iFAMS, VA Form 1358 will be eliminated. Volume III, Chapter 2A – Non-Contractual Obligations will be used for these processes in iFAMS.

020205 If the Chief of the Finance Office or designee determines that the 1358 is not coded correctly or does not fall under one of the specified approved uses, the document will be returned with justification to the requesting agency/service.

020206 To ensure appropriate segregation of duties, no one official may perform more than one of the following key functions of a transaction or event for approved uses contained in Appendix A.

020207 Only individuals with the authority to bind the government on behalf of VA may obligate funds. This authority must be exercised through the approved process for the specific action, (i.e. via approved Form 0242 for micro-purchases; warrants for actions requiring a contracting officer; order officer delegations if approved; or proper systems’ access forms for approved 1358 actions or non-contractual obligations).

A. Requesting the 1358 obligations.

Purchases of goods or services are to be initiated by a requestor who is authorized to request the purchase of goods or services. This person may also initiate increase or decrease adjustments.
When the requestor of the purchase of goods or services is also an authorized approver, the requestor will submit the request to the next higher level for authorization and approval.

B. Approving the 1358 obligation.

The approval of the necessity for goods or services will be made by a person who has been authorized for this responsibility.
When the approver has the role of the requestor of the purchase of goods or services, the request will be submitted to the next higher level for authorization and approval.

C. Recording the obligation of funds.

After approval and prior to the purchase of goods or services, the respective budget and/or finance office will be responsible for verifying that funds are available and authorized. The budget and/or finance office will also ensure the obligation is recorded in the financial system when properly supported in accordance with the requirements of this chapter, including sections 020202 through 020206. An obligation must be recorded in FMS at the time it is incurred.

D. Certifying the receipt of goods or services and approving payment.

Before payment is made for goods or services, an authorized individual will certify that the requested goods or services were received in the quality and quantity agreed upon and in accordance with the terms of an order or contract. Any discrepancies will be noted, researched, and corrected.
The approval for payment is completed by an authorized certifying official. In approving payment, the certifying official is asserting to the legality and propriety of the payment from the appropriation or fund cited and that goods or services were received in the quality and quantity appropriate for the payment being approved. The certifying official does not need to be the physical receiver of the goods or services. Rather, he or she may base their certification of the receipt of the goods or services on a review of official supporting documentation, such as a receiving report, sales receipt, packing slip, bill of lading or a bill of services rendered signed by an individual authorized to receive goods or services. The certifying official approves payments in various automated systems, such as the Veterans Health Information Systems and Technology Architecture (VistA) Fee System or the Invoice Payment Processing System (IPPS).³

E. Periodic Review of 1358 Obligations.

020207 Each Chief Financial Officer (CFO) within VA shall conduct an annual review as part of the normal audit and reconciliation process to ensure that 1358 obligations are used in compliance with this chapter and that segregation of duties is maintained. The review will be performed by an official (as designated by the CFO) in relation to the preparation and submission of end-of-year certification letters. Refer to VA Financial Policy Volume VII Chapter 2, Consolidated Financial Statements, for additional information.

020208 Each Administration and Staff Office CFO will review all 1358 obligations with no activity for over 90 days for validity and accuracy. If the obligation is not not valid and/or supportable, the CFO will make timely adjustments and/or deobligate the 1358 obligation. For all annual estimated 1358s, the service will validate the outstanding balance in July of each year, using year-to-date trends as well as historical data. The service will enter any adjustment for under or over funded obligations by July 31st.

0203 Authority and References

Public Law
- 116-117, Payment Integrity Act of 2019
- 116-260, Consolidated Appropriations Act, 2021, Title XVI, Section 1601, Recording of Obligations
United States Code (U.S.C.)
Code of Federal Regulations (C.F.R.)
Federal Acquisition Regulation (FAR)
Federal Travel Regulation (FTR) Part 301-12, Miscellaneous Expenses
GAO Redbook Volume II, Chapter 7, Obligation of Appropriations, Administrative Approval of Payment
GSA Fleet Customer Leasing Guide
OMB M-21-19, Memorandum for the Heads of Executive Departments and Agencies, Transmittal of Appendix C to OMB Circular A-123, Requirements for Payment Integrity Improvement
SF-1034, Public Voucher for Purchases and Services Other Than Personal
VA Acquisition Regulation (VAAR)
VA Financial Policy
- Volume I, Chapter 11 – Intragovernmental Transactions
- Volume II, Chapter 7B – Honoraria
- Volume III, Chapter 2 – Obligations
- Volume III, Chapter 2A – Non-Contractual Obligations
- Volume VII, Chapter 9 – Payment Integrity and Fraud Reduction
- Volume XIV, Chapter 4 – Miscellaneous Travel Expenses
- Volume XVI, Chapter 1A – Administrative Actions for the Government Purchase Card
- Volume XVI Chapter 1C – Government Convenience Checks
VA Under Secretary for Health Memorandum – Implementation of Section 902 of the PACT Act Buy-Out of Service Contracts
VHA Directive 1620, VA Center for Development & Civic Engagement Program

0204 Roles and Responsibilities

020401 The Assistant Secretary for Management / VA CFO oversees all financial management activities relating to the Department’s programs and operations, as required by the Chief Financial Officers Act of 1990 and 38 U.S.C. 309. Responsibilities include the direction, management and provision of policy guidance and oversight of VA’s financial management personnel, activities and operations. The CFO establishes financial policy, systems and operating procedures for all VA financial entities and provides guidance on all aspects of financial management.

020402 Under Secretaries, Assistant Secretaries, CFOs, Fiscal Officers, Chiefs of Finance Activities, Chief Accountants and other key officials are responsible for ensuring compliance with the policies set forth in this chapter.

020403 The Office of Financial Policy (OFP), within the VA Office of Finance, is responsible for the information contained in this chapter.

020404 The requesting office is responsible for the continuous monitoring and validation of 1358 obligations. Requesting offices are responsible for initiating adjustments to obligated amounts, initiating closeout and deobligation actions, and maintaining proper documentary evidence in coordination with the Finance and Procurement Offices.

0205 Procedures

020501 VA will use the 1358 as an obligation control document only for the approved uses within FMS, which is listed in Appendix A, and obligations for hospital and medical services furnished at non-Departmental facilities that began in FY 2019, as detailed in Appendix D, Obligation at Claims Approval Programs. The 1358 is purely a financial document (except for obligations utilizing the Obligation at Claims Approval methodology, as indicated in Appendix D), and shall not be used as any type of contract or agreement document.

020502 The following rules apply in establishing a 1358 for an item listed as an approved use in accordance with Appendix A, except for obligations utilizing the Obligation at Claims Approval methodology (See Appendix D for guidelines on these transactions):

The 1358 must be completed in accordance with the details in Appendix A and include supporting documentary evidence required by 31 U.S.C. 1501.
The approved purpose will be one of the approved uses within Appendix A, or sub-categories and the period of performance will be designated. To ensure proper stewardship of VA’s funds, the requesting office will continuously monitor and validate 1358 obligations, initiate adjustments to obligated amounts, initiate timely deobligations, and maintain proper documentary evidence.
The obligation number will be assigned to the 1358 when the finance office obligates the document. The requesting agency/service will be notified of the obligation number.
Line item details (authorizations), to include the period of performance and total estimated obligations, will be clearly identified for the individual line item.
Each line item (authorization) will be monitored by the requesting agency/service. This includes ensuring that all transactions and activity have been properly recorded and tracked for each line item.
The total amount for all line items (authorizations) will not exceed the total funds obligated on the 1358. If the amount required exceeds the obligation, the amount on the 1358 will be increased. Increases will be approved by the requesting agency/service Control Point Official. Where the obligation is for a contract, agreement, or order in place, increases over the obligation amount must have funds verified by budget and/or the finance office. Additionally, notifications will be sent to the Contracting Officer. Upon issuance of a modification to a contract, the obligation may be increased.
After all expected activity has been completed, any balance remaining will be de-obligated within 30 days following the end of the month or fiscal year, as appropriate. Decreases will be initiated and approved by the requesting agency/service and routed to the finance office.

020503 For approved uses in Appendix A, the finance office will not obligate a new 1358 without the appropriate information recorded in the vendor, contract number, period of service, and purpose fields on the document, as stated in Appendix C. Obligations will be processed when the information is verified and accurate. A 1358 lacking this information will be returned to the requester, stating the reason for return.

020504 As required in the Federal Procurement Data System (FPDS), procurement expenditures using a 1358 as an obligation document only (uses listed in Appendix A only) will be reported in accordance with contracting reporting requirements. Purchasing and contracting activities will request the required information from the finance office for 1358s that have been established and need to be reported in FPDS. The contracting official is responsible for ensuring the appropriate information is requested, the obligation is tied to the contracting method, and is appropriately submitted to FPDS. The finance office will provide the following minimum information for each 1358 based on contracting’s request. The requested information may change based on contracting reporting requirements.

1358 obligation number;
Contract number;
Vendor;
Specific purpose, period of performance and appropriate reference; and
Total obligation amount for the period requested.

020505 Indefinite Delivery/Indefinite Quantity (IDIQ) contracts will not be obligated using the 1358 unless the purpose is listed as an approved use in Appendix A. If the purpose is not listed, VA Form 2237, Request, Turn-in, and Receipt for Property or Services, will be used as the requesting document and VA Form 2138, Order for Supplies or Services, will be used as the obligating document.

0206 Definitions

020601 Honoraria. Voluntary payments to a person for a service for which a fee is not legally or traditionally required. VA policy, Volume II, Chapter 7B, Honoraria, allows for honoraria payments, not to exceed $100, provided that the payments are not of a significant nature, enforceable by law, and are used as more of a thank you or an expression of appreciation for voluntary services received.

020602 Obligation. A legally binding agreement that will result in outlays, immediately or in the future. When an individual places an order, signs a contract, awards a grant, purchases a service or takes other actions that require the Government to make payments to the public or from one Government account to another, an obligation is incurred.

020603 Obligation at Claims Approval. Occurs when a liability does not arise until the agency formally reviews, applies all established business rules, and approves payment of the healthcare claim or invoice through a contract. In these instances, the agency should not record an obligation until it approves the claim for payment. (See discussion at Government Accountability Office (GAO) Redbook Chapter 7, Obligation of Appropriations, Administrative Approval of Payment.) For policy related to Obligation at Claims Approval, see Volume III, Chapter 3, Obligation at Claims Approval for further information.

020604 Receivers for Delivery of Goods. An authorized individual who accepts or rejects the delivery of goods or services on an invoice as compared to the order or contract. Discrepancies are noted for items not received, incomplete, broken, etc. Receivers for an online system may rely on a notification (written or softcopy form) from another Federal employee before performing the receipt in a system.

020605 Recovery audit. A review and analysis of an agency’s or program’s accounting and financial records, supporting documentation, and other pertinent information supporting its payments, that is specifically designed to identify overpayments. It is not an audit in the traditional sense covered by Generally Accepted Government Audit Standards (GAGAS). Rather, it is a detective and corrective control activity designed to identify and recover overpayments, and, as such, is a management function and responsibility.

020606 Stipends. Fixed sums of money paid periodically for services or to defray expenses. A stipend is distinct from a salary payment because it does not represent payment for work performed, but rather is payment for a role that is normally unpaid or which cannot be measured in terms of a task. 41 CFR 101 allows compensation and expense reimbursement of advisory committee members, staffs, and consultants up to the maximum GS-15 daily rate unless approved by the SECVA.

0207 Rescissions

020701 Financial Policy Volume II Chapter 6, 1358 Obligations, dated March 2024.

0209 Revisions

Section	Revision	Office	Date
0202	Added requirement for documentation of authority to create obligations per OIG Report 21-3101 73 recommendation.	VHA	November 2024
Appendix A, Use #13	NCA updates for Use #13 Outer Burial Receptacles	NCA	November 2024
Appendix A, Use #20	Allowed the use of the 1358 for Land Acquisitions under 38 U.S.C. § 8103 & 38 U.S.C. § 2406.	ORP	November 2024
Various	Move policy to Volume III Chapter 2A	OFP (047G)	March 2024
Appendix A, Use #19	Allowed the use of the 1358 for Military Personnel and Civilian Employees Claims Act under 31 U.S.C. § 3721 and Miscellaneous Travel Expenses under FTR Part 301-12	OFP (047G)	December 2023
Appendix A, Use #20	Allowed the use of the 1358 for Prize Competitions under 15 U.S.C. § 3719	OFP (047G)	December 2023
Appendix A, Use #19	Allowed the use of the 1358 for continuing professional education for occupations identified in 38 U.S.C. § 7411	OFP (047G)	September 2023
Appendix A, Use #19	Allowed the use of the 1358 for the reimbursement of required medical examinations	OFP (047G)	September 2023
Appendix A, Use #19	Allowed the use of the 1358 for the reimbursement of maintenance services purchased in limited circumstances without the GSA Fleet Service Card	OFP (047G)	September 2023
Appendix A, Use #20	Allowed the use of the 1358 for the buy-out of service contracts for certain healthcare professionals	OFP (047G)	September 2023
Appendix A, Use #20	Allowed the use of the 1358 for payment of witness fees for non-federal employees	OFP (047G)	September 2023
Appendix A, Use #20	Allowed the use of the 1358 for payment for overpayment audit recoveries	OFP (047G)	September 2023
Appendix A, Use #19	Allowed the use of the 1358 for reimbursements to employees requiring vision support for workplace roles as required by appropriate collective bargaining agreement	OFP (047G)	June 2023
Appendix A, Use #19	Updated information on the Employee Debt Reduction Program	OFP (047G)	June 2023
Appendix A, Use #20	Allowed the use of the 1358 for GSA Fleet Vehicle purchases through AutoChoice	OFP (047G)	June 2023
Appendix A, Use #20	Allowed the use of the 1358 for legacy enhanced use lease payments	OFP (047G)	June 2023
Appendix A, Use #21	Guidance on caregiver respite and oversight programs are included in obligate at claims approval methodology per OGC opinion; Caregivers receiving stipends under 38 C.F.R. Part 71 are not considered to be community care providers. Therefore, caregiver stipends do not follow the obligation at claims approval methodology. Use #21 is revised to reflect these changes.	OFP (047G)	June 2023
Appendix A, Use #13	Expanded the use of the 1358 for grant recipient cemetery programs providing outer burial receptacles per new legislation (38 USC § 2306)	NCA	December 2022
Appendix A, Use #19	Allowed the use of the 1358 for reimbursement to employees requiring proof of a negative infection test to enter an official duty station or conduct official business	OFP (047G)	October 2022
Appendix A, Use #23	Reactivated use #23 for VBA use; State Approving Agency fund has not been moved to new accounting system.	VBA	October 2022
Appendix D	Updated Obligation at Claims Approval appendix for new policy (Volume II, Chapter 5C)	OFP (047G)	October 2022
Various	Terminology is updated per revised legislation. “Obligation at payment” and “obligate and pay” terminology is updated to reflect “obligation at claims approval”	OFP (047G)	September 2021
060603	Categories of Obligation at Claims Approval programs are updated to reflect revised legislation	OFP (047G)	September 2021
Appendix A, Uses #1 and #2	Legislation is revised for obligations for hospital and medical services furnished at non-Departmental facilities	OFP (047G)	September 2021
Appendix A, Use #11	Clarified that vocational rehabilitation is permitted under Use #11	OFP (047G)	September 2021
Appendix A, Use #14	VBA Lease Agreement Overtime Charges is discontinued via the 1358; these transactions will be paid via iFAMS	OFP (047G)	September 2021
Appendix A, Use #19	Allowed the use of the 1358 for lump sum payments to educational institutions participating in the G.I. Bill work-study program	OFP (047G)	September 2021
Appendix A, Use #19	Allowed the use of the 1358 for Coronavirus (COVID-19) testing and immunization when required for official travel	OFP (047G)	September 2021
Appendix A, Use #20	Allowed funding for research projects to be transferred to Non-Profit Corporations via the 1358	OFP (047G)	September 2021
Appendix A, Use #23	State Approving Agency transactions are discontinued via the 1358; these transactions will be paid via iFAMS	OFP (047G)	September 2021
Appendix B and Appendix C	Revised invalid uses and IFCAP charts to reflect updates to Appendix A	OFP (047G)	September 2021
Appendix D	Updated to reflect Consolidated Appropriations Act of 2021 legislation affecting Obligation at Claims Approval Programs	OFP (047G)	September 2021
Appendix A, Use #15	Allowed Eyeglass Fabrication services to be paid on the 1358	OFP (047G)	October 2020
Appendix A, Use #19	Added “Education Debt Reduction Program” to authorized use #19	OFP (047G)	September 2020
Appendix A, Use #20 Appendix B, Paragraph #5	Allowed postage payments to the U.S. Postal Service under Use #20, Non-Procurement Obligations	OFP (047G)	September 2020
Appendix B, Paragraph #8	Allowed exemption for the use of the 1358 on Construction and Facilities Management obligations	OFP (047G)	September 2020
Appendix B, Paragraph #11	Removed Compensated Work Therapy from the list of invalid uses	OFP (047G)	September 2020
Appendix C	Added “Regulated Utilities” to Use #18 and “Employee Training, Scholarships, Tuition, Training, OIG Emergency Purchases” to Use #19 on IFCAP Chart.	OFP (047G)	September 2020
Appendix D, Paragraph B	Removed “except for State Home Services (which are not processed via 1358s).”	OFP (047G)	September 2020

Appendix A: VA Form 1358 Approved Uses

Following is a list of uses that are appropriate (approved) for the use of a VA Form 1358. The 1358 will not be used for any other purpose. Items not listed under this appendix require the use of VA Form 2237.

Required information for the 1358:

An approved use and specific purpose description;
Period of performance: Date or date range;
Referenced order, obligation, or contract number, if not included elsewhere; and
Vendor or multiple vendors, if applicable. Note: If a waiver allows for the use of “Miscellaneous Vendor” and there are multiple vendors, a separate obligation is required for each vendor type (federal and non-federal). Federal vendors will require a separate obligation for each agency.

Refer to Appendix C, VA Form 1358 Required Information, for additional information and a complete IFCAP listing of the approved uses.

1. Nursing Homes/Adult Day Health Care (Reference Appendix D, Obligation at Claims Approval Programs)

2. Community Care (formerly Non-VA Medical Care), including Dental, Homemaker/Home Health Aid, Community Hospitalization (formerly Non-VA Hospitalization) (Reference Appendix D, Obligation at Claims Approval Programs

3. Standardized Obligations

Description. These obligations are established by a service-level agreement or other contractual agreement at the national level. For example, at the beginning of each fiscal year, for VHA facilities, VHA Central Office provides a list of all standard obligations to the field for local obligations. Payments for the following programs or services are provided by the national level and are distributed to individual facilities for obligation at the local level:
1. Federal Telecommunications Services (FTS) 2001.
2. College of American Pathology/Joint Pathology Center.
3. Convenience check fees.
4. Denver Acquisition and Logistics Center (DALC) services and supplies.
5. SmartPay (US Bank and the National Patient-Centered Community Care (PC3) Centralized contract administrative fees.
6. Federal Employees Compensation Program (FECP), also referred to as Office of Workers’ Compensation Programs (OWCP).
7. SHPS Inc. SHPS is contracted by the Office of Personnel Management (OPM) to administer the Flexible Spending Account (FSA) program. It is a provider of integrated health solutions to help improve personal health and reduce spending.
8. Standard Level User Charges General Services Administration (SLUC/GSA), to include National Archives and Records Administration (NARA) services.
9. Transit benefits.
10. Franchise Fund Accounts: Security and Investigations Center, Law Enforcement Training Center, Financial Services Center, Debt Management Center, IT Infrastructure Operations, Human Resource Enterprise Center, and Records Center and Vault.
11. Supply Fund: Strategic Acquisition Center (SAC).
12. Supply Fund: Technology Acquisition Center (TAC).
Justification.
1. Costs must be borne by the requesting agency/service.
2. No other payment methodology is available for the DALC at this time.
3. As contracts are awarded/inter-agency/intra-agency agreements enacted (on a national basis) to individual vendors for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.
On VA Form 1358, VHA must reference the standardized obligation in the Purpose field as directed.

4. Standardized Obligations Supply Fund: National Acquisitions Center (NAC)

Description. These obligations are established by a service-level agreement or other contractual agreement at the national level. For example, at the beginning of each fiscal year, for VHA facilities, VHA Central Office provides a list of all standard obligations to the field for local obligations. Payments for the following program is provided by the national level and is distributed to individual facilities for obligation at the local level:
1. National Acquisition Center (NAC).
Justification.
1. Costs must be borne by the requesting agency/service.
2. As contracts are awarded to individual vendors/inter-agency/intra-agency agreements enacted for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.
On VA Form 1358, VHA must reference the standardized obligation in the Purpose field as directed.

5. Research Studies/Royalty Payments

Description. These can be studies conducted by both VA and external organizations. This approved use sets up the supporting obligation for payments made directly to multiple participants (VA patients) of research studies for minor costs, such as those associated with travel to their appointments. (38 U.S.C. 7303, Functions of Veterans Health Administration: research programs). VA Form 1358 must reference the research study.
Justification. Multiple individuals are involved and there are no contract(s). “Miscellaneous vendors” may be used because of PII concerns with research study participants; identify the external organization vendor(s) in the Purpose field. Participants will be listed in supporting documentation to ensure that individuals are paid appropriately and to reduce erroneous payments.
On VA Form 1358, in the Purpose field, reference the research study and provide a description.

6. Inter-Library Loan Program (authority code 6) is now disallowed and should no longer be used. Refer to “INVALID USES OF VA FORM 1358” below for additional information.

7. Affiliation Agreements for Interns/Residents. Long-term residency agreements are established between the medical center director and dean of the affiliated university medical school for training of interns/residents. These agreements are negotiated by the medical center director, in consultation with the Office of Academic Affairs in VHA Central Office and may be negotiated yearly or multiple times per year.

Description. Negotiations are conducted for residents from an affiliated university assigned to a medical center. These are affiliation agreements for resident/intern programs, not for medical service contracts negotiated under 38 U.S.C. 8153, Sharing of health-care resources; 38 U.S.C. 7406, Residencies and internships; or 38 U.S.C. 7409, Contracts for scarce medical specialist services.
Justification. 38 U.S.C. 8153 exempts these agreements from FAR contracting requirements.
On VA Form 1358, in the Purpose field, reference Affiliation Agreement.
Affiliation Agreements are done with individual university medical schools/medical school disbursing agents for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.

8. Tort Claims/EEO settlements; OIG Confidential Services and Investigative Purchases

Description. Tort claims/EEO settlements may include settlement, including Judgment Fund, payments to the Department of the Treasury. (Tort: 38 U.S.C. §515, Administrative settlement of tort claims and 28 USC § 2672, Administrative adjustment of claims).
Justification.
1. No contract or acquisition activity is involved with tort claims/EEO settlements.
2. “Miscellaneous Vendor” is not permitted for this use. An individual must be vendorized so that a 1099 may be issued for tax purposes.
3. There is no way to predict the amount or payee in advance; identify the vendor in the description or vendor field. In certain settlement cases, the vendor may be the representative of the claimant. The recipient’s identity in confidential settlements will be recorded in supporting documentation to ensure that claimants are paid appropriately.
C. On VA Form 1358, reference the case number in the Purpose field.

9. Volunteer and Resident Meal Tickets, Volunteer Reimbursements, Honoraria, and Stipends

Description. Volunteer meals can be paid for by medical centers. Some facilities establish a VA Form 1358 for meals for residents. This could be either paid for with General Post Fund donations or Medical Services appropriations. It may also include reimbursements to volunteers for out-of-pocket costs incurred to meet requirements to volunteer, e.g., costs of VA printouts for volunteer drivers. (38 U.S.C. 7406(b), Residents and 38 U.S.C. 513, Contracts and personal services) Honoraria are voluntary payments to a person for a service for which a fee is not legally or traditionally required. VA policy, Volume II, Chapter 7B, Honoraria, allows for honoraria payments, not to exceed $100, provided that the payments are not of a significant nature, enforceable by law, and are used as more of a thank you or an expression of appreciation for voluntary services received. Stipends are fixed sums of money paid periodically for services or to defray expenses. A stipend is distinct from a salary payment because it does not represent payment for work performed, but rather is payment for a role that is normally unpaid or which cannot be measured in terms of a task. 41 CFR 101 allows compensation and expense reimbursement of advisory committee members, staffs, and consultants.
Justification.
1. No contract or acquisition activity is required.
2. This may be a requirement of an affiliation agreement or may be voluntary on the part of the facility.
This 1358 approved use is comprised of five separate types of transactions:
1. Inter-departmental transactions between VHA and the Veterans Canteen Service (VCS). Reimbursable agreements must be established for each location within both Voluntary Services and the VHA medical centers which procure VCS meal tickets for volunteers or residents/interns. These agreements must comply with VA policy on reimbursable agreements and must include the estimated dollar amount of meal tickets that will be procured by that organization for the fiscal year. An annual 1358 obligation with the Canteen Service as the federal vendor must be established for this amount. All VCS reimbursable agreements must be processed via Intra-Governmental Payment and Collection (IPAC), no purchase cards or checks will be used between VCS and VHA.
2. Reimbursements to volunteers for local transportation costs and miscellaneous reimbursable expenses. Since there are a very large number of one-time payments for this program, it is not efficient for VA to individually vendorize each payee. Therefore, “Miscellaneous Vendor” is permitted to use for this purpose
3. Public transportation passes/tickets provided to volunteers in accordance with VHA Directive 1620, VA Center for Development and Civic Engagement Program. These should be procured through either the purchase card or a contract, not a 1358. For vendors that do not accept a purchase card, a convenience check may be used for up to $5,000. Documentation supporting these payments will be kept with other applicable voluntary services documentation in accordance with Records Retention guidelines required by Handbook 1620.
4. Procurement of meals from non-federal sources. These transactions should be procured through either the purchase card or a contract, not a 1358. For vendors that do not accept a purchase card, a convenience check may be used for up to $5,000.
5. Honoraria and stipends. These transactions should be individually vendorized on the 1358, i.e., “Miscellaneous Vendor” is not permitted.
On VA Form 1358, describe the type of obligation, e.g., meals, reimbursement; and the requirement; etc. in the Purpose field.

10. Incentive Therapy/Compensated Work Therapy (38 U.S.C. 1718, Therapeutic and rehabilitative activities)

Description. The Compensated Work Therapy (CWT) Program includes several sub-programs: Incentive Therapy; Sheltered Workshop; Transitional Work and Vocational Assistance; Supported Employment and Post-Employment Supports; and Transitional Residence. This paid work therapy may be performed by select Veterans at VA facilities or at non-VA (federal or non-federal) facilities.
Justification.
1. There are multiple patients. “Miscellaneous vendor” may be used.

11. Beneficiary Travel and Direct Payments to Veterans from General Post Fund

Description. Payments are made to Veterans and/or attendant or non-contract transportation vendors for travel related to medical care from Medical Services appropriation; vocational rehabilitation, Veteran readiness, and employment assistance from Benefits appropriations; and other payments to Veterans from the General Post Fund. (38 U.S.C. 111, Payments or allowances for beneficiary travel).
Justification.
1. There are multiple beneficiaries or vendors. Since there are a very large number of one-time payments for this program, it is not efficient for VA to make individual obligations for each payee. Therefore, “Miscellaneous Vendor,” “Beneficiary Travel,” or similar is permitted to use for this purpose.

12. Home Improvement Structural Alterations (HISA)

Description. Prosthetics implemented in accordance with 38 CFR §17.3100 -17.3130 for the HISA benefit are to be paid to the beneficiary instead of the vendor. The 1358 will be used to obligate the funds for the approved benefit amount. The 1358 is necessary to capture the transaction in the National Prosthetic Patient Database (NPPD), an integral part of patient workload and inventory management.
Justification.
1. A benefit payment will be made to the beneficiary.
2. As payments are processed to individual beneficiaries for these purposes, a specific vendor, i.e., beneficiary, must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.

13. National Cemetery Administration (NCA) Veteran Benefits

Outer Burial Receptacles
1. Description. VA is authorized to provide outer burial receptacles (OBRs) for each new grave in cemeteries under the control of the National Cemetery Administration (NCA) or in a cemetery that is the subject of a grant to a State, County or Tribal Organization under 38 U.S.C. § 2408, in which remains are interred in a casket. In cases where a privately purchased OBR is used in lieu of a government furnished grave liner, VA will pay a monetary allowance. In administering this authority with respect to grant funded cemeteries, VA will provide reimbursement to grant funded cemeteries for the cost of pre-placed OBRs associated with construction of new gravesites, and will provide a monetary allowance for OBRs placed at time of interment Outer burial receptacles are funded by the Veterans Benefits Administration (VBA) Compensation and Pension appropriation.
  1. For privately purchased outer burial receptacles, a one-time monetary allowance is made to the person who paid for the OBR:
    - NCA establishes a single VA Form 1358 obligation for the year.
    - For burials in national cemeteries, private purchase is indicated in the NCA burial system by cemetery staff.
    - A file is sent weekly from NCA burial system to the Corporate Data Center Operations (CDCO).
    - The CDCO uses this data to create a payment file that references the VA Form 1358 obligation and sends these payments to the Financial Management System using OBRBENE as the vendor and referencing the VA Form 1358 obligation.
    - For burials in grant funded cemeteries, a request for monetary allowance is submitted on VA Form 40-10232 to NCA Finance Service with proof of purchase and certified by cemetery official. NCA Finance Service will manually enter the payment information to the Financial Management System using OBRBENE as the vendor and referencing the VA Form 1358 obligation.
  2. For pre-placed outer burial receptacles installed as part of cemetery construction grant project under 38 U.S.C. § 2408, NCA will provide reimbursement to the State, County or Tribal Organization:
    - NCA will establish a 1358 obligation for the purchase of pre-placed outer burial receptacles associated with each grant award for construction of new gravesites, specifying the State, County or Tribal Organization’s vendor ID.
  3. For outer burial receptacles placed at the time of interment in a State, County or Tribal grant funded cemetery, a monetary allowance is paid on a quarterly basis. NCA will establish a 1358 obligation for each State, County or Tribal Organization that uses OBRs at the time of interment.
2. Justification.
  1. Payment under paragraph (1)(a) above is a one-time payment made to an individual who paid for the privately purchased outer burial receptacle. Payment under paragraphs (1)(b) and (1)(c) is authorized under 38 USC § 2306(e) to grant-funded cemeteries.
  2. As there are multiple payees, “Miscellaneous Vendor” may be used for payments to individuals under paragraph (1)(a) above. OBRBENE will be the FMS miscellaneous vendor code. “Miscellaneous Vendor” cannot be used for payments directly to grant funded organizations under paragraphs (1)(b) and (1)(c) above.
  3. As the payment will cross Administrations from VBA to NCA, VBA will issue a Transfer of Disbursing Authority (TDA) from the Compensation and Pension account, thus allowing NCA to administer the OBR program.
Dignified Burial Casket/Urn
1. Description. A payment is made up to an established amount (adjusted annually) to a funeral home, state, or local government agency for the purchase of an original casket or urn for the interment of the remains of deceased eligible Veterans without next-of-kin and without sufficient resources available for burial.
2. Justification.
  1. Payment on behalf of each unclaimed Veteran will be made to a funeral home, state, or local government agency. There is no procurement activity involved in the transaction.
  2. As payments are processed to individual vendors for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.

14. VBA Lease Agreement Overtime Charges (Authority Code 14 is now disallowed and should no longer be used. Refer to Appendix B: Invalid Uses of VA Form 1358 for additional information. Reference VA Financial Policy Volume III, Chapter 2A – Non-Contractual Obligations for policy guidance.

15. Home Oxygen and Eyeglass Fabrication

Description. Individual facility or multi-facility indefinite delivery/indefinite quantity (IDIQ) contracts are awarded for home oxygen and eyeglass fabrication. Because these bills are paid in arrears, an obligation for the estimated amount of the bills is required. It is not possible to estimate an annual amount for each patient on a VA Form 2237, as the number of patients provided home oxygen or eyeglasses changes from month to month.
Justification.
1. Contracts are awarded to individual vendors for home oxygen and eyeglass fabrication services. However, due to the multitude of vendors, fluctuating oxygen and eyeglass needs of patients, number of clinicians involved in determining specific oxygen and eyeglass needs, and system limitations, “Miscellaneous Vendor” may be used for this authorized use.
On VA Form 1358, reference the IDIQ contract in the Purpose field.
VA Form 1358 may be used to obligate the estimated monthly amount of supplies and services. The initiating service will review the monthly invoices prior to payment to ensure the vendor used the proper pricing (established in the IDIQ contract) and that the quantities of supplies and services are valid.

16. Prosthetics — New or Repaired Items. NOTE: This is an interim approved use that will no longer be allowed upon completion of necessary modifications to the Prosthetics software. (38 U.S.C. 543, Advisory Committee on Prosthetics and Special-Disabilities Program)

Description. VA Form 1358 is used in lieu of a VA Form 2237 whenever a vendor for a prosthetic item or repair will not accept a purchase card or EFT.
Justification. If the vendor does not accept purchase cards because he or she does not have a mechanism for doing so, and the item/service must be provided to a patient, it is obligated on a VA Form 1358.
As contracts are awarded to individual vendors for these purposes (when the purchase card is not used), a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.

17. Pharmacy/Subsistence Prime Vendors and Consolidated Mail Order Pharmacy (CMOP) Direct-to-Patient (DTP) Program⁴

Description. A Prime Vendor contract is in place for Pharmaceuticals and Subsistence ordered by VHA field facilities and CMOP. A DTP contract is in place with vendors and managed by the CMOP to supply prescribed items directly to the Veteran. For the reasons listed below, a monthly, quarterly or annual VA Form 1358 is required.
Justification.
1. For Prime Vendor, orders are placed directly through the Prime Vendor’s online proprietary ordering system against a pre-established purchase card account. These charges require a corresponding obligation number in the accounting system.
2. Because of currently limited capabilities of IFCAP, there is no alternate method for obligating these daily, high-volume orders without considerable duplication of data entry, which greatly increases the potential for typing errors, causing more difficulty in reconciling.
3. For DTP, the total amount of weekly invoices is unknown in advance and the large volume of invoices makes tracking expenditures against the obligation difficult without external tracking mechanisms. Utilizing a 1358 provides a stronger tracking mechanism for these expenditures.
4. To use this approved use, ordering activities must follow the Prime Vendor 1358 Guidebook issued by the Pharmacy Benefits Management Office (PBM).
5. As contracts are awarded to individual vendors for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.
On VA Form 1358, reference the Prime Vendor contract number in the Purpose field.

18. Regulated Utilities

Description. VA Form 1358 may be used to obligate public utility services with rates approved and/or established by a regulatory body.
Justification.
1. A FAR and VAAR deviation was issued, effective February 1, 2020, to remove the unnecessary, burdensome, and costly regulatory requirements to seek bilateral written contracts for services provided by public utilities under rates approved and/or established by a regulatory body, while remaining compliant with applicable fiscal law regarding the recording of obligations at 31 U.S.C. §1501(a)(8). This deviation allows VA to streamline the processing of a narrow group of utility service acquisitions by providing an exception to the regulatory requirement to use bilateral contract(s) when procuring regulated utility services under rates approved and/or established by a regulatory body.
2. A contract is required for non-regulated utility services exceeding the micro-purchase threshold.
3. A specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.
On VA Form 1358, describe the utility service in the Purpose field.

19. Reimbursements to VA Employees or Students; Employee Training, Scholarships, Tuition, Training, OIG Emergency Purchases, testing and vaccinations related to pandemic situations declared by the Centers for Disease Control (such as COVID-19), Eye exams, eyeglasses, or lenses required for a workplace visual display terminal (VDT).

A. Description. VA employees can be reimbursed for valid expenses incurred in carrying out approved programs or official business. The following reimbursements may be made:

(1) To employees for items such as but not limited to:

Professional Liability Insurance (50% of cost), not to exceed $150^[5]
Continuing Professional Education not to exceed $1,000 for those occupations identified in 38 U.S.C. § 7411
Certificates or certification licenses required by VA for employees to perform their duties (e.g., pesticide application)^[6]
Eye exams, eyeglasses or lenses required for a workplace visual display terminal (VDT) (See section 6 below)
Required or offered medical or psychiatric examination or psychological assessment under 5 CFR Part 339 Subpart C
Education Debt Reduction Program (EDRP)
Self-certified transit and bicycle benefits, in accordance with Volume XV, Chapter 6A, Transit Benefit Programs, Appendix A: Self-Certification Reimbursements.
OIG Emergency Purchases.
Obtaining maintenance services without the GSA Fleet Service Card in limited emergency circumstances. The GSA Fleet Service Card is the preferred and mandated method of payment for fleet vehicle-related cost.
Claims for personal property damage or loss filed under 31 U.S.C. § 3721, Military Personnel and Civilian Employees’ Claims Act (MPCECA).
Miscellaneous employee travel requirements that are not able to be entered into VA’s travel reimbursement system due to system limitations.

Obligations for employee reimbursements can be made on VA Form 1358.

(2) Employee training in accordance with VA Handbook 5015. Reimbursements may be made for tuition, book expenses, and examination fees that have been approved on an SF-182, Authorization, Agreement, and Certification of Training, and when all requirements of VA Directive 5015, Employee Development, have been met.

Supervisory approval is required for individual employee training requests, approval requirements are as follows:

Less than or equal to $10,000 – first level supervisor.
Greater than $10,000 but less than $25,000 – First level Senior Executive Service (SES).
Greater than $25,000 – Undersecretary, Assistant Secretary, or Other Key Official.

The Government Purchase Card is encouraged to be used for payment of employee training programs, to the maximum extent practicable. VA Form 1358 may be used in instances where the training cost exceeds the purchase card limit, or the vendor does not accept payment by credit card. As payments are processed to individual vendors for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.

Training programs in excess of the micro-purchase threshold specifically created or tailored to VA must be routed via a 2237 through the contracting office a 2237.

(3) Scholarship programs and centrally monitored training programs.

VA may also pay tuition directly to Universities, Colleges, or Other Professional training institutions, paid on behalf of employees and students (e.g., for college students enrolled in the Visual Impairment and Orientation and Mobility Professional Scholarship Program or Health Professionals Educational Assistance Scholarship Programs (such as the Employee Incentive Scholarship Program and the Health Professional Scholarship Program).

(4) Educational institutions participating in GI Bill work-study programs.

The Ryan Kules and Paul Benne Specially Adaptive Housing Improvement Act of 2019 authorizes VA to provide a lump sum payment to educational institutions for Veterans participating in GI Bill work-study programs in accordance with 38 U.S.C. 3485, Work-study allowance. The educational institution will then pay GI Bill work-study students their hourly wage from the lump sum payment and return the unused portion at the end of the year.

(5) Test or immunizations required for VA travel during declared pandemic situations (such as Corona Virus (COVID-19)). If a proof of negative infection test is required for entry into an employee’s official duty station or for official business, VA may use the VA Form 1358 to reimburse the employee for the cost of the test.

There are instances where an employee may be required to show proof of a test or immunization for official travel during a pandemic situation (such as COVID-19). If a traveler cannot obtain a test or immunization free of cost (Federal dispensary or covered under insurance), the cost incurred for temporary duty travel can be claimed as a miscellaneous expense (FTR Chapter 301, Part 301-12 per General Services Administration (GSA) Travel Policy).Organizations using FMS will obligate the transaction using VA Form 1358 – Obligation or Change in Obligation. Authorized relocation costs can be reimbursed under the miscellaneous expense allowance (MEA), either as a lump sum amount or actual expense process (FTR Part 302-16).

If a VA employee is required to submit a negative test for entry into an official duty station or for official business, and the employee cannot obtain a VA-sponsored test, a test covered under insurance, or a test free of cost, the employee may be reimbursed the cost of the test using the VA Form 1358 using authority #19 Employee Reimbursement. The 1358 should use budget object code 2560.

Optional Form 1164 should be completed for reimbursement for official business. The testing receipt(s) should be attached.

Payment can be processed online in FMS or through the manual invoice form process in IPPS.

(6) An agency must pay for all medical and/or psychological and/or psychiatric examinations required or offered by the agency under 5 CFR Part 339 Subpart C, whether conducted by the agency’s physician or medical review officer, an independent medical evaluation specialist (e.g., occupational audiologist) identified by the agency, or a licensed physician or practitioner chosen by the applicant or employee. This includes special evaluations or diagnostic procedures required by an agency.

(7) In limited circumstances and pursuant to the requirements in the relevant Collective Bargaining Agreement (CBA), covered bargaining unit employees (BUEs) that use workplace Visual Display Terminals (VDTs) as part of their normal work and when the use of such equipment requires using Personal Protective Equipment (PPE) during the performance of their official duties in order to mitigate hazardous conditions encountered, may be reimbursed for eye examinations and eyeglasses or contacts.

Based upon supervisory certification that the requirements of the CBA have been fulfilled, an employee may request reimbursement for:

The cost of an eye examination in an amount not to exceed $50; and
The cost of special eyeglasses/contacts (including disposable lenses) for workplace VDT operation up to $175.

(8) Education Debt Reduction Program (EDRP).

EDRP enhances recruitment and retention of health professionals that are required to meet VHA staffing. VA is authorized to provide EDRP payments to permanent, full-time employees appointed under 38 U.S.C. 7401 and part-time employees appointed under 38 U.S.C. 7405 (excluding individuals serving in positions without compensation (WOC) and other time-limited appointments), with qualifying loans, who occupy selected positions providing direct-patient care services, or services incident to direct-patient care services, for which recruitment and retention of qualified personnel is difficult. EDRP awards are based on the availability of funds and Department need.

VA Form 10-0394B, Education Debt Reduction Program (EDRP) Acceptance of Conditions, specifies the terms and conditions of an EDRP award. The EDRP form is signed by the Under Secretary for Health, or designee, and then by the EDRP candidate. The 1358 obligation is created upon the successful completion of the service period’s terms and conditions, as outlined in the VA Form 10-0394B for the appropriate amount specified for the service period. The amount of education debt reduction reimbursement payments made to or for a participant under the Education Debt Reduction Program may not exceed $200,000 over a total of five years of participation in the Program, of which not more than $40,000 of such reimbursement payments may be made in each year of participation in the Program. A service period is the period of time that an EDRP participant must serve in a paid duty status in order to receive an EDRP reimbursement payment. A service period is typically 12 months. EDRP reimbursement payments are made at the conclusion of a service period. A participant in the program may not receive debt reduction reimbursement payments for more than five consecutive 12-month periods of service in a paid duty status. The first, and in some cases the only, service period begins on the calendar day after a VA Form 10-0349B is completed.

Participants seeking reimbursement provide, within 30 calendar days of the end date of each service period, documentation reflecting the total amount of payments made and credited during each service period covered under VA Form 10-0394B. The following are considered acceptable forms of proof of payment: 1) A signed letter from the lending institution, on its letterhead, indicating the exact amount of payments received and credited or posted toward the loans specified in the EDRP application package, during the specific service period. The EDRP participant’s name and specific account numbers must appear on that letter; 2) copies of cancelled checks, front and back, payable to the lending institution(s), and noting specific account numbers; 3) copies of the face of the appropriate check(s), payable to the lending institution(s) plus copies of bank statements showing that those checks cleared the account; 4) a printout from the lender’s Web site. In addition to showing specific dates that payments were credited and amount of payments made on those dates, this printout must reflect the employee’s name and loan account number(s), as specified on VA Form 10-0394A, Education Debt Reduction Program (EDRP) Loan Verification Form; or 5) a completed Lender Loan Payment Verification Form (available from the local EDRP coordinator).

The employee’s HR or finance office will make the appropriate adjustment to the obligation to reflect the actual reimbursement amount if the amount requested is less than the original obligation.

An EDRP payment must be paid directly to the participant and not to the lending institution or other third party and the payment is exempt from taxation.

(9) Obtaining Maintenance Services without the GSA Fleet Service Card

The fleet card is the preferred and mandated method of payment for fleet vehicle-related costs. If drivers are unable to purchase vehicle-needed services with the GSA Fleet Services Card and cash or a personal credit card is used, the driver must seek reimbursement from VA. VA’s point of contact must notify GSA Fleet for reimbursement to the agency.

(10) Claims of personnel of agencies and the District of Columbia government for personal property damage or loss incident to service under 31 U.S.C. § 3721. VA may settle claims of up to $40,000 or $100,000 if the claim is made in conjunction with an evacuation or under extraordinary circumstances.

(11) The miscellaneous travel expense category was removed from the VA travel system in favor of creating specific categories for reimbursement of incurred expenses. Should a reimbursement request not fall within one of the established categories employees must request supervisory approval to incur the expense. Travel expenses should be approved in advance of travel when possible; however, in limited emergency or unforeseeable circumstances, the employee may request approval after travel has commenced. See Volume XIV, Chapter 4 – Miscellaneous Travel, and the Federal Travel Regulation (FTR) Part 301-12, Miscellaneous Expenses, for further guidance.

B. Justification.

Because reimbursements paid to VA employees for training are not reportable obligations to the Federal Procurement Data System (FPDS), and they are not subject to procurement regulations, the obligation does not need to be made on a VA Form 2237/PO. (618 F.2d 170, 176 (2nd Cir. 1980), University of Rochester v. Hartman)
- A copy of the approved SF-182 or other documentation required by VA Directive 5015 must be kept on file by the Finance Activity Office as backup to VA Form 1358 expenditures
The Government Employees Training Act (5 U.S.C. § 4105) states that the head of an agency, without regard to section 41 U.S.C. § 6101 (b-d), may make agreements or other arrangements for the training of employees of the agency by, in, or through non-Government facilities.
Tuition and scholarship transactions are not for the purchase, sale, or use of personal property or non-personal services; therefore, these transactions are not subject to the provisions of the FAR. See University of Rochester v. Hartman, 618 F.2d 170, 176 (2nd Cir. 1980).
GI Bill work-study programs are authorized under Subchapter IV-Payments to Eligible Veterans, Veteran-Student Services; therefore, these transactions are not subject to the provisions of the FAR.
Due to pandemic situations (such as COVID-19), proof of testing or immunization may be required for official travel or official duty purposes. The employee may be reimbursed for this expense via the VA Form 1358.
AGFE Master Agreement Article 29, Safety, Health, and Environment, Section 21 – Vision Program, provides limited instances for the Department’s reimbursement of employees’ eye exams and eyeglasses or contacts when using a workplace VDT as part of their official duties.
38 U.S.C. §7681-7683, Education Debt Reduction, provides the legislative authority for the EDRP.
5 CFR 339.304, Payment for examination, provides the legislative authority for paying for medical and/or psychological and/or psychiatric examinations required or offered by the agency.
GSA Fleet Customer Leasing Guide provides instruction for obtaining maintenance services without the GSA Fleet Service Card in limited emergency circumstances.
31 U.S.C. § 3721 of the MPCECA provides authorization for payment of claims of personnel of agencies and the District of Columbia government for personal property damage or loss.
System constraints require the use of a 1358 as the obligating document for travel expense categorizes not specifically identified within VA’s travel system.

C. As reimbursements are processed to individual employees or educational institutions for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.

20. Non-Procurement Obligations

Description. The following non-procurement obligations may be obligated on a VA Form 1358. The source documentation for each authorized 1358 transaction will be kept on file in the Finance Office and/or by the requesting agency/service in accordance with 31 U.S.C. § 1501, Documentary evidence requirement for Government obligations.
1. OneVA Plus Fund, Compensated Work Therapy (CWT) program (used by VA entities to obligate funds to reimburse CWT program for services provided by CWT workers), other VA internal programs and agreements and Agent Cashier bank service charges.
2. VA Homeless Providers Grant and Per Diem Program, Cemetery Grants, and other VA grant programs as authorized by regulatory guidance that meet the criteria of grants as determined in 31 U.S.C., Chapter 63, Using Procurement Contracts and Grant and Cooperative Agreements.
3. Other government agency obligations such as GSA activity (including Global Stock, vehicle, property leasing and utilities), GSA Fleet Vehicle purchases through AutoChoice, Government Printing Office, Interagency Agreements⁷, Inter-agency Sharing Agreements, Intra-agency Sharing Agreements (VHA, VBA, NCA, OIT), Intergovernmental Personnel Agreements (IPAs) and services (includes Cooperative Administrative Support Units (CASUs)), and Treasury Offset Program (TOP) fees. Refer to Volume I Chapter 11, Reimbursable Agreements.
4. The 1358 may be used for postage paid directly to the United States Postal Service. Postage should not be included on metered mail contracts with commercial vendors (e.g., Neopost, Pitney Bowes). Only the lease of the machines should be included on metered mail contracts. Metered mail contracts are not authorized to be paid via VA Form 1358 and will continue to be paid via VA Form 2237/PO or government purchase card.
5. 38 U.S.C. 7364 authorizes VA to transfer non-appropriated funds to Non-Profit Corporations (NPCs) that are received by the Department for the purpose of conducting research at VA Medical Center (VAMCs).
6. Legacy Enhanced Use Lease (EUL) payments.
  1. EULs established prior to 2012 had legislative authority to make payments to the lessee for rent, insurance, and utility payments.
  2. VA’s EUL statute (38 U.S.C. 8161-8169) was amended in 2012 to remove VA’s authority to lease back space, receive in-kind consideration, and make related payments to lessees in future EULs.
  3. VA Form 1358 may be used for legacy EULs operating under the previous legislative authority. 38 USC 8162 allows the Secretary to make payments from funds appropriated to the Department for the purposes of the EUL and is therefore not governed by Federal Acquisition Regulations.
7. PACT Act Buy-Out of Service Contracts
  1. Section 902 of Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics (PACT) Act of 2022 (PL 117-168) authorizes VA to buy out non-Department service contracts for certain health care professionals (physician, nurse anesthetist, physician assistant, or nurse practitioner) in exchange for employment at rural or highly rural VA facilities for a period of obligated service not less than four years.
  2. Medical Center Directors with delegation of authority from the Secretary are authorized to sign the individual contract buyouts.
  3. Payment of any amount for buy-out of a service contract for a covered health care professional shall be made directly to the candidate or entity with which the covered health care professional has a service obligation.
  4. The cumulative total amount paid by the Department shall not exceed $40,000,000 per fiscal year.
  5. Payment to an individual candidate or the entity with which they had a service obligation contract may not exceed $3,000,000 in accordance with the VA Undersecretary of Health Memorandum, Implementation of Section 902 of the PACT Act Buy-Out of Service Contracts.
  6. VA Form 1358 may be used for these payments in accordance with the PACT Act legislation and VA Undersecretary of Health Memorandum for the program.
8. Witness Fees to Non-Federal Employees
  1. A witness in attendance of any court of the United States shall be paid the fees and allowances in accordance with 28 U.S.C. §1821.
  2. A witness shall be paid an attendance fee for each day’s attendance. A witness shall also be paid the attendance fee for the time necessarily occupied in going to and returning from the place of attendance at the beginning and end of such attendance.
  3. VA Form 1358 may be used for the payment of witness fees due to non-federal employees (i.e., retired, separated personnel) that appear as a witness on behalf of VA. In accordance with 28 CFR §21.2, an employee who appears on behalf of the United States in their official capacity is carried in an official duty status and therefore is not entitled to receive an attendance fee.
9. Overpayment Audit Recoveries
  1. VA is authorized by the Audit Recoveries Under the Payment Integrity Information Act of 2019 (PIIA), codified at 31 U.S.C. §§ 3351-3358, and 31 U.S.C. § 3562 to perform recovery audits of payments made to identify overpayments. OMB Circular A-123, Appendix C, provides agencies with guidance that must be followed when recovery audits are performed. In addition, VA requirements specific to all recovery audits can be found in Volume VII Chapter 9 Payment Integrity and Fraud Reduction Financial policy.
  2. VA is authorized to establish contracts with commercial vendors to identify improper payments. When the vendor identifies an improper payment that is later collected, the payment to the vendor is authorized to be made from funds collected.
  3. VA Form 1358 may be used to obligate amounts due to the recovery auditor as authorized by the initial agreement.
10. Prize Competitions
  1. VA may use appropriated funds for awards associated with prize competitions subject to the limitations under 15 U.S.C. § 3719. Prior to obligating funds for a prize competition, a legal opinion must be obtained from VA Office of General Counsel (OGC) confirming the awards meet the requirements of the Purpose Statute under 31 U.S.C. § 1301.
  2. VA may carry out a program to award prizes competitively to stimulate innovation that has the potential to advance the mission of VA. Prize competition under 15 U.S.C. § 3719 may not result in the award of more than $1,000,000 in cash prizes without the approval of the Secretary. Prize awards greater than $50,000,000 cannot be awarded unless 30 days have elapsed after written notice has been transmitted to the Committee on Commerce Science, and Transportation of the Senate and the Committee on Science, Space, and Technology of the House of Representatives.
  3. Not later than March 1 of each year, the Director shall submit to the Committee on Commerce, Science, and Transportation of the Senate and the Committee on Science and Technology of the House of Representatives a report on the activities carried out during the preceding fiscal year.
  4. Cash prizes must be awarded to individuals or entities. Before payment the awardee must be vendorized as a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.
11. Land acquisitions
  1. Land acquisitions are not procured through FAR procedures.
  2. As authorized by 38 U.S.C. § 8103, VA may acquire land as necessary for the construction and alteration of medical facilities.
  3. As authorized by 38 U.S.C. § 2406, VA may acquire land as needed for national cemeteries.
  4. VA Form 1358 will be used to obligate costs for authorized land acquisitions, including relocation, closing and settlement costs.
Justification.
1. These obligations do not require any action by a procurement official and do not require reporting to FPDS. Using the 1358 under this approved use is not authorization to circumvent the acquisition review; users are encouraged to seek the Office of Acquisition’s advice.
2. Source documents for these obligations may not be automated in the feeder system. For these, supporting documentation would need to be retained.
3. The NCA State Grant Program, authorized by 38 U.S.C. 2408, Aid to States for establishment, expansion, and improvement of Veterans’ cemeteries, authorizes the Secretary to issue an award letter for the monetary grant to a state to establish, expand, or improve a state Veterans’ cemetery and to make progress payments from these funds as the work is completed. A Memorandum of Agreement is established between the state and VA stipulating the terms of the grant. These grants are authorized by the Secretary.
4. Under Treasury Financial Manual (TFM) Bulletin No. 2006-07, Federal Program Agencies using commercial mail processes in accordance with the 41 CFR Part 102-192, as amended, must use Automated Clearing House (ACH) credits for postage payments when funding their USPS PostalOne! ® account and postage meter services. Postage payments directly to USPS do not require Contracting support.
5. There are circumstances under which appropriated funds from other government agencies (OGAs) such as National Institutes of Health and DoD are transferred to the VA under the Economy Act and then subsequently transferred to the NPC (NPCs may not receive any VA appropriated dollars). The 1358 may be used to complete these non-FAR-based transactions.
6. Legal Authorities/Guidance for EULs established prior to 2012: 38 U.S.C.§§ 8161-8169.
7. Legal Authorities/Guidance for PACT Act Buy-Out of Service Contracts: Section 902 of Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics Act of 2022 (PL 117-168).
8. Legal Authorities/Guidance for Witness Fees to Non-Federal Employees: 28 U.S.C. §1821 and 28 CFR §21.2.
9. Legal Authorities/Guidance for Audit Recoveries: Audit Recoveries Under the Payment Integrity Information Act of 2019 (PIIA), codified at 31 U.S.C. §§ 3351-3358, 31 U.S.C. § 3562, and OMB M-21-19.
10. Legal Authorities/Guidance for Prize Competitions: 15 U.S.C. § 3719.
11. Legal Authorities/Guidance for Land Acquisitions: 38 U.S.C. § 8103 & 38 U.S.C. § 2406.
On VA Form 1358, use the source document reference number in the Purpose field.
The affected parties are identifiable. As contracts are awarded to individual vendors for these purposes, a specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.

21. Caregiver Respite, Oversight, and Stipend Programs:

Description.
1. CHAMPVA, Spina Bifida Health, Children of Women Vietnam Veterans, Foreign Medical Program, and other VHA Office of Integrated Veteran Care (formerly VHA Office of Community Care and the Chief Business Office Purchased Care) programs located at the Health Administration Center are included in Obligation at Claims Approval authority refer to Appendix D, Obligation at Claims Approval Programs.
2. Caregiver Stipend, Respite, and Oversight Programs provide support to caregivers in the form of stipends, caregiver respite provided in a home setting, and caregiver respite provided at a non-Departmental facility. (VA MISSION Act of 2018; Federal Rule RIN 2900-AQ48, Program of Comprehensive Assistance for Caregivers Improvements and Amendments Under the VA MISSION Act of 2018.)
Justification. Caregiver Respite provided at non-Departmental facilities is an obligate at claims approval program; however, VA is unable to identify Respite Care provided at Non-Departmental facilities from Respite Care provided in a home setting. Due to the immateriality of the total Respite Care program, a temporary waiver to the obligate at claims approval requirement is being granted to Respite Care provided at Non- Departmental facilities allowing all Caregiver Stipend, Respite, and Oversight Programs to obligate at authorization. This waiver will be in effect as long as total Respite Care is immaterial and Respite Care provided at Non-Departmental facilities cannot be identified.

22. Special Adaptive Housing Inspections (authority code 22) is now disallowed and should no longer be used. Refer to “INVALID USES OF VA FORM 1358” for additional information.

23. State Approving Agency (SAA)

Description. The state legislation established the State Approving Agency (SAA) for approving courses and programs in accordance with the provisions of Title 38, U.S.C. VA is authorized, under the provisions of 38 U.S.C. 3671, Designation, and 3674, Reimbursement of expenses, to reimburse the SAA for reasonable and necessary expenses of salary, travel, administrative costs, outreach activities, and subcontract work incurred by employees of the SAA.
Justification.
1. Contracts are not required as these are reimbursements. A specific vendor must be used in creating each 1358. “Miscellaneous vendors” may not be selected for this authorized use.
On VA Form 1358, reference the SAA and agreement number in the Purpose field.

Appendix B: Invalid Uses of VA Form 1358

Following are examples of invalid uses of VA Form 1358. This list is not all- inclusive and other authorized obligation forms may be used where appropriate.

Deregulated utilities, Network, and or voice/data telecommunications, or combination of services solely relying from both Network and non-Network sources, and electronic and information technology (EIT). Obligate on VA Form 2237/PO.
Contract ambulance. Obligate on VA Form 2237/PO.
Bed rentals. Obligate on VA Form 2237/PO or Government purchase card.
Transcription services. Obligate estimated quantities on a VA Form 2237/PO.
Facility security services. Obligate contracted services on a VA Form 2237/PO.
Desktop delivery of office supplies. Obligate on a VA Form 2237/PO or Government purchase card.
General Post Funds. Obligate using VA Form 2237/PO or Government purchase card, except for meal tickets, direct payments to Veterans, or non-procurement actions (such as directed-use donated funds).
Construction. Obligate on VA Form 2237/PO. Contingency funds not included in the contract amount should remain unobligated in the appropriate fund control point until required. Major and minor construction contracts performed via interagency agreement with the U.S. Army Corps of Engineers are permitted to use the VA Form 1358 due to system limitations.
Interior design/furniture. Obligate on VA Form 2237/PO or Government purchase card.
Studies, such as environmental studies. These should be on contract, agreement, or MOU and obligated on VA Form 2237/PO. Note: This does not apply to research studies.
Registry for nursing services/temporary services. Obligated on VA Form 2237/PO or purchase card.
Headstones. Obligate on VA Form 2237/PO or Government purchase card.
Lab tests and blood products. These are individual contracts and single vendors; obligate on VA Form 2237/PO.
Demurrage for medical gas cylinders. Obligate contracted services on VA Form 2237/PO.
Contracts for medical services performed in a VA facility require the contractor to document services provided in the VHA CPRS package and Patient Encounter systems. As a result, obligation of funds for services provided in a VA facility should be made on VA Form 2237/PO, not on a VA Form 1358 for payment through the VistA Fee software package.
Convenience checks. Obligate on VA Form 2237/PO. Refer to Volume XVI Chapter 1C, Government Convenience Checks.
Limited Open Travel Authority. Enter into the travel system.
Local Travel Under the Manual Threshold (former authority code 4). Enter into the travel system.
No Longer Used (Formerly Emergency Care Beneficiary Travel, Including Mileage) (former sub-authority code 3E). Use sub-authority code 2F (Non-Contract Emergency Travel).
Undefined (former sub-authority code 3R). Use appropriate authority code.
NCA Burial Receptacles (former authority code 13). Use sub-authority code 13A (Outer Burial Receptacles).
Inter-Library Loan Program (formerly authority code 6). Administration forecasting and analysis should be done to determine if a contract is appropriate in order to preclude splitting requirements. Delivery/task orders will be done by contracting officers or ordering officials appointed by contracting officers. If this analysis determines that the requirement (based on annual figures) is less than the micro-purchase threshold, then the purchase card, not a contract, must be used. A convenience may be used for up to $5,000 for vendors who do not accept a purchase card or EFT.
Training programs in excess of the micro-purchase threshold specifically created or tailored to VA must be routed via a 2237 through the contracting office.
Fees imposed by States for reviews of professional certifications of medical staff to ensure accreditation in the State (formerly included as part of sub authority code 20A). Organization forecasting and analysis should be done to determine if a contract is appropriate in order to preclude splitting requirements. Delivery/task orders will be done by contracting officers or ordering officials appointed by contracting officers. If this analysis determines that the requirement (based on annual figures) is less than the micro-purchase threshold, then the purchase card, not a contract, must be used. A convenience check may be used for up to $5,000 for vendors who do not accept a purchase card or EFT.
Special Adaptive Housing (SAH) inspections are reviews of properties for compliance with SAH requirements for grants by VA to Veterans or Servicemembers who have specific service-connected disabilities for the purpose of constructing an adapted home or modifying an existing home (formerly authority code 22). Either a contract or the purchase card, if less than the micro-purchase threshold, must be used.
State Home Program (formerly part of authority code 20) obligations are no longer processed in VistA. VA Form 1358 is not used for this program, since obligations now occur directly in FMS and payment is processed in IPPS.
VBA Lease Agreement Overtime Charges (authority code 14) obligations are now being processed in iFAMS and must follow VA Financial Policy – Non-Contractual Obligations.

Appendix C: VA Form 1358 Required Information

A. The following information is required for use of a VA Form 1358 entered in IFCAP. This guidance is applicable to 1358 obligations established under both Appendix A and Appendix D of this policy.

Purpose Field: 1358 Approved Use	Specific purpose (mandatory field). Refer to section C for a complete listing of approved uses as identified in Appendix A.
Period of Performance	Start and End Dates
Vendor Field	Vendor name and address. Not required for multiple vendors.
Contract Number Field	Contract number only required when a contract is associated with a vendor and the system allows the format⁸. If a contract number does not fit the format, enter it in the Description field. Not required for multiple vendors or when exception designates a single vendor and a regulatory authority, e.g., HISA, Prosthetics.
Description/Justification Field	Description of service/product being received or ordered. Multiple vendors (if applicable). Referenced order, obligation, or contract number, when required and if not included in Contract Number field.

B. The following information is required for a manual VA Form 1358.

Vendor Field	Vendor name and address. Not required for multiple vendors.
Contract Number Field	Referenced contract, order, or obligation number, when required. Not required for multiple vendors or when exception designates a single vendor and a regulatory authority, e.g., HISA, Prosthetics.
Purpose Field Description/Justification Field	Approved use (mandatory). Refer to section C below for a complete listing of approved uses as identified in Appendix A. Description of service/product being received or ordered. Specific period of performance (start and end dates.) Multiple vendors (if applicable).

C. Updated listing of approved uses as identified in IFCAP (based on Appendix A.) The items below may not be reflective of what is programmed in IFCAP. The following list should be used where differences occur.

Authority	Sub-Authority	Approved Use
1		Nursing Homes/Adult Day Health Care (Permitted only as specified in Appendix D)
1	A	– Nursing Home
1	B	– Adult Day Health Care
2		Community Care (formerly Non-VA Medical Care) Program (Permitted only as specified in Appendix D)
2	A	– Community Care (formerly Non-VA Medical/Dental Care) (pre-authorized)
2	B	– Community Care (formerly Non-VA Medical/Dental/Emergent Transportation (no prior authorization)
2	C	– Homemaker/Home Health Aid
2	D	– Community Care (formerly Non-VA Hospitalization (pre-authorized)
2	E	– Community hospitalization (formerly Non-VA Hospitalization (no prior authorization)
3		Standardized Obligations
3	A	– Federal Telecommunications Services (FTS) 2001
3	B	– College of American Pathology/Joint Pathology Center
3	C	– Convenience Check Fees
3	D	– Denver Acquisition and Logistics Center Services and Supplies
3	E	– Supply Fund: Strategic Acquisition Center
3	F	– SmartPay (US Bank) and National Patient-Centered Community Care (PC3) Centralized contract administrative fees
3	G	Federal Employees Compensation Program
3	H	SHPS
3	I	Standard Level User Charges/GSA/NARA
3	J	Transit Benefits
3	K	Franchise Fund: Security and Investigations Center
3	L	Franchise Fund: Law Enforcement Training Center
3	M	Franchise Fund: Financial Services Center
3	N	Franchise Fund: Debt Management Center
3	O	Franchise Fund: IT Infrastructure Operations
3	P	Franchise Fund: Records Center and Vault
3	R	Supply Fund: Technology Acquisition Center
4		Standardized Obligations Supply Fund: National Acquisition Center
5		Research Studies/Royalty Payments
6		Disabled: Not a Valid Code
7		Affiliated Agreements for Interns/Residents
8		Tort Claims/EEO Settlements/OIG Confidential Services and Investigative Purchases
9		Volunteer and Resident Meal Tickets, Volunteer Reimbursement, Honoraria, and Stipends
10		Incentive Therapy/Compensated Work Therapy
11		Beneficiary Travel and Direct Payments to Veterans from General Post Fund
12		Home Improvement Structural Alterations
13		Disabled: Not a Valid Code
13	A	– Outer Burial Receptacles
13	B	– Dignified Burial Casket/Urn
14		Disabled: Not a Valid Code
15		Home Oxygen and Eyeglass Fabrication
16		Prosthetics – New or Repaired Items
17		Pharmacy/Subsistence Prime Vendors Consolidated Mail Order Pharmacy (CMOP) Direct-to-Patient (DPT) Program
18		Regulated Utilities
19		Reimbursements to VA Employees or Students; Employee Training, Scholarships, Tuition, Training, OIG Emergency Purchases – Professional Liability Insurance (50% of cost) not to exceed $150 -Continuing Professional Education not to exceed $1,000 for those occupations identified in 38 U.S.C. § 7411 – Certificates or certification licenses required by VA employees to perform their duties (e.g., pesticide application) – Self-certified transit benefit and bicycle benefits per VA Volume XV, Chapter 6A – Employee training reimbursements not included in Statutorily Authorized Scholarships, Health Professionals Educational Assistance Programs, and Academic Degree Programs – Employee training paid to training providers – Direct payments to Universities, Colleges, or Other Professional Schools for statutorily authorized scholarship programs, paid on behalf of employees and students – OIG Emergency Purchases – Education Debt Reduction Program – Vaccination or testing required for official travel or official business – Eyeglasses or lenses required for a workplace Visual Display Terminal (VDT) -Required or offered medical or psychiatric examination or psychological assessment -Obtaining maintenance services without the GSA Fleet Service Card in limited emergency circumstances – Claims under the Military Personnel and Civilian Employees’ Claims Act – Miscellaneous Travel Expenses
20		Non-Procurement Obligations
20	A	– One VA Plus Fund, Agent Cashier Bank Service Charges, legacy EUL payments, PACT Act Buy-Out of Service Contracts, Witness Fees to Non-Federal Employees, Overpayment Audit Recoveries, Prize Competitions, Land Acquisitions
20	B	– Compensated Work Therapy Program
20	C	– Internal VA Programs and Agreements
20	D	– VA Homeless Providers Grant and Per Diem Program
20	E	– Cemetery Grants and other VA Grant Programs
20	F	– GSA Activities and TOP Fees
20	G	– Government Printing Office
20	H	Inter-Agency Sharing Agreements (VA/DOD/IHS/THP Sharing) and Interagency Agreements (USPS)
20	I	Intra-Agency Sharing Agreements (VHA, VBA, NCA, OIT)
20	J	Intergovernmental Personnel Agreements and Services, including CASUs
21		Caregiver Support Program – Caregiver Stipend, Respite, and Oversight programs
21	A	– Disabled: Not a Valid Code
21	B	– Disabled: Not a Valid Code
21	C	– Disabled: Not a Valid Code
21	D	– Disabled: Not a Valid Code
21	E	– Disabled: Not a Valid Code
22		Disabled: Not a Valid Code
23		State Approving Agency

Appendix D: Obligation at Claims Approval Programs

This section describes VHA’s process/procedure for recording Obligation at Claims Approval obligations in FMS. The full Obligation at Claims Approval policy can be found in VA Financial Policy Volume III, Chapter 3 – Obligation at Claims Approval.
The majority of Obligation at Claims Approval categories of care no longer require a 1358 to be established in IFCAP. There are still a few instances in which a 1358 is required to be set up in FMS in order for approved payments to be recorded in FMS.
Prior to, or at the beginning of each FY:
1. The VHA Finance Office will issue guidance detailing the specific categories of care and providing the associated obligation numbering schema. This schema will identify obligations that require the station to set up a 1358 in IFCAP and which obligations do not require a 1358 and will be established directly into FMS by the VHA Finance Office.
2. Annually for each category of care operating under the Obligation at Claims Approval authority, FMS requires an obligation to be established to create the line of accounting to record obligations at the time of claim approval. The VHA Finance Office operates under two processes in which to establish obligations:
  - The VHA Finance Office will establish an obligation directly in FMS for $0.01 for categories of care that do not require a 1358.
  - For categories of care requiring an IFCAP 1358, the VHA Finance Office will identify these for the station to set up for $1.00. These transactions will transmit to FMS to establish the amount and line of accounting in FMS.
Funds (budgets) are managed and legal obligations recorded in FMS for Obligation at Claims Approval categories of care.

Appendix E: VA Form 1358

VA Forms website ()

VA Form 1358 Obligation or Change in Obligation

Appendix F: Previous Policy Revisions

Section	Revision	Office	Date
0602	Added references to Appendix D for Community Care medical obligations Removed the authorization to use “Miscellaneous Vendor” on VA Form 1358, with limited exceptions	OFP (047G)	March 2020
0603	Added definition for Obligate at Claims Approval	OFP (047G)	March 2020
0605	Added references to Appendix D for Community Care medical obligations	OFP (047G)	March 2020
0609	Moved previous policy revisions table to a new Appendix F	OFP (047G)	March 2020
Appendix A Appendix C	Added references to Appendix D for Community Care medical obligations	OFP (047G)	March 2020
Appendix A	Strengthened controls over the use of “Miscellaneous Vendors” for each approved use	OFP (047G)	March 2020
Appendix A Appendix B	Reinstated the approved use #18 for regulated utilities, in accordance with FAR and VAAR deviation	OFP (047G)	March 2020
Appendix A Appendix B	Moved Special Adaptive Housing Inspections from 1358 approved use to invalid use	OFP (047G)	March 2020
Appendix A	Revised Use #19 to include training and scholarship payments paid by VA directly to educational institutions. Added internal controls for individual training requests over $10,000 and $25,000.	OFP (047G)	March 2020
Appendix B	Clarified the Invalid Uses of VA Form 1358 for General Post Funds and Payments made to educational institutions or training providers on behalf of employees or students	OFP (047G)	March 2020
Appendix B	Removed previous Invalid Use #26 (payments made directly by VA to educational institutions) to be consistent with revisions to Appendix A, Use #19 (Training and Tuition payments)	OFP (047G)	March 2020
Appendix D	Added procedures for VHA Community Care medical obligations	OFP (047G)	March 2020
Appendix E	Moved previous policy section Appendix D to Appendix E	OFP (047G)	March 2020
060205	Modify to read: After approval and prior to the purchase of goods or services, the respective budget and/or finance office will be responsible for verifying that funds are available and authorized, and ensuring the obligation is recorded in the financial system, when properly supported in accordance with the requirements of this chapter, including sections 060202 through 060205.	003A2A	July 2018
060205	Update reference from Online Certification System (OLCS) to Invoice Payment Processing System (IPPS).	42C	July 2018
060205	Change the legal reference in footnote two to: Matter of: Coast Guard–Electronic Certification Procedures, B-302789, July 6, 2005.	023	July 2018
060205	Change: references from delegated to authorized.	047G	July 2018
060207	Delete: The Office of Internal Controls (OIC) may include reviews of 1358 obligations to ensure compliance with this chapter as indicated in the Annual Review Plan approved by the VA CFO.	047B1	July 2018
060404	Delete: OIC is the VA CFO’s primary quality assurance organization providing oversight of Department financial management, capital asset management, and logistics activities. OIC is responsible for conducting periodic reviews of VA Form 1358 usage to ensure compliance with this chapter as indicated in the Annual Review Plan approved by the VA CFO.	047B1	July 2018
060501	Delete: The 1358 will not be used for any other purposes. Add: The 1358 is purely a financial action and shall not be used as any type of contract or agreement document, i.e., establishing a contract or as an invoice payment method. Terms and conditions of the contract take precedence over these procedures.	003A2A	July 2018
060502	Add: Where the obligation is for a contract, agreement, or order in place, increases over the obligation amount must have funds verified, the Contracting Officer should be notified, and upon issuance of a modification to a contract, the obligation may be increased.	003A2A	July 2018
060504	Add: Using a 1358 as an obligation document only.	003A2A	July 2018
060504	Modify verbiage to state: The contracting official is responsible for ensuring the appropriate information is requested, the obligation is tied to the contracting method, and is appropriately submitted to FPDS.	003A2A	July 2018
060601	Add: Honoraria. Voluntary payments to a person for a service for which a fee is not legally or traditionally required. VA policy, Volume II, Chapter 7B, Honoraria, allows for honoraria payments, not to exceed $100, provided that the payments are not of a significant nature, enforceable by law, and are used as more of a thank you or an expression of appreciation for voluntary services received.	047G	July 2018
060604	Add: Stipends. Fixed sums of money paid periodically for services or to defray expenses. A stipend is distinct from a salary payment because it does not represent payment for work performed, but rather is payment for a role that is normally unpaid or which cannot be measured in terms of a task. 41 CFR 101 allows compensation and expense reimbursement of advisory committee members, staffs, and consultants up to the maximum GS-15 daily rate unless approved by the SECVA.	047G	July 2018
Appendix A	Add to authority code 2: FAR 32.702 requires that funds must be verified/approved prior to contract award.	003A2A	July 2018
Appendix A	Add to authority code 3: Supply Fund: Strategic Acquisition Center (SAC).	003A2A	July 2018
Appendix A	Add to authority code 3: Supply Fund: Technology Acquisition Center (TAC).	003A2A	July 2018
Appendix A	Change authority code 4 to: Standardized Obligations Supply Fund: National Acquisition Center (NAC)	003A2A	July 2018
Appendix A	Change authority code 6 to: Disabled: Not a Valid Code.	047J	July 2018
Appendix A	Change authority code 9 to: Volunteer and Resident Meal Tickets, Volunteer Reimbursement, Stipends, and Honoraria.	047A	July 2018
Appendix A	Add to authority code 9: Honoraria are voluntary payments to a person for a service for which a fee is not legally or traditionally required. VA policy, Volume II, Chapter 2, Honoraria, allows for honoraria payments, not to exceed $100, provided that the payments are not of a significant nature, enforceable by law, and are used as more of a thank you or an expression of appreciation for voluntary services received. Stipends are fixed sums of money paid periodically for services or to defray expenses. A stipend is distinct from a salary payment because it does not represent payment for work performed, but rather is payment for a role that is normally unpaid or which cannot be measured in terms of a task. 41 CFR 101 allows compensation and expense reimbursement of advisory committee members, staffs, and consultants.	047J	July 2018
Appendix A	Change authority code 18 to: Disabled: Not a Valid Code.	047J	July 2018
Appendix A	Change authority code 19, deleting: Tuition expenditures made on behalf of an employee or scholarship recipient and paid directly to a vendor may also be made on VA Form 1358.	047J	July 2018
Appendix A	Change sub authority code 20A to reflect the disallowed 1358 use for: Fees imposed by States for reviews of professional certifications of medical staff to ensure accreditation in the State.	047J	July 2018
Appendix A	Updated authority code 22 hyperlink to 38 U.S.C. 2101, Acquisition and Adaption of Housing Eligible Veterans.	003A2A	July 2018
Appendix B	Add: Inter-Library Loan Program (former authority code 6). Administration forecasting and analysis should be done to determine if a contract is appropriate in order to preclude splitting requirements. Delivery/task orders will be done by contracting officers or ordering officials appointed by contracting officers. If this analysis determines that the requirement is less than the micro-purchase threshold, then the purchase card, not a contract, must be used. A convenience check may be used for up to one-half of the micro-purchase threshold, for vendors who do not accept a purchase card or EFT.	047J	July 2018
Appendix B	Add: Regulated Utilities (formerly authority code 18). All regulated utilities will be routed through contracting, which will determine the appropriate contracting method. VA Form 90-2237 will be used to request regulated utilities and obligations will be recorded via VA Form 90-2138.	047J	July 2018
Appendix B	Add: Payments made directly by VA to educational institutions or training providers on behalf of employees or students (formerly included as part of authority code 19). Organization forecasting and analysis should be done to determine if a contract is appropriate in order to preclude splitting requirements. Delivery/task orders will be done by contracting officers or ordering officials appointed by contracting officers. If this analysis determines that the requirement (based on annual figures) is less than the micro-purchase threshold, then the purchase card, not a contract, must be used. A convenience check tied to the purchase card may be used for up to one-half of the micro-purchase threshold, for vendors who do not accept a purchase card or EFT. Employees must agree in writing that it they do not successfully complete the course; they will incur a federal debt and a bill of collection will be issued to them.	047J	July 2018
Appendix B	Add: Fees imposed by States for reviews of professional certifications of medical Staff to ensure accreditation in the State (formerly included as part of sub-authority code 20A). Organization forecasting and analysis should be done to determine if a contract is appropriate in order to preclude splitting requirements. Delivery/task orders will be done by contracting officers or ordering officials appointed by contracting officers. If this analysis determines that the requirement is less than the micro-purchase threshold, then the purchase card, not a contract, must be used. A convenience check may be used for up to one-half of the micro-purchase threshold for vendors who do not accept a purchase card or EFT.	047J	July 2018
Appendix C	Change: Sub-authority code 3E to: Supply Fund: Strategic Acquisition Center.	003A2A	July 2018
Appendix C	Change: Sub-authority code 3R to: Supply Fund: Technology Acquisition Center.	003A2A	July 2018
Appendix C	Change: Authority code 4 to: Standardized Obligations Supply Fund: National Acquisition Center.	003A2A	July 2018
Appendix C	Change authority code 6 to: Disabled: Not a Valid Code.	047J	July 2018
Appendix C	Change authority code 18 to: Disabled: Not a Valid Code.	047J	July 2018
Appendix C	Change authority code 19 to: Reimbursements to VA Employees or Students.	047J	July 2018
Appendix C	Change sub authority code 20A to: One VA Plus Fund and Agent Cashier Bank Service Charges.	047J	July 2018

VA Form 1358 will not be used in iFAMS. Instead, iFAMS utilizes document types to categorize each accounting transaction. See Volume III, Chapter 5A, Non-Contractual Obligations policy for additional information. ↩
Due to system constraints and costs for modifying IFCAP, IFCAP may not be updated to reflect modifications or clarifications to the approved uses listed in Appendices A, C or D. See Volume III, Chapter 5A, Non-Contractual Obligations policy for additional information. ↩
The role of approving payments for individual invoices, as accomplished in the VistA Fee system or IPPS, is not to be confused with the role of a certifying officer at the VA Financial Services Center (FSC) in Austin, TX, who approves a schedule of payments transmitted to Treasury. The FSC certifying official who approves a schedule of payments transmitted to Treasury for disbursements is 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, not the individual vouchers (see Matter of: Coast Guard–Electronic Certification Procedures, B-302789, July 6, 2005). Accordingly, the role performed by the FSC is not the same as the role of “approving payment” noted in this policy. The “approving payment” role noted in this policy is the official who approves payment in the VistA Fee system, IPPS, or other subsidiary payment system used by VA. ↩
In pharmacy, the Contracting Officer (from the National Acquisition Center) approves the Ordering Officer, who in turn places orders with the prime vendor. When an Ordering Officer establishes the 1358, he or she is barred from performing other segregation of duty functions, but may receive/certify orders placed by other ordering officers. ↩
Per Public Law 106-58, dated September 29, 1999, professional liability insurance premiums are one-half the cost incurred, not to exceed $150. For managers and supervisors, refer to Section 7103(a) of Title 5, and for law enforcement officers, refer to Section 8331(20) or 8401 of Title 5 or Section 4823 of Title 22. ↩
The employee is responsible for submitting a signed application accompanied by proof of payment. ↩
Refer to Volume I Chapter 11, Intragovernmental Transactions. ↩
Integrated Funds, Distribution, Control Point Activity Accounting and Procurement (IFCAP) only brings up the contract number field when a single vendor is input and must be entered in a set format. Also, unless the contract is completed through IFCAP, the contract number may not fit the format. Regulatory authorities cannot be entered in this field. ↩

Chapter 02B – 1358 Obligations

Chapter 02B – 1358 Obligations

0201 Overview

0202 Policies

A. Requesting the 1358 obligations.

B. Approving the 1358 obligation.

C. Recording the obligation of funds.

D. Certifying the receipt of goods or services and approving payment.

E. Periodic Review of 1358 Obligations.

0203 Authority and References

0204 Roles and Responsibilities

0205 Procedures

0206 Definitions

0207 Rescissions

0209 Revisions

Appendix A: VA Form 1358 Approved Uses

Appendix B: Invalid Uses of VA Form 1358

Appendix C: VA Form 1358 Required Information

Appendix D: Obligation at Claims Approval Programs

Appendix E: VA Form 1358

Appendix F: Previous Policy Revisions

Footnotes

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