Questions concerning this policy chapter should be directed to:

• Veterans Health Administration
• Veterans Benefits Administration
• National Cemetery Administration
• Debt Management Center
• Financial Services Center
• Construction and Facilities Management
• All others

0601 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policies regarding the creation, execution, administration, accounting, and reporting of buy/sell transactions. Although G‑Invoicing was mandated for all Federal Program Agencies (FPAs) by October 1, 2022, some of VA’s Trading Partners have not yet met this requirement, so VA must continue using the legacy paper IAA process until those partners fully transition to G‑Invoicing, as outlined in the External Agency Implementation and Timeline.

For information on the accounting and reporting of other types of IGTs, refer to VA Financial Policy Volume IX, Chapter 5, Intragovernmental Transactions. For information on Treasury G-Invoicing Buy/Sell agreements refer to VA Financial Policy Volume IX, Chapter 7, Buy/Sell Transactions (G-Invoicing).

Key points covered in this chapter:

• VA will comply with statutory and regulatory requirements when entering into IAAs;
• VA will adhere to Treasury’s guidance on IAAs;
• VA will not perform work and/or make any payment before the IAA is officially executed;
• VA will review, approve, execute, and retain IAAs and related modifications;
• VA will submit all IAAs and modifications to the appropriate document repository to include acquisition and non-acquisition assisted;
• VA will record accurate accounting entries for buy/sell activities, perform regular reconciliations, and resolve reconciliation differences in accordance with Treasury’s guidance; and
• VA will close out IAAs in a timely manner.

0602 Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various	Full Review	OFP	Ensure continued alignment with Treasury, OMB, and VA policies	September 2026
0605	Formatting and editorial adjustments	OFP	Strengthen readability without altering underlying policy requirements	September 2026
0606	Updated citations and references to TFM 4700, VAAR Subpart M817.5 and other governing authorities	OFP	Reflect the most current statutory and regulatory guidance	September 2026
Appendix D & E	Consolidated all deobligation criteria into a single reference chart.	OFP	To streamline guidance and improve usability by presenting all deobligation criteria in one consolidated chart.	September 2026

For a complete listing of previous policy revisions, see Appendix A: Previous Policy Revisions

0603 Definitions

Advances – Cash outlays made by a Federal entity prior to receiving agreed upon goods and/or services.

Assisted Acquisition – A type of interagency acquisition where a servicing agency performs acquisition activities on a requesting agency’s behalf, such as awarding and administering a contract, task order, or delivery order.

Buy/sell Transaction – Transactions that occur between two Federal entities where goods or services are purchased by one entity from another entity. This arrangement is accomplished through the issuance of a reimbursable agreement (i.e., G-Invoicing platform, or Treasury Form 7600(A)(B)) between the two entities. Trading partners must have appropriate statutory authority (e.g., Economy Act), prior to engaging in an agreement for buy/sell transactions.

Federal Intra-governmental Data Standards (FIDS) – Data elements that form the foundation of the intra-governmental buy/sell process.

General Terms and Conditions (GT&C) –The section of an IAA that identifies the buyer and seller involved, the authority for the agreement, required actions, period of performance, and type (i.e., single order or multiple order IAA).

G-Invoicing –Mandatory Treasury solution for buy/sell transactions that will allow Federal agencies to initiate payments and to manage the receipt and acceptance of GT&C, orders, and performance.

Inter or Intra-Agency Agreement (IAA) – A written agreement entered between Federal agencies (Inter), or organizational units within the same agency (Intra), establishing a relationship between a buyer and seller, which specifies the goods to be furnished or tasks to be accomplished.

Intra-Governmental Payment and Collection (IPAC) – Payment and collection transfer of funds across Federal Program Agencies (FPAs) for goods and services (i.e., buy/sell transactions), fiduciary transfers (i.e., investment and borrowing transactions), Federal employee benefits data and check aftermath activity.

Non-severable Services – Services that represent a single undertaking that, if not completed in full, would not provide the buyer with any value.

Order – Also known as the ordering instrument, is the funding section of an IAA, which includes the goods and/or services requirements, funding information, and authorized signatures to establish the obligation between the trading partners.

Period of Performance (POP) – The period of time specified by the IAA within which the terms and conditions of an IAA remain in full force and effect. This is also known as the start and stop date of an interagency agreement. Goods and services will not begin being delivered before the start date identified in the POP and will finish being delivered by the end date of the POP.

Requesting Agency – A Federal entity that requests goods or services from another Federal entity, also referred to as the buyer.

Severable Services – Services of a continuing or recurring nature, which may be funded on a fiscal year or on an incremental basis.

Servicing Agency –A Federal entity that is responsible for providing goods or services to another Federal entity, also referred to as the seller.

Trading Partner (TP) – A Federal entity that is party to Intra-governmental Transactions (IGTs) as either the buyer or the seller.

0604 Roles and Responsibilities

Administration and Staff Office Chief Financial Officers (CFOs) are primarily responsible for reviewing and signing IAA routing sheets for amounts greater than or equal to $25 million.

Financial Services Center (FSC) is responsible for reviewing, approving, accounting for, and retaining all of VA’s IAAs and related modifications. FSC is responsible for coordinating with program offices and accounting/budget offices to ensure the accuracy of accounting entries, performance of reconciliations, and resolution of reconciliation differences. FSC is also responsible for assigning agreement numbers on IAAs.

Accounting/Funding Officials (Buyer and Seller) are responsible for approval of the funding section of the Order and recording and adjusting entries associated with the IAA accounting events. The accounting/funding officials are also responsible for performing reconciliations and coordinating with program offices and FSC to resolve reconciliation differences.

Program Office (Buyer and Seller) is responsible for preparing the IAA documentation package; participating in the review, approval, execution, administration, and closeout of the IAA; and assisting in the recordation of accounting entries and the reconciliation process. This responsibility may be assigned to a designated official (i.e., local finance office, etc.) in part or in its entirety to complete.

Office of General Counsel (OGC) (Buyer or Seller) is responsible for providing legal review and concurrence on an IAA where applicable.

0605 Policies

060501 General Policies

1. When a Federal entity initiates a buy/sell transaction with another Federal entity, the initiating entity must determine that amounts are available, ordered goods or services cannot be provided by contract as conveniently or cheaply by a commercial enterprise, and that the buy/sell activity is in the best interest of the U.S. Government.
2. When Federal entities are involved in buy/sell activities with each other, they become trading partners (TPs) bound by the terms and conditions contained in an IAA. The Federal entity soliciting the goods and services will be referred to as the buyer and the Federal entity providing the goods and services will be referred to as the seller.
3. VA will comply with statutory and regulatory authorities and only enter an IAA in compliance with the following:
   1. The Economy Act (31 U.S.C. §1535 – §1536, and its associated regulation (Federal Acquisition Regulation (FAR) Subpart 17.5 Interagency Acquisitions) provides guidance for IAAs administered under this Statute.
      1. To reduce potential Antideficiency Act violations and to be compliant with the Economy Act, buyers and sellers will work together to deobligate any unused amounts prior to expiration of the appropriation.
      2. Buyers must monitor their IAAs regularly to ensure that the seller performs agreed-upon tasks timely to avoid any lapse of funding.
   2. Non-Economy Act
      1. Refers to all statutory authorities other than the Economy Act.
      2. Non-Economy Act related statutory authorities include, but are not limited to:
         • Medical Sharing Agreement, 38 U.S.C § 8153;
         • Government Employees Training Act (GETA), 5 U.S.C. § 4104;
         • Intergovernmental Personnel Act, 5 U.S.C. § 3371 et seq.;
         • Debt Collection Act, 5 U.S.C. § 5514(a)(2);
         • VA Supply Fund, 38 U.S.C. § 8121; and
         • VA Franchise Fund, Public Law 109-114.
   3. There are no specific requirements to deobligate unused amounts associated with Non-Economy Act orders prior to the expiration of the appropriation as long as the buyer has a bona fide need for goods or services and the seller is actively seeking to provide the goods and services.
4. VA will utilize an IAA to document all buy/sell activities between organizational units both within and outside of VA.
5. Grants, cooperative agreements, special purpose agreements and contracts between VA and non-Federal entities are not considered buy/sell transactions and are not processed via an IAA.
   1. Grants, cooperative agreements, and special purpose agreements are used for special purposes specifically authorized by law and are not for the acquisition of goods or services by the Federal Government. Refer to P.L. 95-224, 2 C.F.R. § 200.201 for additional details.
   2. Contracts between VA and non-Federal entities, such as state and local Governments for the purchase of goods and services will follow the requirements set forth in the FAR and VA Acquisition Manual.
6. VA will utilize Treasury standard forms 7600A General Terms and Conditions (GT&C) and 7600B Order for the IAA. Except for:
   1. Medical cost sharing IAAs with oversight by the Office of Integrated Veteran Care, in which case, Form 10-1245C can be used.
   2. Specific instances where business partner requirements by other agencies require the use of agency-specific forms (e.g., U.S. Government Publishing Office (GPO) Standard Form (SF) -1, General Services Administration (GSA) ordering portals).
7. VA will adhere to Treasury Financial Manual (TFM) Volume I, Chapter 4700 to divide the buy/sell process into four distinct phases: IAA initiation and GT&C; Order; Performance Transactions/Receipt and Acceptance; and Funds Settlement/IAA Closeout. Refer to Appendix B: TFM 4700 Buy/Sell IPAC & G-Invoicing Transaction Cycles for specific business and accounting events that occur in each phase. The following sections will exhibit VA’s policies based on the four phases.
8. Distinguishing between buy/sell transactions or cost sharing/reclassifications is dependent upon whether or not the office providing the service performs the service as short-term limited assistance or provides that service as a normal part of their business activity. If this is short-term limited assistance a buy/sell agreement is not required, if a normal part of business activity, then buy/sell agreement is required. See Appendix E: Personnel Cost Scenario for examples.

060502 IAA Paper Form Establishment Process

1. The essential steps for establishing an IAA are the same for Economy Act and Non-Economy Act orders; however, the differences apply to whether the IAA uses acquisition or non-acquisition assistance. VA must adhere to the FAR requirements for executing assisted acquisition IAAs. For requirements related to acquisitions and accounting, refer to VA Acquisition Manual Subpart M817.5 Interagency Acquisitions.
2. To begin the IAA establishment process, the buyer’s program office will conduct research and analyses such as market research and or develop an independent cost analysis unless the legal authority directs VA to participate in the buy/sell transaction. The research and analysis will determine whether conducting the proposed buy/sell activity with another Federal entity would be in the best interest of the Government.
3. After a determination has been reached that an IAA with another Federal entity is in the best interest of the Government, the buyer’s program office will work with the potential seller to develop the agreement.
4. After confirming with the potential seller that it has the capability and capacity to enter into the proposed IAA, then the buyer will begin negotiating the proposed IAA with the seller. If VA is the seller, then VA must obtain verification of proper and adequate reimbursable authority from the accounting/budget office and determine the ability to provide or produce items or services prior to entering into any agreement with the buyer.
5. The buyer’s program office will obtain a cost estimate from the seller and consult with the buyer’s accounting/budget office to verify the funding availability. If the funds are under the constraint of a continuing resolution, the buyer will identify the funding restriction and denote it in the IAA. In addition, there are special rules of funds control for different types of services as follows:
   1. The funds available to pay for services in one fiscal year are not available to pay for services in the following fiscal year unless the services are non-severable or otherwise authorized by law.
   2. For non-severable services, only the funding available in the fiscal year when the services begin will be used for the duration of the IAA’s POP. Funding available in subsequent fiscal years cannot be used for payment or reimbursement of the services.
   3. In accordance with 41 U.S.C. § 3902, severable services funding may be obligated for up to 12 months and may cross fiscal years. Each option period exercised starts a new order and 12-month POP.
6. After the buyer and the seller concur on the details of the IAA, the authorized personnel on both sides will review, approve, and sign the GT&C (e.g., Form 7600A) and Order (e.g., Form 7600B).
   1. An IAA form will contain the GT&C and the order(s). The GT&C will be reviewed and approved by the buyer and the seller prior to the Order being completed. Signatures are required from all parties involved in a buy/sell transaction before any goods or services are received or reimbursements made with another Federal entity.
   2. Information documented in the GT&C and order(s) includes data elements that form the foundation of the buy/sell process. IAAs will conform with Treasury requirements and contain all data elements specified by Treasury. The Treasury Fiscal Service Data Registry is an authoritative reference for the Federal Intragovernmental Data Standards (FIDS).
   3. VA’s program office or designee will ensure the appropriate reviews of the IAA package prior to signing the IAA. Program Officials will utilize the Routing Cover Sheet (see Appendix C) to manage the review and approval process and ensure IAAs are reviewed and approved by the appropriate office. Below are the additional reviews prior to IAA signature:
      1. FSC will perform an initial review of the IAA, assign an IAA number and sign routing sheet;
      2. OGC, if applicable (i.e., All Economy Act interagency acquisitions with $250,000 or more in life cycle costs, and all interagency acquisitions with $750,000 or more in life cycle costs, require OGC review and concurrence);
      3. Other applicable reviews if required (per internal Directives and Handbooks);
      4. Chief Information Officer (CIO) or designee, if applicable will review the IAA and sign the routing sheet;
      5. Administration and Staff Office CFO’s will review all IAAs ≥ $25M threshold and sign routing sheet; and
      6. FSC will perform a final review of the IAA and sign the routing sheet.
   4. IAA Routing Cover sheet will be reviewed and signed based on the below threshold amounts. Treasury form 7600 separates the GT&C (Form A) and Order (Form B). The routing sheet review and approvals will be completed for Treasury 7600(A)(B) agreement forms.
      1. GT&C
         1. Program Official
            • Greater than or equal to $25 million will require review from the SES responsible for overseeing the program office or his/her designated official and signature on the routing sheet.
         2. Administration and Staff Office CFO’s
            • Greater than or equal to $25 million will require review and signature on the routing sheet.
         3. Local Program and Finance Office Official
            • After receiving the appropriate routing sheet signatures, will sign the routing sheet and GT&C.
      2. Order
         1. Program Official
            • Less than $5 million will require review and signature on routing sheet and order (recommend GS12 or higher-level employee perform this approval).
            • Greater than or equal to $5 million will require review and signature on routing sheet and order (recommend GS13 or higher-level employee perform this approval).
         2. Local Finance
            • Less than $5 million will require review and signature on routing sheet and order (recommend GS12 or higher-level employee perform this approval).
            • Greater than or equal to $5 million will require review and signature on routing sheet and order (recommend GS13 or higher-level employee perform this approval).
   5. Every order must be sent to FSC, who will assign an IAA number. FSC will also conduct the initial review. The IAA number is an essential element that connects orders to obligation documents and is used and referenced in the reconciliation process. The IAA number will also allow the FSC to monitor the IAAs that have not been completed.
   6. The agreement is not valid until it is signed by both parties.
   7. All signed buy/sell IAAs must be uploaded into the appropriate document repository (e.g., FMS users will send agreements to FSC for upload into the IAA repository; iFAMS users will upload agreements into iFAMS), to include:
      • Economy or non-Economy Act agreements; and
      • assisted acquisition and non-assisted acquisition agreements.
   8. If FSC finds issues with the signed IAA, they will return the IAA to the program office or designee to address the concern.
   9. Exemptions from uploading into the repository include:
      • General Services Administration (GSA) Motor pool, Supply, and Telephone; and
      • Postage.
   10. Any changes to an IAA after it has been signed and approved must be amended, signed, and uploaded into the repository

060503 IAA Paper Form Administration

1. VA will assign Program Officials or designees to lead the administration process from the inception of the buy/sell activity.
2. VA will not perform work and/or make any payments before the IAA is officially executed.
3. Upon the execution of an IAA:
   1. The seller will:
      1. Start working on the ordered goods and services;
      2. Record an unfilled customer order/undelivered order and anticipated reimbursements; and
      3. If an advance is utilized, record the advance as a liability.
   2. The buyer will:
      1. Obligate the funds based on the IAA; and
      2. If an advance is utilized, record an asset for the advance.
4. During the POP of the IAA:
   1. The seller will:
      1. Manage the fulfillment of the IAA, including, but not limited to:
         • Overseeing the performance of the seller and/or the contractor;
         • Monitoring goods and services delivery and receipt status to conform with the POP start and stop date;
         • Resolving performance/compliance issues and disputes;
         • Negotiating and signing modifications to the IAA, when necessary; and
         • Initiating the closeout process.
      2. Will make funding adjustments based on authorized modifications, when applicable;
      3. After the goods and services are accepted, will accrue revenue, record receivables, validate the expense, and complete the billing request; and
      4. After the bills are verified and approved by the buyer:
         • Recognize the cash receipts and collected reimbursements;
         • Process all IPAC transactions in accordance with Treasury’s cut-off dates. Payments/collections can be processed by either party as determined by the order within the IAA. All IPAC transactions must include the IAA or obligation number as specified in the IAA.
         • Ensure the appropriate IGT sub-category data element was used to accurately categorize the transaction. This includes:
         • Buy/Sell;
         • Expenditure Transfer – Non-Exchange;
         • Benefits;
         • Custodial Transfer – Non-Exchange;
         • Custodial Transfer – Exchange;
         • Capital Transfer;
         • Investments;
         • Borrowings; and
         • Other/Miscellaneous
   2. The buyer will:
      1. Manage the fulfillment of the IAA, including, but not limited to:
         • Ensuring contract expectations are being met by the seller and/or the contractor;
         • Monitoring goods and services delivery and receipt status to conform with the POP start and stop date;
         • Resolving performance/compliance issues and disputes;
         • Negotiating and signing modifications to the IAA, when necessary; and
         • Initiating the closeout process.
      2. Make funding adjustments based on authorized modifications, when applicable;
      3. Record a monthly accrual for expenses incurred but not invoiced or paid;
      4. After the goods and services are accepted, will liquidate the advance payments (if applicable), recognize service expense/received goods, record payables, and review the billing documents;
      5. After the bills are verified and approved:
         • Record disbursements and process payments based on the agreed payment schedule;
         • Process all IPAC transactions in accordance with Treasury’s cut-off dates. Payments/collections can be processed by either party as determined by the order within the IAA. All IPAC transactions must include the IAA or obligation number as specified in the IAA.
         • Record reimbursements in the “reimbursable” funds established for these collections; and
         • VA will perform a regular reconciliation process to ensure the accuracy of transactions. Refer to the following policy item C for the reconciliation process.
5. Reconciliation:
   1. The seller will:
      1. Reconcile buy/sell transactions to ensure accounting entries are correct in their systems during the POP and as a part of closeout;
      2. Comply with Treasury’s requirement to reconcile transactions, which include:
         • seller’s accounts receivable vs. buyer’s accounts payable;
         • seller’s unearned revenue/liability from buyer vs. buyer’s advance to seller; and
         • seller’s revenue vs. buyer’s expenses/capitalized purchases;
      3. Perform reconciliation on a monthly basis;
      4. Resolve reconciliation differences in a timely manner to ensure the accuracy of VA’s quarterly consolidated financial statements, which are certified by the CFOs of the Administrations and Staff Offices; and
      5. Document reconciliation differences using the IAA agreement number and order number.
   2. The buyer will:
      1. Reconcile buy/sell transactions to ensure accounting entries are correct in their systems during the POP and as a part of closeout;
      2. Comply with Treasury’s requirement to reconcile transactions, which include:
         • buyer’s accounts payable vs. seller’s accounts receivable;
         • buyer’s advance to seller vs. seller’s unearned revenue/liability from buyer; and
         • buyer’s expenses/capitalized purchases vs. seller’s revenue;
      3. Perform reconciliation on a monthly basis;
      4. Resolve reconciliation differences in a timely manner to ensure the accuracy of VA’s quarterly consolidated financial statements, which are certified by the CFOs of the Administrations and Staff Offices; and
      5. Document reconciliation differences using the IAA agreement number and order number.
   3. As required by Treasury, FSC will communicate with other Federal agencies as timely as possible, but no less than quarterly, to address and resolve reconciliation differences.
   4. If the reconciliation differences with other Federal agencies cannot be resolved timely, FSC will comply with Treasury’s requirements for developing Root Cause/Corrective Action Plans (CAP) and the Dispute Resolution Process. Refer to Volume IX, Chapter 5, Intragovernmental Transactions, for detailed information.
6. VA will start the close-out process when the IAA reaches the end of its POP. Refer to Volume III, Chapter 2 – Obligations, for guidance on periodic review of open and stale obligations. If there are justifying circumstances that prevent the closeout, VA will document the reasons/basis for non-closure and continue collaborating with its TPs to resolve any issues.
   1. The seller will:
      1. Ensure the IAA is satisfactorily completed, and final payment has been made;
      2. Return any unobligated or unused funding to the buyer if an advance was processed relative to the IAA. Specific to Economy Act IAAs, the return should be performed prior to the expiration of the fund’s availability;
      3. Close and deobligate any open third-party contracts;
      4. Complete the review, approval, and documentation process for IAA closure based on agreed-upon procedures;
      5. Deobligate the excess funding according to authoritative requirements. Economy Act orders will be deobligated to the extent that the agency or office filling the order has not incurred obligations by either providing the goods or services or have awarded a contract before the end of the period of availability of the appropriation. Refer to 31 U.S.C. § 1535. Non-Economy Act orders will be deobligated to the extent possible, particularly to return funding to no-year funds when third-party contracts are closed and deobligated. Refer to Volume III, Chapter 2, Obligations Policy, for reconciling open obligations.
      6. Refer to Appendix D: Deobligating Funds in an Economy Act IAA for deobligating funding on an IAA for Severable and Non-severable services under the Economy Act.
      7. Close the IAA in their procurement/acquisition systems and/or accounting and financial systems; and
      8. File all IAA-related documents according to the documentation retention requirements.
   2. The buyer will:
      1. Ensure the IAA is satisfactorily completed, and final payment has been made;
      2. Seek the return of funding from the seller, if an advance was processed relative to the IAA. Specific to Economy Act IAAs, the return should be performed prior to the expiration of the fund’s availability;
      3. Close and deobligate any open third-party contracts;
      4. Complete the review, approval, and documentation process for IAA closure based on agreed-upon procedures;
      5. Deobligate the excess funding according to authoritative requirements. Economy Act orders will be deobligated to the extent that the agency or office filling the order has not incurred obligations by either providing the goods or services or have awarded a contract before the end of the period of availability of the appropriation. Refer to 31 U.S.C. § 1535.
      6. Refer to Appendix D: Deobligating Funds in an Economy Act IAA for deobligating funding on an IAA for Severable and Non-severable services under the Economy Act.
      7. Close the IAA in their procurement/acquisition systems and/or accounting and financial systems; and
      8. File all IAA-related documents according to the documentation retention requirements.

060504 IAA Related Reporting Requirements

1. FSC and Administration/Staff Office CFOs will cooperate to ensure the appropriate recording and reporting for buy/sell-related activities, transactions, and reconciliations in VA’s accounting system.

• FSC and Administration/Staff Office CFOs will follow OMB and Treasury’s guidelines for performing reconciliations and reporting. Refer to Volume IX, Chapter 5, Intragovernmental Transactions for details.

0606 Authorities and References

• United States Code (U.S.C.)
  • 5 U.S.C. § 3371- 3376, Assignments to and from States
  • 5 U.S.C. § 4104, Government facilities; use of
  • 5 U.S.C. § 5514, Installment Deduction for Indebtedness to the United States
  • 31 U.S.C. §1531 – §1537, Transfers and Reimbursements
  • 38 U.S.C. Chapter 81, Acquisition and Operation of Hospital and Domiciliary Facilities; Procurement and Supply
  • 41 U.S.C. § 3902, Severable services contracts for periods crossing fiscal years
• 2 C.F.R. § 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• Public Law 95-224, Federal Grant, and Cooperative Agreement Act
• OMB the Office of Federal Procurement Policy Memorandum, Guidance for Improving the Management and Use of Interagency Acquisitions
• TFM Volume I, Part 2, Chapter 4700, Agency Reporting Requirements for the Financial Report of the United States Government
• Treasury Fiscal Service Data Registry
• Treasury Form 7600A, Agreement Between Federal Agencies General Terms & Conditions (GT&C) Section
• Treasury Form 7600B, Agreement Between Federal Agencies Order Requirements and Funding Information (Order) Section
• FAR 17.5 Interagency Acquisitions
• VA Financial Policy Publications
  • Volume III, Chapter 2, Obligations Policy
  • Volume IX, Chapter 5, Intragovernmental Transactions
  • Volume IX, Chapter 7, Buy/Sell Transactions (G-Invoicing)
• VA Acquisition Regulations (VAAR)
• VA Acquisition Manual (VAAM)
• VA Market Research Guide for Acquisition Teams
• VA Form 10-1245C, VA/Department of Defense Sharing Agreement
• VA Franchise Fund Public Law 109-114
• External Agency Implementation and Timelines

0607 Rescissions

Volume I, Chapter 11A – Buy/Sell Transactions (Paper Form) November 2022

Appendix A: Previous Policy Revisions

Section	Revision	Office	Reason for Change	Effective Date
1105	Remove VA to VA use of internal Form 2269 for Buy/Sell agreements	OFP	Internal Buy/Sell agreements transitioned to G-Invoicing platform	May 2024
1105	Remove National Acquisition Center (NAC) exemption to use purchase request form 2237 in lieu of Form 2269	OFP	VA Buy/Sell agreements transitioned to Treasury’s G-Invoicing platform	May 2024
1105	Added Treasury requirement for all User Interface/Bulk file IPAC files to include IGT sub-category data element	OFP	New Fiscal Service data element to ensure accurate categorization of the transaction	May 2024
1105	Removed Procurement of High-Tech Medical Equipment by NAC Mandatory Clause memo	OFP	VA Buy/Sell agreements transitioned to Treasury’s G-Invoicing platform May 2024	May 2024
1101 Overview	Added reference to the Treasury Financial Manual (TFM) Vol I, Part II, Chapter 4700 for additional information related to assisted acquisition requirements	OFP	OMB Federal Procurement Policy, Improving the Management and Use of Interagency Acquisitions removed as some material updated	November 2022
110501 General Policies	Added criteria for determination of buy/sell transaction vs cost sharing/account adjustment	OFP	Elements for consideration when determining intragovernmental processing	August 2022
Appendix F	Personnel Cost Scenario Examples added as Appendix F	OFP	Fact patterns to assist with determination of correct transactional process	August 2022
1101	Policy Name Change	OFP	Distinguish between Buy/Sell Transactions using legacy paper form process and Buy/Sell Transactions using G-Invoicing platform	July 2022
1105 Policies	Required Forms and Mandatory Clause for High-Tech Medical Equipment (HTME) Procurement	OFP	Notice of Finding  (NFR 21-4) on HTME Procurement Controls Remediation Action	July 2022
1103 Definitions	Updated definitions	OFP	To use consistent with G-Invoicing Buy/Sell financial policy	July 2022
Appendix C	Removed from Policy	OFP	Previous Appendix C: G-Invoicing (GT&C and Order Stages) removed. New G-Invoicing Policy Volume I, Chapter 11b (G-Invoicing) established	July 2022
Appendix E	Appendix E added to address High-Tech Medical Equipment procurement intra-agency agreements forms and verbiage to be utilized on an interim basis	OFP	Interim remediation action plan established to address audit finding NFR 21-4 regarding intra-agency agreements placed with the National Acquisition Center (NAC)	July 2022
Various	Performed five-year review and reformatted to new policy format	OFP	Reorganize chapter layout	September 2020
Various	Changed the title to Buy/sell Transactions	OFP	Improve comprehension and understanding of related content	September 2020
1103 Definitions	Updated definitions	OFP	To align definitions with FAR and Treasury TFM where applicable	September 2020
1104 Roles and Responsibilities	Removed offices without roles specific to Interagency Agreements (IAA) policy	OFP	No specific role in this policy	September 2020
1105 Policies	Updated policy section to clarify: authorities; IAA process; IAA Administration; Reporting requirements	OFP	Standardize agency guidance to federal guidance	September 2020
Appendix A	Updated appendix to remove Treasury Form 7600 and add buy/sell transaction process	OFP	Provide standardized agency guidance	September 2020
Appendix B	Moved repository information to policy section and added IAA approval cover sheet	OFP	Provide standardized agency guidance	September 2020
Appendix C	Added G-Invoicing information processes	OFP	Provide standardized agency guidance	September 2020

Appendix B: TFM 4700 Buy/Sell IPAC & G-Invoicing Transaction Cycles

The Buy/Sell process model is defined by four distinct phases of activity:

• IAA Initiation and GT&C
• Order
• Performance Transactions/Receipt and Acceptance; and
• Fund Settlement/IAA Closeout

Each phase is characterized by specific business and accounting event(s) and is governed by a particular set of business rules to guide the decision-making process throughout the Buy/Sell life cycle, as displayed below.

Phase	Initiation and GT&C	Order	Performance Transaction and Receipt/Acceptance	Fund Settlement and IAA Closeout
Buy/Sell Business Event	-Complete Determination & Findings and identify trading partners -Establish GT&C -Officials Approve GT&C	-Document statutory authority and bonafide need -Complete accounting terms of IAA -Document TAS/BETCs -Create fiscal obligation	Goods/services are performed and delivered	-Buyer submits payment -Funds are transferred -Agreement is closed out
Accounting Event(s)	-No accounting Events	-Record UCO/UDO -Record advance payments (if necessary)	-Document the exchange of goods/services -Record invoices -Record accruals	-Record payment/collection -Record deobligations (if necessary)
Source: TFM Volume 1, Chapter 4700, Appendix 8

Stage	GT&C	Order	Performance Transaction	Fund Settlement and IAA Closeout
Platform	G-Invoicing	G-Invoicing	G-Invoicing	IPAC
Buy/Sell Business Event	-Trading partners’ roles & responsibilities are identified -Contact information and authorized officials are established -Agency Officials will Establish & approve GT&C	-Accounting terms of the IAA are completed -Product requirements are detailed -A fiscal obligation is created	-Goods / services are delivered / performed -The exchange of goods / services (Delivered / Received) -Accrual information is exchanged	-IPAC is initiated through the completion of the Performance Transaction -Funds are transferred
Source: TFM Volume 1, Chapter 4700, Appendix 8

Appendix C: Template of VA IAA Routing Cover Sheet

IAA NO.	IAA Routing COVER SHEET
	REQUESTING AGENCY (BUYER):	IAA STATUTORY AUTHORITY:
		ECONOMY ACT	NON-ECONOMY ACT
	SERVICING AGENCY (SELLER):	ESTIMATED TOTAL COST: $
TITLE OR ORGANIZATIONAL ELEMENT	REVIEWER’S NAME AND TITLE	Approved	Date
FSC’s Initial Review
OGC’s review, if applicable (See OAL Part M 817)
Other Applicable Review (per internal Directives or Handbooks)
CIO or designee’s review for IT equipment, if applicable
Administration or Staff Office CFO’s for amounts ≥ $25M (Buyer or Seller)
FSC’s Final Review

Appendix D: Deobligating Funds in an Economy Act IAA (including Assisted Acquisitions)

Service Type	Can Cross Fiscal Years?	Deobligating Required at FY-End?
Severable (less than or equal to 12 months)	Yes, under 41 U.S.C. 3902 & FAR 32.703-3(b)	Yes – any unused funds must be deobligated at fiscal year-end
Non-Severable	No-Must be fully funded at award	Yes – unused funds must be deobligated at fiscal year-end
Economy Act IAA	Subject to same rules above	Yes – unless another statutory authority applies (B-289380)

Appendix E: Personnel Cost Scenario Examples

Description	Transfer for the Payment of a Good or Service is normal part of Sellers business activity (Buy/Sell)	Does Transfer result in an Obligation or Outlay (Expenditure Transfer)	Policy Guidance	Considerations / Comments
An NCA staff member performs a project for the VAMC and VHA wishes to provide a performance award.	No	Yes	Volume II, Chapter 1 – Appropriations Law	VA will record adjustments to expenditures by transferring expenditures from one VA organization to another (e.g., one of the organizations gives an award to a VA employee who works in another VA organization and the employing organization has already obligated and expended the award to its employee). Subject to award limitation VA may record a transfer of costs associated with an employee’s activity from one organization completed on behalf of another organization, if the costs have already been obligated and expended by the employing organization.
A medical center would like to have a person who currently works in the Canteen Service, work for Dietetics on the weekends. This person would help prepare food. They would be filling a gap as there is a shortage of food workers at this medical center.	No	Yes	Volume II, Chapter 1 – Appropriations Law	VA will record adjustments to expenditures to temporarily charge one VA appropriation for an expenditure benefiting another VA appropriation, as long as amounts are available in both appropriations and the accounts are adjusted to reimburse the appropriation initially charged during or as of the close of the fiscal year.   VA may record a transfer of costs associated with an employee’s activity from one organization completed on behalf of another organization, if the costs have already been obligated and expended by the employing organization.
A VBA contact center representative located on the same campus as a VAMC volunteers to serve on their labor pool for COVID. This would result in overtime.	No	Yes	Volume II, Chapter 1 – Appropriations Law	VA will record adjustments to expenditures to temporarily charge one VA appropriation for an expenditure benefiting another VA appropriation, as long as amounts are available in both appropriations and the accounts are adjusted to reimburse the appropriation initially charged during or as of the close of the fiscal year.   VA may record a transfer of costs associated with an employee’s activity from one organization completed on behalf of another organization, if the costs have already been obligated and expended by the employing organization.
Signed 2269 for a salary/payroll agreement between facility A and B, the detail assignment to include 10% of FTE time up to a one-year period. The requesting organization will reimburse the servicing organization for the period of service.	No	Yes	Volume II, Chapter 1 – Appropriations Law	VA will record adjustments to expenditures to temporarily charge one VA appropriation for an expenditure benefiting another VA appropriation, as long as amounts are available in both appropriations and the accounts are adjusted to reimburse the appropriation initially charged during or as of the close of the fiscal year.