Who reviews and approves GPC managing account invoices and transaction supporting data for compliance?

Specific to the purchase programs, the Approving Official is an individual (typically a supervisor) responsible for ensuring that the purchase account is used properly by the agency. The Approving Official also authorizes account holder purchases (for official use only) and ensures that the statements are reconciled and submitted to the Designated Billing Office (DBO) in a timely manner.

What is a Certifying Official?

A Certifying Official is an individual who has been charged with the responsibility of authorizing certified vouchers for payment and ensuring that funds are available for obligation before payment. The Certifying Official is held accountable for public funds in civilian agencies.

Note: OMB Circular A-123, Appendix B and the GSA SmartPay Master Contract language utilize the terms Approving Official and Certifying Official synonymously. In the case of many agencies/organizations, the individual that holds the title of Approving Official also holds the title of Certifying Official. However, the roles of Approving Official and Certifying Official may be separate functions in some agencies/organizations.

What is my role as an Approving Official?

There are many important responsibilities entrusted to the Approving Official, including:

• The Approving Official is responsible for ensuring that all purchases made by the account holder(s) within his/her span of control are appropriate and the charges are accurate. Purchases should not only be legal and proper, but also should be considered “mission essential”. In order to ensure proper purchases, the Approving Official must review and approve account holder statements belonging to all account holders within their purview. The Approving Official’s review should include looking at all required receipts and account holder logs.
• The Approving Official is responsible for counseling account holders within his/her span of control regarding regulations, misuse, and delinquency.
• The Approving Official is responsible for resolving all questionable purchases with the account holder. Upon review of receipts and account holder logs, if the Approving Official finds a questionable purchase, the Approving Official must work with the account holder to receive more information regarding the purchase in order to determine the legitimacy of the purchase.
• The Approving Official is responsible for elevating unresolved questionable purchases to the Agency/Organization Program Coordinator (A/OPC). In the event an unauthorized purchase is detected or there is a purchase that is still in question after review of supporting account holder documentation, the Approving Official must notify the A/OPC as well as any other appropriate personnel in accordance with agency policy. This may include notifying the agency’s Office of the Inspector General (OIG) for further investigation relating to potential misuse.
• The Approving Official is responsible for ensuring monthly billing account accuracy. The Approving Official signs the account statement and maintains documentation regarding the account in accordance with agency procedures.
• The Approving Official is responsible for conducting informal compliance reviews for all account holders under their span of control. These reviews should be completed in accordance with the agency’s specific policies (i.e. frequency, format).
• The Approving Official is responsible for ensuring that account holders follow the mandatory source requirements established in Part 8 of the Federal Acquisition Regulation (FAR), otherwise known as the Required Sources of Supplies and Services.
• Assist A/OPCs and account holders with their responsibility to obtain, maintain and retain complete documentation of all purchases, particularly when pre-approval is required. This can be done by ensuring the proper documentation is sent and received through the approval chain. Tools, logs, and templates for the AO can be found on the GSA SmartPay website at: https://smartpay.gsa.gov/content/resources-approving-officials

Note: Approving Officials may be held financially responsible for payments made on accounts because of failure to ensure billing account accuracy.

Remember, it is important to review your agency’s specific policy regarding reimbursement and disciplinary actions.

OMB Circular A-123, Appendix B provides multiple recommendations with regard to the Approving Official function. OMB Circular A-123, Appendix B recommends:

• Compliance reviews, or agency audits of account holder files, should be conducted at a minimum on an annual basis.
• The span of control, or number of account holders assigned to each Approving Official, is no greater than between 1:5 or 1:10 (i.e. each Approving Official is responsible for between 5 and 10 account holders).
• An Approving Official is able to act independently. For example, an employee should not be the Approving Official for a supervisor. This type of arrangement may put the employee in a compromising position and jeopardize their role as an Approving Official.

In addition to the above recommendations provided in OMB Circular A-123, Appendix B, many agencies may provide additional responsibilities for the Approving Official within their agency’s policies. It is important that the Approving Official reviews the agency’s specific policies before beginning their official duties.

What is my role as a Certifying Official?

United States Code Title 31 Section 3528, states the roles and responsibilities of a Certifying Official. These roles and responsibilities include:

• Certifying a voucher is responsible for the information contained in that voucher and the supporting records.
• The Certifying Official is responsible for the computation of the certified voucher.

The Certifying Official must ensure that all line items contained in the voucher and the total amount for payment has been computed correctly and that there are no mathematical errors in the voucher.

• The Certifying Official is responsible for the legality of the proposed payment under the appropriation or fund involved in the payment. In other words, the Certifying Official must make sure that the line of accounting that is utilized to pay the voucher aligns with the type of items purchased.

In the case of the purchase program, the Certifying Official will most often rely on other members of the Government Purchase Team to review the supporting records (i.e. the account holder and the Approving Official). However, the Certifying Official still has a responsibility to assess the accuracy of the data while performing the certification process and to report suspect transactions to the A/OPC and appropriate investigative office.

• The Certifying Official is financially responsible for repaying a payment if the payment was certified and was illegal, improper, or incorrect due to negligence on the part of the Certifying Official or was not paid out of the correct appropriation due to negligence on the part of the Certifying Official.

See United States Code 31, Section 3528 for a full explanation of the financial responsibilities of a Certifying Official.

In addition to the roles and responsibilities stated above, many agencies may provide additional responsibilities for the Certifying Official within their agency’s policies. It is important that the Certifying Official reviews the agency’s specific policies.

Additional Resources

Additional resources including tools, logs, and templates for the AO can be found on the GSA SmartPay website at: https://smartpay.gsa.gov/content/resources-approving-officials