NOW THAT YOU’RE A CERTIFYING OFFICER
PDF Version November 2007
We originally issued this booklet in 1983 to provide a readable
desk reference for all newly appointed Certifying Officers.
Today, our original goal remains the same and we still believe this
pamphlet is a useful resource for newly appointed Certifying
Officers as well as those who have been in the position for some
time. This revised addition includes language on the reporting of
large dollar transactions and we have clarified the requirements for
including taxpayer identification numbers on payment vouchers. Like
the previous version, this version is an easily downloaded PDF
document available from the Financial Management Service (FMS)
Website.
Washington, D.C.
Wanda J. Rogers
November 2007
Assistant Commissioner &
Chief Disbursing Officer
Payment Management
Financial Management Service
Now that you’re a
Certifying Officer


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NOW THAT YOU’RE A CERTIFYING OFFICER
NOW THAT YOU’RE A CERTIFYING OFFICER
Now that you’re a
Certifying Officer
Department of the Treasury
Financial Management Service
Payment Management
Initial Printing: September 1983
Reprinted: June 1989
Revision: March 2005
Revision: November 2007
Supplement to the
Treasury Financial Manual, Volume I, Part 4-1000
Introduction
This pamphlet has been written for
all of you who are certifying officers
in the Federal Government. We
hope that it will serve as a conven-
ient introduction for those of you
who are new on the job and as a
helpful refresher for those of you
who are veteran certifying officers.
We want to emphasize in this
pamphlet how important your
responsibilities are as a certifying
officer and how serious the
consequences may be if you do not
live up to them. We hope you will
keep this pamphlet handy and refer
to it often.
Why did we develop this
pamphlet for You?
As a certifying officer, you are
personally accountable for the
correctness of Federal Government
payments. You are one of nearly
1600 certifying officers, collectively
accountable for over 1.7 trillion
dollars each year. You have a big job!
Most of you are conscientious about
your work. You are proud to be
involved in the Federal Government,
and you want to do your part helping
it run smoothly and cost effectively.
You’re sensitive to issues like fraud,
abuse, waste and mismanagement in
the Federal Government. However,
sometimes your own role may not
seem to be important. After all, you
are just one person among the thou-
sands and thousands. You may think
that what you do or don’t do won’t
make a difference.
We prepared this pamphlet to assure
you that you do make a difference.
You are accountable for your share
of the 1.7 trillion dollars! In the
following pages we’re going to
emphasize your responsibilities as a
certifying officer, which are mandated
by law. It is important for you to be
aware of these responsibilities and
know how to meet them.
How has personal
accountability changed?
Two hundred years ago, when the
Treasury Department was first
established, the concept of personal
accountability was simpler than it is
today. In those early days of our
country, all the money used to keep
the Government running was paid
out from one central location at the
Treasury. And most of the
transactions were made in cash.
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Why this pamphlet?
The officers knew what goods were
ordered and what goods were
delivered. Their firsthand knowledge
of transactions made accountability
simple.
However, as Government grew, the
system became more complicated.
It was no longer workable for all
payments to come from Washington,
D.C.; certifying officers were needed
throughout the country. Over the
years new laws changed and
strengthened the methods available
for determining that payments are
legal, proper and correct. However,
the basic concept of personal
accountability has remained intact.
During the second half of the 20th
century, the Federal Government has
grown rapidly in size and complexity.
In the 1940’s, vouchers documenting
a business transaction were
processed entirely by hand. Large
groups of clerks prepared and
reviewed vouchers, verified their
accuracy, and compared the facts on
the vouchers with those on the
source documents. Then certifying
officers, who supervised these clerks,
reviewed their work and, on the
basis of their review, certified the
payments.
What is a “Certifying
Officer?”
Ever since Congress created the
Treasury Department in 1789, certain
Government employees have been
held accountable for Federal
payments. Specific people, called
certifying officers in civilian agencies,
have responsibility to verify that
payments made by the Federal
Government are legal, proper and
correct. The verification involves
certifying a voucher upon which a
disbursement will be made. As a
certifying officer you may supervise
a unit within an accounting or data
processing organization. In addition
to ensuring that payments are legal,
proper and correct, much of your
time may be spent supervising
accounting or payment processing.
What is “Personal
Accountability?”
As a certifying officer you are held
personally accountable, individually
responsible for verifying that the
Federal Government payments under
your jurisdiction are legal, proper and
correct. This is your “personal
accountability.” If any payment that
you have certified is found to be
illegal, improper or incorrect, you
may be held individually responsible
for reimbursing the Federal
Government for the amount of that
payment. Being held responsible to
the degree that you are required to
reimburse these payments is termed
“pecuniary liability.”
Today, sophisticated computer
systems have automated the process
that was formerly done only by
individuals. For example, both
accounts payable and receivable are
entered into central databases from
multiple communication portals. The
databases verify transactions, create
on-line and output reports and
generate payment records. Certifying
officers certify these payments on the
basis of the amounts on the database
media. However, the fact that trans-
actions affecting payments are legal,
proper and correct actually is deter-
mined by individuals at the field
offices or by a computer.
It is often impossible for today’s
certifying officers to personally
review source documents and verify
the facts on every payment because
of the volume of payments and the
complexity of today’s systems.
Instead, they must rely on the
integrity and reliability of payment
system certifications and individuals
operating them.
What is a payment
system?
A payment system includes all deci-
sions and actions that are involved in
making payments with Government
funds for Government activities. It
begins with reviewing and processing
contractual documents, reports, and
invoices and ends with the issuance
of Treasury Checks or electronic
funds transfers.
A payment system does not include
decisions to purchase, lend, hire, fire,
or award Federal assistance. As a
certifying officer, your involvement in
a payment system occurs at the end
of the payment processing cycle.
Originally, individuals completed all
the steps in a payment system
manually. Today, most payment
systems are automated. Manual
systems and automated systems use
different methods for making sure
that payments are legal, proper and
correct.
In a manual system, you work with
the basic source documents.
Although you can’t completely
determine if a payment is legal or
accurate by examining the source
documents, this examination does
provide reasonable assurance that a
transaction:
•Has been processed through all the
designated responsible and author-
izing officials.
•Is properly documented.
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•Equipment functions properly and
operates according to preset
stipulations.
•Physical access to documents and
equipment is adequately restricted.
•Source data received from outside
the processing departments and
agencies or from other computer
systems are processed according to
the above criteria.
While you are still legally liable, under
an automated payment system, the
conditions under which you may be
relieved may be different from those
under a manual system.
Previously, accountable officers’,
which include Certifying Officers,
requests for relief from liability were
sent to the Comptroller General.
However, in 1991, the Department
of Justice determined that certain
Federal Statutes purporting to
authorize the Comptroller General
to issue decisions relieving account-
able officers from liability were
unconstitutional, see Comptroller
General’s Authority to relieve
Disbursing Officers from liability
14 Op. O.L.C. (1991). Thus, under
certain law, the Government
Accountability Office (GAO)
decisions do not relieve accountable
officers from legal liability.
Furthermore, each agency is respon-
sible for assessing the personal
liability and obligations of its
Certifying Officers.
Regardless of what system is used, no
one has the authority to make known
overpayments.
What types of payments
are processed?
The Federal Government makes a
wide variety of payments. For
example, payments are made for
employee payrolls, retirement
benefits (civil service retirement,
railroad retirement, social security),
administrative expenses (contracts,
purchase orders, travel, maintenance
services etc.), and for grants-in-aid to
state and local governments and
tribal organizations. Many of the
systems used to make these
payments can be complex and there
is a fair amount of diversity among
them.
•Is computed correctly according to
source documents.
•Is not improper, unreasonable, or
fraudulent according to the
information that is available.
The employees who initiate these
source documents or sign them (not
certifying officers) are the ones who
actually determine that the payment
is legal, proper and correct. You
certify the payment based on these
signed documents. However, you
usually do not escape liability for
losses resulting from improper
certification by claiming you were
either not in a position to personally
ascertain that each item on a voucher
was correct, or by claiming you must
depend on the correctness of your
subordinates’ work.
If you rely on the statements and the
computations of subordinates, you
must assume responsibility for the
correctness of their statements and
computations. An exception may be
made if it can be shown that neither
you, nor your subordinates, in the
reasonable exercise of care and
diligence, could have known the
facts.
Automated payment systems present
special problems for certifying
officers because you rarely examine
individual payments or supporting
documents. It can be difficult to
certify these payments because:
•The number of transactions is so
large
•Transactions are often system
generated
•Data originates from multiple
communication portals
•The payment file is system
generated based on data received
from other networks
A well-designed automated payment
system will include evidence to verify
that the system is designed and
operating properly. You use this
evidence to determine that payments
are legal and accurate. Well-designed
automated payment systems have
procedures requiring that:
•Documents are properly
authorized, approved and examined
before they are transcribed into
machine-readable form.
•Transcriptions are complete and
accurate.
•Specifications that identify what
systems are required to do are
consistent with current legal and
policy requirements. (These specifi-
cations also must specify adequate
controls over inputs, processing,
and outputs, and they must provide
for processing all aspects of
transactions properly.)
•Additions, deletions, or changes to
data or computer programs are
authorized and controlled.
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005
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NOW THAT YOU’RE A CERTIFYING OFFICER
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Identification Number (TIN) of each
person to whom payment may be
made under the voucher. TINs on
payment vouchers are not required
under the following circumstances:
a.Where an agency does not have the
statutory or legal authority to
require a Federal payee to submit a
Taxpayer Identification Number and
the agency has no other means of
obtaining it;
b.Where a Federal payment recipient
is unable to obtain a Taxpayer
Identification Number;
c.Where the collection or provision
of a Taxpayer Identification
Number has a detrimental effect on
a law enforcement operation, mili-
tary operation, national security, or
emergency relief effort;
d.Where the agency does not expect
to make more than one payment, in
an amount of $200 or less, to the
same recipient within a one-year
period (i.e., the payment is non-
recurring) and the cost of obtaining
a TIN would be prohibitive; or
e.Where FMS determines that the
collection or provision of a TIN is
not in the best interest of the
Government
What should you do
in carrying out your
responsibilities to avoid
liability?
Certifying officers have a heavy
burden of verification in order to
avoid liability or qualify for relief.
Therefore, in carrying out your
responsibilities you should do the
following:
•Properly supervise subordinates by
establishing a system of procedures
and controls which minimize
opportunities for incorrect or
improper payments and insure that
the system is followed.
•Know that you have a right to
request an advance decision from
the Comptroller General when you
have doubts about the legality of
payments.
•Be alert to the possibility of
voucher-schedules and supporting
documents being processed a
second time.
•Make use of the evidence that is
available, e.g., fund availability certi-
fications, and other documentation
which would indicate that
procedural safeguards regarding
payment have been observed.
•Return payment vouchers that are
inadequately documented to the
appropriate administrative officials
for proper approvals and
supporting documents.
•Do not sign blank voucher forms.
According to law and
regulations, what are your
responsibilities as a
Certifying Officer?
As a certifying officer, you are
responsible for the accuracy and
legality of the payments made from
Federal funds that you approve.
Specifically, 31 U.S.C. 3528 states
that you are:
•Responsible for any errors in
certified payments.
•Responsible for making sure that
the facts presented in certified
documents for payment are
complete and accurate.
•Responsible for illegal, improper or
incorrect payments made by the
Federal Government because you
have made false, inaccurate or
misleading certifications.
•Responsible for any payments made
that are prohibited by law and that
do not represent legal obligations
under the appropriations or funds
involved.
However, the Act also states that you
are not required to make good on
payments you certified if:
•You based your certifications on
official records.
•You exercised due diligence in
performing your duties.
•You had no personal knowledge of
any illegal, improper or incorrect
payments and could not be
expected to uncover them in the
reasonable performance of your
legal duties.
In addition, you must ensure that
payments are in compliance with
Executive Order 13224, Blocking
Property and Prohibiting Transactions
With Persons Who Commit,
Threaten to Commit, or Support
Terrorism.
Federal Agencies are encouraged to
limit the use of the Same Day
Payment Process “Fedwire” to large
dollar payments. In accordance with
Treasury Financial Manual Volume I
Part 6, Section 8500, in the event of
a large dollar disbursement the
Certifying Officer is responsible for
submitting Large Dollar Notifications
(LDN) to the Financial Management
Service (FMS), Cash Forecasting
Division.
Title 31, Chapter 33, Subchapter II
(d) U.S.C. 3325, further clarifies the
Certifying Officer’s responsibility by
stipulating that each certified voucher
submitted to a disbursing official
should included the Taxpayer
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NOW THAT YOU’RE A CERTIFYING OFFICER
NOW THAT YOU’RE A CERTIFYING OFFICER
Questions
Please use the following questions to
check your knowledge of the infor-
mation in this pamphlet. Circle the
right answer and check your
accuracy on page 12. For every
question answered incorrectly please
review the section indicated with the
answer.
1. What is personal
accountability?
A. Being held individually
responsible for verifying that
all payments under your juris-
diction are legal, correct and
proper.
B. Being held individually
responsible for reimbursing
the Government when errors
are made by your supervisor.
C. Being held responsible for
reimbursing the Government
if an incorrect payment is
made due to computer
malfunction.
D. Being held responsible for
reimbursing the Government
if an incorrect payment is
made due to computer
malfunction.
2. What is pecuniary liability?
A. Being individually responsible
for reimbursing the
Government for any
payment that you certified
which is found to be illegal,
improper, or incorrect.
B. Being responsible for
reporting malfeasance to
your supervisor.
C. Being responsible for
individually supervising the
work of field officers.
According to the law,
what can happen to you
if you are negligent in
performing your job?
Certifying officers are among the
employees involved in the payment
process who are required to make
good any payments that are illegal,
inaccurate or improper.
If an outstanding liability remains as a
result of a loss for which the
certifying officer is liable, and there is
not a request for relief or relief is
requested and denied, the certifying
officer becomes indebted to the
United States for the amount
involved. At this point, the agency
can initiate collection action against
the person in accordance with the
law. If the person is still employed by
the Government, the means of
collection is mandatory withholding
of pay.
In addition, the Civil Service Reform
Act of 1978 states that “…employees
should be separated who cannot or
will not improve their performance
to meet required standards.” In
another section, the Act says that
employees may be reduced in grade
or removed if their job performance
is unacceptable.
You have an extremely responsible
position. Payments that you certify
must be correct, proper and legal.
You are personally accountable and
have pecuniary liability for payments
that you certify.
The increasing complexity of pay-
ments and the development and
enhancement of automated payment
systems has changed the infrastruc-
ture of your job, but it has not
relieved you of your responsibility.
Therefore, it is important that you
stay abreast of changes in the area
of “electronic certification”.
Conclusion
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7. According to the law,
a certifying officer is:
I.
Responsible for any errors in
certified payments.
II. Responsible for making sure
that the facts in certified
documents for payment are
complete and accurate.
III. Responsible for reporting any
errors to the local Congressman
or Congresswomen.
IV. Responsible for any payments
made that are prohibited by
law and that do not represent
legal obligations under the
appropriation or funds involved.
A. All of the above are true.
B. None of the above are true.
C. I and II are true.
D. I and IV are true.
8. To carry out your
responsibilities and avoid
liability there are several
things you should do.
These include:
I. Never sign blank voucher
forms.
II. Never authorize payments
when funds are not available to
cover the payments.
III. Be alert to the possibility of
vouchers or voucher-schedules
and supporting documents
being processed a second time.
IV. Know that you have no right to
request an advance decision
from the Comptroller General
when you have doubt regarding
the legality of payments.
A. All of the above are true.
B. None of the above are true.
C. Only I and II are true.
D. I, II and III are true.
3. Who and what must
today’s certifying officer
rely on to determine that
transactions are legal,
proper and correct?
A. Interviews with field officers
and personal reviews of every
source documents.
B. People who service
computers and computer
manuals.
C. Individuals in field offices and
the payment systems they
help operate.
4. Automated payment
systems present special
problems of certification
because:
I.
The number of transactions is
so large
II. There are so many locations
initiating transactions.
III. Transactions are entered from
remote terminals.
IV. Data are transferred through
telecommunications
networks and central
computer processing.
A. None of the above are true.
B. All of the above are true.
C. I and II are true.
D. II and IV are true.
5. The basic issue in
determining your legal
liability in an automated
payment system is:
A. How long you have worked
as a certifying officer.
B. Your ability to pay.
C. Whether it was reasonable
for you to rely on the system
to continually produce legal
and accurate payments.
6. According to the law, two
conditions under which
you are not required to
make good on payments
you have certified are:
I.
You based your certification on
official records.
II. You knew that your work would
be double-checked by others.
III. You exercised due diligence in
performing your duties.
IV. You gave blanket approval to
the people you supervise to
proceed with payments.
A. I and II are true.
B. II and IV are true.
C. I and III are true.
D. I and IV are true.
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NOW THAT YOU’RE A CERTIFYING OFFICER
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4A. Wrong. Review the section
entitled “What is a payment
system?”
4B. Correct.
4C. Wrong. Review the section
entitled “What is a payment
system?”
4D. Wrong. Review the section
entitled “What is a payment
system?”
5A. Wrong. Review the section
entitled “What is a payment
system?”
5B. Wrong. Review the section
entitled “What is a payment
system?”
5C. Correct.
6A. Wrong. Review the section
entitled “According to the law
what are your responsibilities
as a Certifying Officer?”
6B. Wrong. Review the section
entitled “According to the law
what are your responsibilities
as a Certifying Officer?”
6C. Correct.
6D. Wrong. Review the section
entitled “According to the law
what are your responsibilities
as a Certifying Officer?”
7A. Wrong. Review the section
entitled “According to the law
what are your responsibilities
as a Certifying Officer?”
7B. Wrong. Review the section
entitled “According to the law
what are your responsibilities
as a Certifying Officer?”
7C. Wrong. Review the section
entitled “According to the law
what are your responsibilities
as a Certifying Officer?”
7D. Correct.
8A. Wrong. Review the section
entitled “What should you do
in carrying out your responsibil-
ities to avoid liability?”
8B. Wrong. Review the section
entitled “What should you do
in carrying out your responsibil-
ities to avoid liability?”
8C. Wrong. Review the section
entitled “What should you do
in carrying out your responsibil-
ities to avoid liability?”
8D. Correct.
9. True or False: Certifying
officers are the only
individuals involved in the
payment process who are
required to make good on
payments that are
illegal, inaccurate or
improper.
A. True
B. False
10. A well-designed
automated payment
system has procedures
that require:
I.
Transcriptions are complete
and accurate.
II. Physical access to documents
and equipment is open to all.
III. Additions, deletions or changes
to data or computer programs
are authorized and controlled.
IV. System generated documents
are randomly audited to ensure
accuracy.
A. I and II are true.
B
II and IV are true.
C. III and IV are true.
D. I and III are true.
Answers
1A Correct.
1B. Wrong. Review the section
entitled “What is personal
accountability?”
1C Wrong. Review the section
entitled “What is personal
accountability?”
2A. Correct.
2B Wrong. Review the section
entitled “What is personal
accountability?”
2C. Wrong. Review the section
entitled “What is personal
accountability?”
3A. Wrong. Review the section
entitled “How has personal
accountability changed?”
3B. Wrong. Review the section
entitled “How has personal
accountability changed?”
3C. Correct.
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NOW THAT YOU’RE A CERTIFYING OFFICER
NOW THAT YOU’RE A CERTIFYING OFFICER
Our representatives
are ready to answer
your questions.
Please contact:
Austin Financial Center
U.S. Department of the Treasury
Austin Financial Center
P.O. Box 149058
Austin, TX 78714-9058
(512) 342-7300
cas.afc@fms.treas.gov
Kansas City Financial Center
U.S. Department of the Treasury
Financial Management Service
Kansas City Financial Center
P.O. Box 12599-0599
Kansas City, MO 64116-0599
(816) 414-2100
Philadelphia Financial Center
U.S. Department of the Treasury
Financial Management Service
Philadelphia Financial Center
P.O. Box 8676
Philadelphia, PA 19101-8676
(215) 516-8000
San Francisco Financial Center
U.S. Department of the Treasury
Financial Management Service
San Francisco Financial Center
P.O. Box 24700
Oakland, CA 94623-1700
(510) 594-7300
9A. Wrong. Review the section
entitled “According to the law,
what can happen to you if you
are negligent in performing
your job?”
9B. Correct.
10A. Wrong. Review the section
entitled “What is a payment
system?
10B. Wrong. Review the section
entitled “What is a payment
system?
10C. Wrong. Review the section
entitled “What is a payment
system?
10D. Correct.