6 FAH-5 H-440
BILL PAYMENTS
(CT:ICASS-93; 04-17-2019)
(Office of Origin: CGFS/ICASS)
6 FAH-5 H-441 Bill Payments Policy
(CT:ICASS-16; 10-15-2010)
(Applies to participating ICASS agencies)
The ICASS system uses customer payments to meet the cost of providing services at post. To ensure the continued ability to provide critical administrative support services to all customer agency programs operating abroad, the ICASS system must have a policy that results in the swift and fair resolution of disputes and the prompt payment of all bills. To accomplish this, the ICASS system must ensure:
(1) That all ICASS participants follow established policy;
(2) That the ICASS system complies with its legal obligation to collect all amounts owed in a timely basis. In addition, the ICASS system cannot continue to provide services on an advance basis when amounts are overdue. Section 23 of the State Department Basic Authorities Act (22 U.S.C. 2695(b)(2)) that governs the ICASS system reads as follows:
“The Secretary of State shall bill each Federal agency for amounts due for services provided [for administrative support]. The Secretary shall notify a Federal agency which has not made full payment for services within 90 days after billing that services to that agency will be suspended or terminated if full payment is not made within 180 days after the date of notification. Except as provided under paragraph (3) [a waiver from the Secretary to cover protection of life and safeguard U.S. Government property] the Secretary shall suspend or terminate services to a Federal agency which has not made full payment for services under this section 180 days after the date of notification. Any costs associated with a suspension or termination of services shall be the responsibility of, and shall be billed to, the Federal agency.”
(3) That all service providers will complete budgets, following ICASS principles described in 6 FAH-5, ICASS Handbook, on time, and will provide their customers the required 10 working days and the relevant ICASS budget reports for invoice review;
(4) That posts submit budgets and signed invoices on time to the ICASS service center. The ICASS budget committee will withdraw one percent of the traditional bureau target amount from any post that doesn’t submit its initial budget on time along with all signed invoices. Any post suffering the one percent penalty also may be ineligible to receive an increase in the final ICASS target;
(5) That all customers are responsible for processing invoices at their level promptly according to the annual schedule established by the ICASS service center;
(6) That the ICASS service center will coordinate and monitor headquarters invoice preparation, payment and dispute resolution, and provide the ICASS Executive Board (IEB) and ICASS working group regular reports pursuant to the annual schedule published by the ISC;
(7) That customer agencies with invoices more than 270 days past due will lose their vote at ICASS working group meetings and on ICASS working group committees although these will be no bar to their attending/speaking at open meetings. The agency will only receive emergency services in the field essential to protect life and U.S. Government property, assuming the Department of State’s Under Secretary for Management has authorized a waiver as required by law. Additional services can be provided if the agency has transferred, in advance, adequate funds to cover its projected requirements; and
(8) That payments will be approved by the IEB, assessed, and made at the Washington level.
6 FAH-5 H-442 Billing Procedures for Department of State Service Provider
(CT:ICASS-93; 04-17-2019)
(Applies to participating ICASS agencies)
a. Following the receipt of posts’ ICASS budget and cable certification of signed invoices (actual signed invoices are retained at post), the ICASS service center (ISC) ensures that each post has submitted its ICASS budget, cable certification, and documentation of any disputes. The ISC verifies the dollar amount of each invoice against the budget submission.
b. For documenting post invoice disputes see 6 FAH-5 H-461.2 Disputes Regarding Post Invoices and 6 FAH-5 H-461.5, Dispute Process for Alternate-Service Providers (ASP).
c. For missing budgets/unsigned invoices:
(1) The ISC works with the regional bureaus to determine the status of missing budgets and unsigned invoices; and provides the regional bureaus lists of all of their posts that have submitted ICASS budgets or signed invoices at any point after the deadline. It is the responsibility of each regional bureau to advise the ISC of any compelling, extenuating circumstances that might justify a waiver of a late submission penalty. The late submission penalty, which applies only to the initial budget submission, is a one-percent reduction of the traditional bureau portion of the post's ICASS target and ineligibility for any final adjustment of the post target;
(2) In mid-January, the ISC submits to the budget committee a list of all posts whose budgets and/or signed (or documented) invoices were not submitted by the deadline date. It also lists posts that have submitted unsigned invoices without documentation of a dispute. The list includes an explanation of the circumstances of each missing budget and/or unsigned (or undocumented) invoice, to the extent that the regional bureau or post has provided an explanation;
(3) The budget committee confirms that each post on the list is subject to the one-percent penalty and/or identifies posts which, based on compelling evidence of extenuating circumstances (e.g., a misrouted DHL package, a coup forcing evacuation of the mission in the week before the budget deadline), will be exempt from the one-percent penalty; and
(4) The ISC works with the regional bureaus to advise delinquent posts that the traditional bureau portion of their ICASS target has been reduced by one percent and that they will not qualify for an upward adjustment of their target during the budget review process.
d. For differences between signed invoices and the budget submission: Where a post has submitted documentation explaining why signed invoices differ from those in the budget submission, the ISC ensures that all affected agencies receive a copy of that documentation. Where a post has neglected to provide written explanation of these differences, the ISC obtains an explanation from the post and provides it to all affected agency headquarters and directs the post provide it to all affected agencies.
e. The ISC consolidates post invoices and adds central headquarters costs not reflected in the post budgets (such as ISC, M/MED, Overseas Schools cost, etc.) according to ICASS budget timeline deadlines for the current fiscal year. To facilitate transmission of the Working Capital Fund Replenishment (70 percent) invoice in advance of the budget hearings, the ISC uses an estimate of central headquarters costs based on prior fiscal year final levels. The ISC adjusts central headquarters costs to approved current year levels when issuing the Final invoice.
f. The ISC delivers consolidated agency invoices to the Funds Control and Reimbursements Division (BP/RPBI/FCR) in accordance with the established ICASS budget timeline for the current fiscal year. Both initial and final ICASS invoices include the wording per Section 23 of the State Department Basic Authorities Act [22 U.S.C. 2695(b)(2)] as well as the following:
(1) For the purposes of Section 23, the date of transmission of this invoice under cover of Form DS-1605, Reimbursement Agreement, is the first day of the 90-day payment period. Time that elapses between the Department of State's receipt of a signed Form DS-1605 by BP/RPBI/FCR, and transmission of a bill or processing of a payment via the Intra-Governmental Payment and Collection System (IPAC) by the Global Compensation Directorate (CGFS/GC) will not be counted against the 90-day payment period or the 180-day suspension of service notification;
(2) In accordance with the ICASS bill payment and disputes policy, as established by the interagency ICASS working group and ratified by the ICASS Executive Board, agencies will pay all amounts not in dispute promptly within 90 days of receiving a Form DS-1605; and
(3) The agency receiving this Form DS-1605 for ICASS services must advise the ICASS service center (ISC) of any and all disputes with this invoice within the initial 90-day payment period. The ICASS Executive Board will not consider invoice disputes that agencies fail to submit within the initial 90-day period. An agency’s advice of a dispute to the ISC must be in writing and provide a full account of its dispute, to include: the date and number of the consolidated invoice (Form DS-1605) in dispute, the post or location of the dispute, the nature of the dispute, the amount in dispute, and the name and telephone number/email address of the person who will represent the agency in resolution of the dispute.
g. BP/RPBI/FCR prepares Form(s) DS-1605, Reimbursement Agreement(s) to cover the ICASS invoices and sends them to the agencies within five days of receiving consolidated invoices from the ISC. The ISC reimbursements officer uses a weekly report (Analysis of Pending ICASS Agreement Report), which includes amounts authorized for payment (signed DS-1605s). Form DS-1605 contains the following notice: “It is the responsibility of authorizing officers to establish or have established an obligation on their agency's books and to forward a copy of all invoice documentation and other appropriate documentation to their disbursing office in accordance with their agency's procedures.”
h. When BP/RPBI/FCR receives a signed Form DS-1605 in connection with an ICASS invoice, it sends a copy to CGFS/GC to collect payment. The ISC reimbursements officer uses Analysis of Pending ICASS Agreements Report to track receipt of signed Forms DS-1605 and their transmission to BP/RPBI/FCR for payment.
i. Upon receipt of a signed Form DS-1605 from BP/RPBI/FCR, CGFS/GC either sends a bill to the agency finance or accounts payable office in question or collects payment through IPAC. CGFS/GC advises the ISC when it has either sent out a bill or effected payment through the Intra-Governmental Payment and Collection System (IPAC), and likewise advises the ISC as each ICASS payment is received so that the ISC knows when a bill payment is delinquent in terms of either the 90-day initial payment period or the 180-day notice period.
j. The ISC reimbursements officer keeps track of all ICASS accounts (i.e., invoices to customer agencies) on an ongoing basis. At the first ICASS working group meeting following the beginning of every calendar quarter, the reimbursements officer, working with input from BP/RPBI/FCR and CGFS/GC, provides the ICASS working group (IWG) a list of all unsigned Forms DS-1605 and all unpaid bills as of the last day of the preceding quarter. IWG members inquire within their agencies as to the status of payments. The ISC also includes a current list of unsigned Forms DS-1605 and unpaid bills as a tab in the briefing book for all ICASS Executive Board meetings.
k. When the ISC reimbursements officer determines that an agency has not made full payment of an ICASS invoice within 90 days of the transmission of a Form DS-1605 (minus any days that pass between BP/RPBI/FCR's receipt of a signed Form DS-1605 and CGFS/GC's transmission of a bill or collection of payment via IPAC), the reimbursements officer sends a letter to that agency's authorizing and disbursing offices. The letter notifies the agency that, in accordance with Section 23 of the State Department Basic Authorities Act [22 U.S.C. 2695(b)(2)], ICASS services will be suspended to all activities covered by its agency code if full payment is not received within 180 days of the date the notice is sent:
(1) The reimbursements officer provides copies of the notice to:
(a) The affected ICASS Executive Board (IEB) member (if applicable), or, in the absence of an IEB representative, the agency's most senior management official;
(b) The IEB Chair;
(c) The Chief Financial Officer of the Department of State;
(d) The ICASS working group;
(e) The executive director of the affected Department of State regional bureau;
(f) BP/RPBI/FCR (if the action is based on an unsigned Form DS-1605), and CGFS/GC (if the action involves an unpaid bill); and
(g) This action is in addition to any reminders BP/RPBI/FCR or CGFS/GC might send out, and is the only notice that refers to possible suspension of services;
(2) The reimbursements officer sends a cable to posts (including the financial service centers) which provide ICASS service to the agency or entity that is delinquent in its payment. The cable (sample copy attached) is to the attention of:
(a) Ambassador;
(b) Deputy Chief of Mission (DCM);
(c) Affected agency;
(d) Management counselor; and
(e) ICASS council chair. Copies of the cable go to those listed in the first subsection of this paragraph, as well as to the Department of State's Office of Management, Policy and Planning (M/P), which bears responsibility for coordinating National Security Decision Directive 38 (NSDD-38) staffing increase and decrease requests. The cable lays out the terms and conditions of the service suspension that will result at post if the agency's disbursing office does not pay its consolidated ICASS bill in full within 180 days.
l. In September of each year, the ISC reimbursements officer prepares for the ISC director's signature a decision memorandum to the Department of State's Under Secretary for Management. The memorandum identifies for the upcoming fiscal year those services that meet the criteria for a waiver of service suspension under paragraph (3) of Section 23 of the State Department Basic Authorities Act [22 U.S.C. 2695(b)(2)] "to cover protection of life and safeguard U.S. Government property." The memorandum requests that the Under Secretary, on behalf of the Secretary, approve a blanket waiver of the following services under the provisions of paragraph (3):
(1) Emergency medical service, on a case-by-case basis, in those exceptional circumstances where the regional medical officer determines that medical service is essential to protect life;
(2) Local guard service to properties whose safeguarding is the direct responsibility of the embassy or consulate;
(3) Payroll services for locally employed staff;
(4) Emergency maintenance and building operating services required to prevent physical damage to buildings for which the embassy or consulate bears responsibility; and
(5) Services provided in connection with an agency's drawing down or complete departure from country as a result of service suspension.
m. Posts must request waivers for other services on a case-by-case basis. Where an agency or post requests and the Under Secretary for Management grants a special waiver so that an agency can receive additional ICASS services in connection with the protection of life and the safeguarding of U.S. property, the ISC reimbursements officer contacts the agency to make arrangements for an advance payment to cover the full costs of the special waived services. Costs for ICASS services covered by the Under Secretary for Management’s general waiver (see paragraph j of this section) will be charged against the agency's outstanding balance.
n. During the 180-day warning period, the ISC's reimbursements officer makes every effort to bring an agency's delinquent bill and potential suspension of service to the attention of those in the agency who can affect payment. If payment is not received, the reimbursements officer sends a notice to all parties listed in paragraph i of this section advising them that all services except those expressly waived by the Under Secretary of State for Management are suspended. The notice (and cable to posts) defines the terms and conditions of the suspension in accordance with both the ICASS billing and disputes policy and the Under Secretary's waiver.
o. When the ISC reimbursements officer receives documented evidence from CGFS/GC that an agency has made full payment of its delinquent ICASS invoice and that the agency is not otherwise delinquent on other ICASS invoices, the reimbursements officer notifies the parties (listed in paragraph i of this section) of these billing procedures that either the agency's ICASS services will not be suspended or, if they are already suspended, can be restored.
p. The ISC sends out many instruction cables over the course of a budget cycle. Critical to the ICASS bill payment and dispute process is a message the ISC sends out by April 1 each year reminding posts to record their workload counts and ICASS time allocations as of May 1 and forward these to the ICASS council for consideration as of June 1, with council concurrence no later than July 1.
6 FAH-5 H-443 Budgeting AND INVOICE Procedures for Alternate-Service Providers (ASP)
6 FAH-5 H-443.1 Target Setting and Funding of Alternate-Service Providers (ASP)
(CT:ICASS-89; 02-21-2019)
(Applies to participating ICASS agencies)
a. At the initial target setting process, the alternate-service provider (ASP) headquarters representative presents targets for approval by the ICASS budget committee. The ICASS service center (ISC) then communicates the authorized funding levels to each ASP post. For a USAID ASP, these targets do not include costs for operating costs (non-ICASS dual position charges paid only by the ASP). This differs from the State-ICASS methodology, which includes these costs in the target.
b. The ASP headquarters issues allotments from its Working Capital Fund to all post alternate service providers.
c. If an ASP does not obligate all funds, the difference is treated as post’s carryover funds. These funds are to be spent based on an agreement between the post ICASS council and the ASP.
d. The ASP will maintain a contingency fund in case one of its posts needs additional funds for an unanticipated requirement that arises after the final targets have been set. The ICASS guidelines for contingency funds would apply to the ASP. Replenishment of the fund will be accomplished through charges to all customers at the headquarters level in the next fiscal year. The distribution methodology of the contingency fund cost will be based upon each agency’s percentage share of the total post invoice in the year following the allotment of the contingency funds.
6 FAH-5 H-443.2 Service and Invoicing at Post
(CT:ICASS-89; 02-21-2019)
(Applies to participating ICASS agencies)
a. The post alternate service provider (ASP) provides the service in accordance with an ICASS council approved memorandum of understanding (MOU) and funding level.
b. The ASP provides the service and uses the ICASS-ASP budget and billing software to generate ASP invoices.
c. The ASP creates a budget for either the shared service(s) or the entire administrative budget. It will choose either a Lite or Standard budget version. If the version differs from the current post version, the post council must approve the selection.
d. The ASP is assigned its own agency code, distinct from its program agency code. ICASS is treated as a customer and an invoice is calculated for its use of the ASP services.
e. The ASP software uses the same American salary table and average cost for post assignment travel as the ICASS software in the derivation of the invoices.
f. The redistributed administrative cost is automatically calculated if the entire administrative budget is entered into the software. A council-approved alternate redistribution cost may be used if the entire administrative budget is not entered into the software in order to calculate customer invoices. Such redistribution will be budgeted under the overhead cost center. This supersedes the recommendation that overhead not exceed 5% of the total budget. The local service provider is responsible for developing the methodology for alternate redistribution charges.
g. The ASP can allocate a portion of staff time to the non-ICASS dual-position cost center if the staff performs services other than ASP administrative services. These functions are defined as non-ASP services.
h. The ASP generates preliminary invoices for all customers at post including one for State-ICASS (agency code 1901.1) if applicable. At posts where an ASP provides services to and receives services from State ICASS, since the invoice generated from the ICASS and ASP software does not include the redistributed service provider costs, the ISC will calculate this distribution. To accomplish this the ASP and State financial management officer (FMO) both submit budgets to the ISC ten days in advance of the ICASS budget submission deadline. The ISC will calculate the distribution and electronically transmit invoices back to the ASP and State ICASS service provider for circulation and signature. Agencies will have ten business days to review and authorize the invoices.
i. The ASP submits an email summary of all signed invoices to the ISC. The ASP maintains signed invoices at post for audit purposes.
j. At posts where ASP and State ICASS do not cross service each other, budgets are submitted to the ISC concurrent with submission of the email summary.
6 FAH-5 H-443.3 Processing and Payment of Invoices
(CT:ICASS-89; 02-21-2019)
(Applies to participating ICASS agencies)
a. The ASP invoice and payment process is separate from the State-ICASS invoice and payment process. This is because the ASP operates out of its own Working Capital Fund.
b. The ISC loads the ASP budgets into the ICASS global database. It compiles consolidated invoices at the agency level, includes any additional Washington-related costs, and provides them to ASP headquarters.
c. ASP headquarters will issue invoices to all agencies for collection and collect the funds in conformance with standard ICASS collection procedures. The ISC will provide all ASP 90- and 180-day delinquency notification letters to the ASP headquarters for issuance. Customers who are delinquent over 270 days in paying bills may have ASP services cut off and will lose their vote on the council. A senior ASP management official at post or designee will engage the chief of mission and jointly make a determination as to whether services to the delinquent agency may be cut off without endangering lives or U.S. Government property.
d. The ISC will prepare invoices for ASP headquarters three times annually. The first set of invoices will reflect a 70% advance payment into the ASP Working Capital Fund and will be based on prior-year billed amounts to all ASP customers. The second set of invoices will represent the initial invoice for the current fiscal year and will be for informational purposes only to all ASP customers. The third and final set of invoices will represent the final full cost for the fiscal year. ASP customers will pay the balance due between the final full cost and the initial 70% advance payment.
6 FAH-5 H-443.4 Alternate Service Provider (ASP) Financial Management
(CT:ICASS-89; 02-21-2019)
(Applies to participating ICASS agencies)
An alternate service provider (ASP) will develop its own method to compare its budget to spending for financial management purposes. Integrating accounting data with the ICASS budget software is the responsibility of the ASP.
6 FAH-5 H-444 through h-449 unassigned