Amending a grant funded case

← All Insights

1. Changing a case nobody signed

Changing a sales case means going back to the purchaser. On a grant funded case there is no purchaser, and the manual removes the step entirely. "Amendments to BPC cases and training grants do not require Benefitting Partner acceptance or signature" (SAMM C15.6.1).

That does not make them quick. An amendment runs the same document route as the original, with the planning document replaced by an explanation of the change, and needs state department approval before implementation (SAMM C15.6.1).

Timing is what constrains it. Agencies may amend during the current or the expired period of the appropriation funding the case, but the scope of what an amendment can do narrows sharply once the money has expired (SAMM C15.6.1). How the case was written in the first place is covered in writing a capacity building case.

2. What an amendment can still do after the money expires

Three things, and no more. "Amendments after the period of availability (POA) are limited to returning funds, reducing scope if funds were not obligated, and prior year adjustment (PYA) actions (using funds from the same appropriation)" (SAMM C15.6.1).

The third of those is where most of the work happens, and it is controlled. "IAs must request PYA from DSCA (Office of Business Operations (OBO)) and document approval in DSAMS-BPC case remarks" (SAMM C15.6.1).

The underlying idea is a distinction that appropriations law makes and ordinary commercial language does not. "The funds are no longer available for incurring new obligations when an appropriation expires but remain available for recording, adjusting, and liquidating obligations properly chargeable to that account" (SAMM C15.6.1.1). Expired money can still settle old business. It cannot start new business.

And it does not last. "Five years after expiration, the funds are cancelled and no longer available for any purpose" (SAMM C15.6.1.1).

3. When a prior year adjustment is needed

The list of triggers is practical. Agencies must submit a request to use expired funds "for: within scope increases to BPC case or training grant Total Case Value (TCV); adjustments within TCV" (SAMM C15.6.1.1.2), meaning increasing one line while decreasing another, along with working capital fund price increases and extensions to the months allowed.

The package is substantial. It identifies the money or time needed and why, and where more funds are needed for a procurement it carries a contracting officer determination and a legal opinion (SAMM C15.6.1.1).

Three situations do not need one at all, and they are worth knowing because they cover the most common cause of slippage. No request is needed where "The increase in MOS for a procurement articles line is due to delays in delivery and does not impact any training or services lines" (SAMM C15.6.1.1.2.1.1), or where the extension stays inside the obligation period, or inside the cross year allowance (SAMM C15.6.1.1.2.1).

So a late delivery on an equipment line is absorbed. A late delivery that drags training with it is not.

4. Which money pays

The preference is to stay in the original year. "The original appropriation will be used, if available, to fund the PYA request" (SAMM C15.6.1.1.1). Where that money is cancelled, spent or committed elsewhere, current year funds available for the same purpose must be used instead.

That is a real cost to the current program, which is why the decision is coordinated across the comptroller and the general counsel before funds are released (SAMM C15.6.1.1.1). Congress may also have to be told: "A Congressional Notification (CN) may be required in certain instances, (i.e., when assistance exceeds the previous total program value) prior to authorizing and releasing the funds" (SAMM C15.6.1.1.1).

Where current year money is used, the two cases are tied together. Lines are loaded in the current year case with quantities defaulted and the months ending no later than the fund expiry, each linked back to the old case by a standard note (SAMM C15.6.1.1.3.1). The old case is also amended to record that funds were not available and to name the current year case paying the bill (SAMM C15.6.1.1.4.4).

5. Who approves, and how long it takes

Approval is split by what the change does. "Within 30 days of receiving the complete PYA request from the IA, the CFD will inform the IA of DSCA's decision" (SAMM C15.6.1.1.4.1). Anything that raises the total value of the case is approved by the comptroller directorate, while adjustments inside the existing total, and extensions of time, are approved one level down (SAMM C15.6.1.1.4.1).

An approval is not just permission. The finance director supplies the exact case note wording and a memorandum, and records the approval in case remarks (SAMM C15.6.1.1.4.2).

That memorandum then starts the document clock. "the IA will use the memo's date as the Request Date in DSAMS-BPC" (SAMM C15.6.1.1.5), and from there the amendment runs through the ordinary writing and review process.

6. Closing a case against a deadline

Where the funding year is ending, closure becomes a reporting exercise. "The IA will input closure status/issues for all BPC cases and training grants funded with cancelling funds" (SAMM C15.7.3) on a published form.

The reporting rhythm accelerates as the deadline approaches. "DSCA (OBO) will download this information monthly beginning in November, bi-weekly beginning in July, and weekly beginning in September during the FY of cancellation" (SAMM C15.7.3).

An open contract is not a bar to closing. "A BPC case or training grant may be closed even when an underlying contract remains open as long as the contract lines pertaining to the BPC case or training grant are closed and there are no unliquidated obligations" (SAMM C15.7.3.2). Closure generally is described in how a BPC case runs and closes.

7. When the numbers will not reconcile

Sometimes the billed amounts and the recorded values cannot be made to match. The manual provides a route rather than leaving the case open indefinitely, and it is a last resort after other options are exhausted: "the IA must submit the case for closure adjustment by July 31" (SAMM C15.7.3.1.1) of the cancelling year, having discussed it with the finance director first.

The request is a memorandum for record, validated inside the agency and signed off by the regional division. "Once approved, the MFR will act as the case closure certificate and be uploaded onto the closed version of the case" (SAMM C15.7.3.1.1). A memorandum stands in for a certificate nobody can honestly produce.

If the agency does not act, the decision is taken for it. "No later than August 15 of that same cancelling year, DSCA will direct closure adjustment via a guidance letter on any remaining cases that have not been previously submitted for closure by an IA" (SAMM C15.7.3.1.1).

8. What a supplier can take from this

The distinction between expired and cancelled money explains a great deal of behavior on these programs. Expired funds can still pay an invoice and settle a claim, but they cannot buy anything new, and five years on they are gone entirely.

Two points matter commercially. A delay to an equipment line is usually absorbed, but a delay pushing training or services out needs an approved request, adding at least thirty days. And once the cancelling year is running, closure is chased weekly, so an outstanding invoice becomes urgent for reasons unconnected to the work.

Key terms

Expired funds	Money that can still record, adjust and liquidate existing obligations but cannot incur new ones.
Cancelled funds	Money five years past expiry, unavailable for any purpose.
Prior year adjustment	The approved route for changing a case funded by an appropriation that has already expired.
Closure adjustment	A memorandum standing in for a closure certificate where billed amounts cannot be reconciled.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

Money with an expiry date changes how quickly work has to be placed and finished. Sentfore supports defense programs at the delivery end, providing secure transport, protective security, accommodation and site support in complex environments. Requirements can be sent through the contact page.