Implementing a case and warning of delays

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1. From signature to implementation

A signed Letter of Offer and Acceptance (LOA) does not start work by itself. The implementing agency (IA) implements a case once the purchaser has signed it and provided any required initial deposit (SAMM C6.1.1). The case must be implemented in every applicable data system before execution begins. The manual names the Defense Security Assistance Management System (DSAMS), the Defense Integrated Financial System, the Case Performance Reporting Solution and the military department systems.

The IA should then issue detailed implementing instructions to the activities that will execute the case (SAMM C6.1.1). Those instructions must state that implementation is subject to receipt of obligational authority issued by the IA. How that authority is created on the finance side is covered in budget and obligational authority on a case.

2. Emergency implementation

On an exception basis, a case can be implemented before the deposit arrives. The Country Finance Director of the Defense Security Cooperation Agency (DSCA), with approval from the division chief, may process an emergency implementation (SAMM C6.1.2). It is used only when the purchaser has accepted the LOA or amendment and immediate execution is required.

The request goes by email to the Country Finance Director from the purchaser or the IA (SAMM C6.1.2). It names the case and explains the urgency. The manual’s example is meeting a contract award deadline after which prices would rise. The director may ask the purchaser when it expects to send the deposit, then tells the IA and the Defense Finance and Accounting Service (DFAS) of the decision. If approved, DSCA posts an emergency implementation authority milestone in DSAMS and DFAS posts a financial implementation milestone. The IA then processes the obligational authority in DSAMS and the military department systems.

3. Delayed implementation

A case is delayed when it does not implement before its offer expiration date (SAMM C6.1.3). One common reason is a purchaser that accepts the document but does not send the initial deposit by that date. The manual asks purchasers to send the deposit promptly, because failing to do so delays implementation. The manual warns that delay could raise the cost of the case and risk changes to delivery and the period of performance. The IA, with DFAS and DSCA, reserves the right to cancel the LOA or amendment.

The sequence is set out (SAMM C6.1.3.1). The IA posts the acceptance milestone. If no deposit reaches DFAS, it tells the Country Finance Director and, with that director’s approval, notifies the security cooperation organization (SCO), the purchaser’s paying office and the IA. The IA keeps asking when the deposit will come until it arrives. DFAS then posts the financial implementation milestone, and the IA processes the obligational authority.

4. Delivering on time, and warning early

The manual ties delivery to the relationship itself. It describes rapid delivery as a tangible demonstration of American commitment to the government-to-government relationship, so every effort should be made to deliver on time (SAMM C6.2.1). Case managers, with the SCOs, track delivery status (SAMM C6.2.2).

Bad news must be coordinated before it is delivered (SAMM C6.2.3). Any communication telling a partner that the United States cannot deliver must be coordinated in advance with DSCA’s country portfolio director or Country Finance Director in three situations. The first is a case that met the congressional notification thresholds and faces a price rise of 10 percent of case value or $25M. The same applies where such a case faces a delay of more than 6 months in an article or service critical to the operational requirement.

The second covers any case, whatever its value, where a delay may reasonably be expected to damage the bilateral relationship, disrupt planned operations or add significant cost, such as unplanned storage charges (SAMM C6.2.3). The third covers serious concerns about the reliability, availability or serviceability of a major component, one without which the end item cannot operate. DSCA then coordinates a response with the State Department, the Under Secretary for Policy and others as needed (SAMM C6.2.3.1). That coordination also decides which office should deliver the message to the partner. Where there is doubt, case managers are encouraged to assume the situation qualifies.

5. Keeping the record

Case files follow Volume 15, Chapter 6 of the Financial Management Regulation (SAMM C6.2.4). A case may run for several years, and case managers must keep retired files, invoices, bills of lading and other proof of shipment accessible as the audit trail for government and purchaser funds. "The retention period is 10 years after the date of case closure" (SAMM C6.2.4). Cases with large volumes of transactions may keep their documents electronically. Records for articles under enhanced end use monitoring are kept indefinitely by the IA and the SCO, or until the government has verifiable information that the items were properly disposed of. Those records may be stored electronically or in the end use monitoring area of the Security Cooperation Information Portal. The structure of the file is described in the case file and how long it is kept.

Execution records such as case directives, requisitions, shipping documents and billing documents are normally unclassified (SAMM C6.2.5). Every financial and logistics transaction must be recorded in the official case file, and cost statements must be backed by source documents. Where supporting documents are missing, certified memoranda from those responsible are kept. Each disbursement voucher must carry contracts or purchase orders, invoices and receiving reports (SAMM C6.2.6). That documentation also supports case reconciliation. The manual calls complete, accurate and accessible records the key to reconciling and closing a case, and asks case managers to make every effort to keep them that way (SAMM C6.2.5).

Key terms

Implementation	The step that opens a case in every data system once it is signed and any deposit is received.
Emergency implementation	An exceptional implementation before the deposit arrives, approved by DSCA finance.
Offer expiration date	The date by which a case must implement, after which it is delayed and may be canceled.
Major component	An assembled element without which the end item cannot operate.
Retention period	Ten years after case closure for the case file, under the manual.

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

Delays on a case are often decided by conditions on the ground, which is where support matters most. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.