NB_300_18_30 - NB 300-18-30 LTP – Guidance to States Regarding FY 2018 Easement Internal Controls Preobligation Reviews and Cutoff Date, Prepayment/Closing Blackout Period, and Approved Reviews That Do Not Result in an FY 2018 Obligation
NB 300-18-30 LTP – Guidance to States Regarding FY 2018 Easement Internal Controls Preobligation Reviews and Cutoff Date, Prepayment/Closing Blackout Period, and Approved Reviews That Do Not Result in an FY 2018 Obligation
National Bulletin:  300-18-30 Date: August 27, 2018
Subject:  LTP – Guidance to States Regarding FY 2018 Easement Internal Controls Preobligation Reviews and Cutoff Date, Prepayment/Closing Blackout Period, and Approved Reviews That Do Not Result in an FY 2018 Obligation  


 
Purpose.   To provide States with guidance on how the National Internal Controls Team (National IC Team) will process fiscal year (FY) 2018 easement preobligation review requests submitted during the 4th quarter of FY 2018.  This guidance also provides States with direction on how to handle approved internal controls preobligation reviews that did not result in an obligated agreement. 
 
Expiration Date.   September 30, 2018
 
Background.  National Instruction (NI) 300-300 (amended July 2015) requires specific levels of internal control reviews prior to the obligation and payment/closing of any easement or 30-year contract enrollment.  In prior fiscal years, the National IC Team received packages for review late into September and after the cutoff date published by the Accounts Payable Services Branch (APSB) for obligation and payment package submissions. Although the National IC Team worked with States and processed as many packages as possible, some preobligation packages remained in “Follow up Needed” status at the end of the fiscal year, and not all applications with approved IC reviews were obligated by the end of the fiscal year.  Late submissions to the National IC team are also anticipated in FY 2018.  FY 2018 APSB end-of-year guidance will be forthcoming and must be used in concert with this guidance.        
 

Explanation. This guidance provides States with notification that preobligation IC review requests must be submitted for national internal controls by September 17, 2018, or they will not be approved for obligation in FY 2018.  It also provides States notification that any preobligation review completed and approved in FY 2018, either by the National IC Team or at the State level, that does not end in an obligation during FY 2018 is not valid to move forward towards obligation in FY 2019.  New IC 2019 internal control checklists must be completed and approved before entering into any FY 2019 obligations.  The FY 2019 preobligation internal controls checklists will be released in forthcoming guidance.

        

An active FY 2018 preobligation review is any review that was not approved, rejected, or withdrawn by September 30, 2018. On October 1, 2018, the National Easement Staging Tool (NEST) maintenance request statuses will be set to “Expired” for any active easement FY 2018 preobligation reviews submitted for national-level IC review.  This new status does not apply to prepayment and closing reviews and those reviews will continuing to be processed by the National IC Team beyond FY 2018.

  

In addition, due to the Accounts Payable Services Branch cutoff dates for processing payments and applications—

-   Preobligation IC review requests submitted for national internal controls review after September 17, 2018, will not be processed and will have the maintenance request status set to “Rejected.” This cutoff date for obligation approvals is intended to minimize the negative impact of unreconciled late-September obligations on the NRCS financial statement. 

-   ACEP-WRE prepayment/closing IC reviews not approved by September 21, 2018, will be held for approval until October 1, 2018.  This blackout period for closing and payment approvals, for ACEP-WRE only, is intended to minimize the negative impacts of unreconciled late-September closings and payments on the NRCS financial statement. 

 

States are reminded to enter all closing dates in NEST prior to September 30, 2018.   As a reminder, national IC reviews can take up to 30 days after submission of the NEST MR if there are no findings.  Accordingly, States are advised to submit national IC reviews well in advance of the published APSB cutoff date.

 
Contact.  If you have questions or concerns regarding this national bulletin, contact the National IC Team at NRCS.Internalcontrols@wdc.usda.gov.    
 
 

 /s/                                                                                       /s/

 

Jeffrey Machelski                                 Jimmy Bramblett

Chief Financial Officer                                Deputy Chief for Programs

 
 
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