Lesson 12: Approving and Certifying Officials

What is an Approving Official (AO)?

Specific to the purchase programs, the AO is an individual (typically a supervisor) responsible for ensuring that the purchase card/account is used properly by the agency. The AO also authorizes card/account holder purchases (for official use only) and ensures that the statements are reconciled and submitted to the Designated Billing Office (DBO) in a timely manner.

What is my role as an AO?

There are many important responsibilities entrusted to the AO, including:

• Ensuring that all purchases made by the card/account holder(s) within his/her span of control are appropriate and the charges are accurate. Purchases should not only be legal and proper, but also should be considered “mission essential”. In order to ensure proper purchases, the AO must review and approve card/account holder statements belonging to all card/account holders within their purview. The AO’s review should include looking at all required receipts and card/account holder logs.
• Counseling card/account holders within his/her span of control regarding regulations, misuse and delinquency.
• Resolving all questionable purchases with the card/account holder. Upon review of receipts and account-holder logs, if the AO finds a questionable purchase, they must work with the card/account holder to receive more information regarding the purchase in order to determine the legitimacy of the purchase.
• Elevating unresolved, questionable purchases to the agency/organization program coordinator (A/OPC). In the event an unauthorized purchase is detected or there is a purchase that is still in question after review of supporting card/account holder documentation, the AO must notify the A/OPC as well as any other appropriate personnel in accordance with agency policy. This may include notifying the agency’s Office of the Inspector General (OIG) for further investigation relating to potential misuse.
• Ensuring monthly billing account accuracy. The AO signs the account statement and maintains documentation regarding the account in accordance with agency procedures.
• Conducting informal compliance reviews for all card/account holders under their span of control. These reviews should be completed in accordance with the agency-specific policies (e.g., frequency, format).
• Assisting A/OPCs and card/account holders with their responsibility to obtain, maintain and retain complete documentation of all purchases.

Many agencies may provide additional responsibilities for the AO within their agency’s policies. It is important that the AO reviews the agency-specific policies before beginning their official duties.

Please note that AOs may be held financially responsible for payments made on accounts because of failure to ensure billing account accuracy. It is also important that the AO reviews the agency-specific policy regarding reimbursement and disciplinary actions.

What is a Certifying Official?

A Certifying Official is an individual who has been charged with the responsibility of authorizing certified vouchers for payment and ensuring that funds are available for obligation before payment. The Certifying Official is held accountable for verifying that payments made by the federal government are legal, proper and correct.

Please note that the OMB Circular A-123, Appendix B [PDF, 71 pages] and the GSA SmartPay® Master Contract language use the terms AO and Certifying Official synonymously. In the case of many agencies/organizations, the individual that holds the title of AO also holds the title of Certifying Official. However, the roles of AO and Certifying Official may be separate functions in some agencies/organizations.

What is my role as a Certifying Official?

United States Code Title 31 Section 3528 states the roles and responsibilities of a Certifying Official.

Certifying Officials are responsible for:

• Information stated in the certificate, voucher and supporting records.
• Computation of the certified voucher.
• The legality of the proposed payment under the appropriation or fund involved in the payment. In other words, the Certifying Official must make sure that the line of accounting that is utilized to pay the voucher aligns with the type of items purchased.
• Repaying a payment if the payment was certified and was illegal, improper or incorrect due to negligence on the part of the Certifying Official or was not paid out of the correct appropriation due to negligence on the part of the Certifying Official.

In the case of the purchase program, the Certifying Official will most often rely on other members of the Government Purchase Team (such as the card/account holder and the AO) to review the supporting records. However, the Certifying Official still has a responsibility to assess the accuracy of the data while performing the certification process and to report suspect transactions to the A/OPC and appropriate investigative office.

Many agencies may provide additional responsibilities for the Certifying Official within their agency’s policies. It is important that the Certifying Official reviews the agency-specific policies before beginning their official duties.

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