U.S. Fish and Wildlife Service logo
United States Department of the Interior 

                                      FISH AND WILDLIFE SERVICE     
                                               Washington, D.C. 20240

DOI 150th Anniversary logo
 In Reply Refer To:
 FWS/DF                                                                                                                          JAN 4, 1999
 

Memorandum
 
 
To: Service Directorate 
From: Deputy Director
Subject: Payments by Electronic Funds Transfer 
The Debt Collection Improvement Act of 1996 requires that all Federal payments made after January 1, 1999, be made electronically, unless specifically waived. On September 25, 1998, the Department of the Treasury issued its final rule regarding Electronic Funds Transfer (EFT) requirements of the Act. On November 19, 1998, the Department of the Interior issued policy guidance on implementing the final rule. Attachment 1 contains the Service's policies and procedures for implementing EFT requirements of the Act. Attachment 2 is a copy of the Department of the Interior's policies on EFT compliance.

Currently, 95 percent of Service employees receive their salary electronically and 85 percent of travel payments are made electronically. Please note that employees who do not receive payments electronically must request and submit a waiver to continue receiving payments by Treasury checks. Employees may experience delays if waivers have not been requested and entered into the Service's finance system. Procedures for employees to begin receiving payments electronically or requesting waivers are provided in the Director's memorandum of August 4, 1998, attachment 3. Authority to approve waivers is delegated to Regional Directors and may not be delegated further than the Regional Finance Officer.

A continuing effort is being made by the Divisions of Contracting and General Services and Finance to obtain vendor EFT information.

If there are any questions regarding this matter, please contact Ed Buskirk at (703) 358-1742 extension 9 then 3.
 

                                                                            /s/ John G. Rogers
Attachments


Attachment 1
Payments by Electronic Funds Transfer
Implementing Policies and Procedures
Fish and Wildlife Service

Employee Payments

Electronic payments to employees was addressed in the Director's memorandum dated August 4, 1998.  The memorandum indicated that by September 30, 1998, all employees should receive their salary, travel advances (including all Permanent Change of Stations), travel vouchers, and miscellaneous expense payments via Electronic Funds Transfer (EFT).

If an employee does not desire to enroll in EFT, they must complete the waiver process as outlined in the Director's August 4, memorandum.

Volunteer Payments

Volunteers receiving incidental expense reimbursements and recognition awards are considered recipients of Federal payments. As such, they are to receive payments electronically or be granted waivers. Please request that each volunteer provide the information necessary to initiate electronic payment by completing and returning Attachment lb, ACH Enrollment Form, to the Denver Administrative Service Center (DASC), Fiscal Service's Unit. Volunteers who choose not to accept electronic payments are granted a blanket waiver, and no volunteer is to be denied or delayed payment. Please note, all volunteers receiving waivers should provide their name and social security number which is to be forwarded to the DASC. This information will be entered on the VEND table and will serve to document that a waiver has been obtained.

Vendor Payments

In July 1998 the Service's Finance Center sent 3400 letters to vendors with whom the Service had made payments from January through April 1998, but had not received EFT information. To date over 1100 vendors have responded to this mailing. The Finance Center will issue a second mailing in mid-December to those who did not reply and a first mailing to those vendors paid with paper checks since April.

There are two methods by which each Region can assist in increasing EFT compliance. First, encourage the use of the Government purchase credit card. Each credit card transaction is considered EFT compliant. Second, ensure that all information is collected to process new vendor payments electronically.

Please refer to the section below for procedures concerning waivers for vendors.

Imprest Fund Payments

Imprest funds are not considered EFT compliant. Accordingly, these type of payments should be greatly reduced. Organizations currently using imprest funds should instead use the Government purchase credit card or, FEDSELECT for vendors that do not accept the credit card. Other disbursements of $500 and less should be made by Remote Data Entry in FFS. An annual review of existing imprest funds must be conducted to verify the need of the authorized amount.

Vendor EFT Waivers

The Department of the Treasury's final rule outlined seven conditions for obtaining an EFT waiver. Waiver approval is delegated to the Regional Director and may be not be delegated further than the Regional Finance Officer. For Region 9, waiver approval is delegated to the Chief, Division of Finance, but may not be delegated further than the Chief, Branch of Financial Policy Region 9 Finance Office.

Waiver Requested by an Individual (Sole Proprietor) Vendor
 
Condition la Any individual who does not have an account at a financial institution is automatically waived from the EFT requirement.
Condition lb An individual with or without an account with a financial institution determines that payment by EFT would impose a hardship due to a physical or mental disability, a geographic barrier, or financially
Waiver Requests Involving Natural Disasters, Public Safety, or Foreign Payments
 
Condition 2 The political, financial, or communications infrastructure of a foreign country does not support payment by EFT.
Condition 3 Where the payment is to a recipient within an area designated by the President or an authorized agency administrator as a disaster area. This waiver is limited to payments made within 120 days after the disaster is declared. 
Condition 4 A response to contingency operations conducted by or in support of the Department of Defense.
Condition 5 Where payment by EFT may pose a threat to national security, the life or physical safety of an individual may be endangered, or a law enforcement action may be compromised. 
 
Waiver Requests for Non-Recurring Payments or Public Expedience
 
Condition 6 Where the agency does not expect to make more than one payment to the same recipient within a one year period, and the cost for making the payment by EFT exceeds the cost of making the payment by check. 
Please note: The Service determines if it is more cost effective to make the payment electronically or by check. The Service will not be expected to document a cost/benefit analysis for each non-recurring payment.
 
Condition 7 Where the Service's need for goods and services is of such unusual and compelling urgency that the Government would be seriously injured unless payment is made by a method other than EFT or where there is only one source for the goods or services and the Government would be seriously injured unless payment is made by a method other than EFT. 
Please note: An example of a transaction which would qualify for this waiver is the purchase of real property.

Waivers under Conditions 1a and 1b require the individual or vendor to request the waiver. Attachment Id, EFT Waiver Request Form is to be used for these instances.

Waivers under Conditions 2 through 7 are granted without contacting the vendor. The determination to grant these waivers is a decision by the Service that conditions do not permit EFT payment or it is not cost effective to make the payment by EFT. For each payment received where there is no EFT data or waiver information on the at the bottom of the VEND table, the decision must be made to either request the EFT data or grant a waiver under Conditions 2 through 7. All waivers are to be documented in accordance with the Service's procedures and are subject to review by the Department of the Treasury. Attachment 1 e, Internal EFT Waiver Request Form is to be used for Conditions 2 through 7.

General Procedures

Employees

All new hires will continue to be asked to complete the necessary information to receive their salary via EFT. All employees seeking a Government charge card for travel will continue to be asked to complete the necessary information to receive their travel reimbursement via EFT. All other employees were addressed in the Director's August 4, 1998 memorandum, attachment 3.

If the employee has been authorized a waiver this information will appear in the Bank Information section at the bottom of the VEND table, the BANK NAME field will say WAIVER OBTAINED.

Volunteers

Volunteers have been authorized a blanket waiver. For those volunteers executing the waiver by providing there name and social security number, this information will appear in the Bank Information section at the bottom of the VEND table, the BANK NAME field will say VOLUNTEER WAIVER.

Vendors

After January 4, 1999, vendor invoices will be considered "incomplete" if there is no EFT or waiver information concerning the vendor in FFS. Incomplete invoices are not subject to prompt pay provisions and therefore, will not be entitled to interest penalties for late payments until the invoice is complete. Incomplete invoices are to be returned to the vendor within seven calendar days. If the vendor has obtained a waiver it will appear in the Bank Information section at the bottom of the VEND table, the BANK NAME field will say WAIVER OBTAINED.

Invoices returned to the vendor should be accompanied by attachments 1a, Letter Requesting EFT Enrollment, and lb, ACH Enrollment Form. If the vendor completes the ACH Enrollment Form, the vendor should fax the invoice and form to the requesting office. The requesting office should fax the ACH form to the DASC Fiscal Services Unit for input into FFS. When entering the payment, the DATE INVOICE RECEIVED will be the date the invoice and the ACH form were received. The vendor should mail the original ACH form and invoice back to the requesting office. The requesting office station should ensure that the original invoice is filed, not the fax copy. The original ACH form should be sent to the DASC Fiscal Services Unit.

If the vendor believes they qualify for a waiver, the request for a waiver must be made in writing. When a vendor requests a waiver send attachments 1c, Letter to Vendor Requesting EFT Waiver, and 1d, EFT Waiver Request Form. The vendor should return the original invoice with their written waiver request.

If the request for a waiver is denied, send the vendor attachment 1f, Letter to Vendor Denying EFT Waiver. It is not incumbent upon the reviewers of waivers to do extensive research to determine the validity of a vendor's request. Once the ACH Enrollment form is received from the vendor fax it to the DASC Fiscal Services Unit for input into FFS. When entering the payment the DATE INVOICE RECEIVED will be the date the invoice and the ACH form was received. The original ACH form should be sent to the DASC Fiscal Services Unit.

If the request for a waiver is approved, the DATE INVOICE RECEIVED will be the date the waiver was approved.

If a waiver is granted under Conditions 2 through 7 complete attachment le.

Once a waiver is approved the original waiver will be maintained at the DASC. It is suggested that the office approving the waiver retain a copy until the VEND table is updated.


Attachment la
Sample Letter Requesting EFT Enrollment
Office Letterhead

Company Name
Company Address

Dear Sirs:

The Debt Collection Improvement Act requires most Federal payments to be made electronically. We do not have the necessary information to electronically pay your invoice_____________dated_________.  Please complete the PAYEE/COMPANY INFORMATION section and the FINANCIAL INSTITUTION INFORMATION section of the attached form and return it and your original invoice to the above address as soon as possible. We will schedule your invoice for payment when we receive this information. You may expedite the process by faxing this letter, the attached form, and the invoice to (XXX) XXX-XXXX. However, please return the original form and original invoice to the address above.

The Debt Collection Improvement Act allows for waivers to the electronic payment requirement in certain instances. Individuals may apply for a hardship waiver, while corporations, partnerships, universities, government units, etc. may apply for waivers under limited conditions. If you believe you qualify for such a waiver, please contact us at the above address and we will send you a waiver request form.

Questions may be directed to________________________or_________________________

Attachments
ACH Enrollment Form
Invoice_____________


Attachment 1b
ACH Vendor / Miscellaneous Payment Enrollment Form

To open Attachment 1b (available as an Adobe PDF file), click here.


Attachment lc
Sample Letter to Vendor Requesting EFT Waiver
Office Letterhead

Company Name
Company Address

Dear Sirs:

On__DATE___we requested that you provide the necessary information to allow us to electronically pay your invoice___________________dated____________.  You responded by requesting a waiver to the electronic payment requirement. Attached is the form to be used in requesting this waiver.

Please complete the attached EFT Waiver Request Form and return it to the above address as soon as possible. It will take a week or more to process your request. You may expedite the process by taxing the attached form to (XXX) XXX-XXXX. However, please return the original form and original invoice to the address above.

For your convenience we have also attached the ACH Enrollment Form which is needed to provide the information to electronically pay your invoice in the event you no longer wish to request a waiver. In that case, please complete the PAYFE/COMPANY INFORMATION section and the FINANCIAL NSTITUTION INFORMATION section of the attached form and return it to the above address as soon as possible. We will schedule your invoice for payment when we receive this information.

Questions may be directed to________________________or____________________

Attachments
Waiver Request Form
ACH Enrollment Form


Attachment 1d
EFT Waiver Request Form

The Debt Collection Improvement Act of 1996 requires that all payments be made by electronic funds transfer (EFT) after January 1, 1999. Waivers to this requirement may be granted under the conditions described below. Please mark the condition which applies and complete the information requested at the bottom.

Waiver Requested by an Individual (Sole Proprietor) Vendor

Condition 1a  [ ]  I (we) do not have an account with a financial institution.

Condition lb   [ ]  Payment by EFT would impose a hardship due to a physical or mental disability,
                            a geographic barrier, or financially.

Vendor Name __________________________________________________________________

Vendor Address ________________________________________________________________
 
                          ________________________________________________________________

Vendor Contact Name ______________________________________________

Vendor Contact Phone Number _______________________________________

Explanation of Waiver Request (Please explain how/why you meet the condition marked)

_____________________________________________________________________________

_____________________________________________________________________________

_____________________________________________________________________________

---------------------------------------- For Govemment Use Only -----------------------------------

   [ ] Approved     [ ]  Not Approved

Signed  _______________________________                Title ____________________________


Attachment le
Internal EFT Waiver Request Form

The Debt Collection Improvement Act of 1996 requires that all payments be made by electronic funds transfer (EFT) after January 1, 1999. Waivers to this requirement may be granted under the conditions described below. Please mark the condition which applies and complete the information requested at the bottom.

Waiver Requests Involving, Natural Disasters, Public Safety, or Foreign Payments
 
 
Condition 2     [ ] The political, financial, or communications infrastructure of a foreign country does not support payment by EFT. 
Condition 3     [ ] Where a natural or other disaster makes payment by EFT not feasible.
Condition 4     [ ] A response to contingency operations conducted by or in support of the Department of Defense. 
Condition 5     [ ] Where payment by EFT may pose a threat to national security, the life or physical safety of an individual may be endangered, or a law enforcement 
action may be compromised. 
 
Waiver Requests for Non-Recurring Payments or Public Expedience
 
Condition 6    [ ] Where the agency does not expect to make more than one payment to the same recipient within a one year period. 
Condition 7     [ ] Public necessity suggests that payment by other than EFT is in the best interest of the Government. 
Explanation of Waiver Request (Please explain how the condition marked was met)

_____________________________________________________________________________

_____________________________________________________________________________

_____________________________________________________________________________
 

Signed ______________________________          Title _________________________________


Attachment 1f
Sample Letter to Vendor Denying EFT Waiver
Office Letterhead

Company Name
Company Address

Dear Sirs:

On__DATE_____we requested that you provide the necessary information to allow us to electronically pay your invoice____________dated__________.You responded by requesting a waiver to the electronic payment requirement.

You requested a waiver based upon___________________________.  Upon reviewing this request your authorization for a waiver is denied because_________________________________.

Please complete the PAYEE/COMPANY INFORMATION section and the FINANCIAL INSTITUTION INFORMATION section of the attached ACH Enrollment Form and return it to the above address as soon as possible. We will schedule your invoice for payment when we receive this information. You may expedite the process by faxing the attached form and invoice to (XXX) XXX-XXXX.

Questions may be directed to____________________or______________________________.

Attachments
Waiver Request Form
ACH Enrollment Form
 


 Attachment 2
 
U.S. Fish and Wildlife Service logo
United States Department of the Interior 

                                      FISH AND WILDLIFE SERVICE     
                                               Washington, D.C. 20240

DOI 150th Anniversary logo
                                                                                                                   NOV 19, 1998
Memorandum
 
 
To: Bureau Chief Financial Officers
From: /s/ John Berry 
Assistant Secretary - Policy, Management and Budget 
Subject: Departmental Policy on Electronic Funds Transfer Payment 
Requirements of the Debt Collection Improvement Act of 1996 
Attached is the Department's policy guidance on implementing the electronic funds transfer (EFT) requirements of the Debt Collection Improvement Act (DCIA) of 1996. The Treasury Department issued the final regulation (31 CFR Part 208) on EFT on September 25, 1998.

If you have questions or require additional information concerning this matter, please contact Sky Lesher on (202) 208-4701.

Attachment


POLICY ON COMPLIANCE
WITH ELECTRONIC FUNDS TRANSFER
PAYMENT REQUIREMENTS

I. Background

The Debt Collection improvement Act (DCIA) of 1996 requires that all payments (with few exceptions) be made by electronic funds transfer (EFT) after January 1, 1999. The implementing regulation issued by the U.S. Treasury is found in 31 CFR Part 208 and sets forth the conditions under which waivers from EFT payment requirements are appropriate. Treasury Regulations provide seven waiver conditions from EFT payments.

The first waiver condition allows individuals (includes employees and sole proprietors) to self determine whether the use of EFT would impose a hardship due to a physical disability, mental disability, language, literacy or a geographic barrier or where the use of EFT would impose a financial hardship. The waiver is based on the individual's self-assessment that a hardship exists.

For remaining waiver conditions ( i.e., Conditions 2 through 7), the U.S. Treasury has delegated agencies the authority and responsibility for making determinations as to whether a payment or class of payments falls within one (or more) of the waiver categories. Waivers are allowed for an indefinite amount of time unless the condition warranting the waiver is no longer met. Treasury reserves the right to review agency compliance with EFT waiver requirements.

II. Policy

A) General.
It is the policy of the Department to utilize electronic payment mechanisms to the fullest extent possible. All payments to non-Federal recipients effective January 2, 1999 are presumed to be made by electronic funds transfer or other EFT compliant alternatives such as those identified below:
 

For: Use: 
Wage and Salary Payments DD/EFT 
Payment of Employee Awards  FPPS and DD/EFT
Travel reimbursement vouchers, local and TDY  DD/EFT 
Cash Advances for Official Travel  ATM privilege and DD/EFT (non-cardholders) 
Official Travel Expenses Government Contractor- Issued Charge Card 
Miscellaneous Purchases Government Contractor- Issued Charge Card 
Fleet and Vehicle Expenses Government Contractor- Issued Charge Card 
Vendor Payments EFT
 

B) Use of Convenience Checks - Blanket Waiver Condition.
Selected holders of the government contractor-issued charge card for the purchase business line will have convenience check privileges. Convenience checks may be used without additional waiver when the government contractor-issued charge card is not accepted by a given merchant. However, any other uses of convenience checks will require a documented E.FT waiver by authorized bureau personnel.

C) Waiver Conditions.
When payment by EFT is not possible a waiver must be obtained. Waiver condition numbers are listed and identified as in the final Treasury regulation.

D) Bureau Administrative Requirements.
Attachment 3
 
DOI logo
United States Department of the Interior 

                                      FISH AND WILDLIFE SERVICE     
                                               Washington, D.C. 20240

IN REPLY REFER TO:
FWS/DF

Memorandum
 
 
To: All Fish and Wildlife Service Employees
From: Dupty Director                     /s/ John G. Rogers     AUG 4 1998
Subject: Electronic Payment to Employees 
The Debt Collection Improvement Act (DCIA) of 1996 requires Federal agencies to convert all Federal payments from checks to electronic funds transfer (EFT) no later than January 2, 1999. To accomplish this objective with regard to payments to employees, September 30, 1998, has been established as a goal for the following type of payments:

It is mandatory for all employees to enroll in the EFT Program by September 30, 1998.

The Service, via the authority of the Government Management Reform Act of 1994, implemented EFT for Federal wage and salary payments of all newly hired employees hired on or after December 22, 1996. Human Resources Management Bulletin 96-3 (November 20, 1996) established Departmental policy on paying employee salary and wages electronically. Currently 94 percent of Service employees have their salary checks deposited through the EFT process.

The Service also implemented the payment of travel vouchers through the EFT process as of August 1, 1995. Although the program is very successful, there are approximately 2,072 travelers who have not enrolled in the program. To date, 68 percent of our travelers receive their payments electronically.
 
Receiving payments by EFT results in:

The following policy is established for full implementation of EFT payments:

Travel and Miscellaneous Expenses

If you are not receiving payments for travel and/or miscellaneous expenses via EFT, complete the SF-3881, ACH Vendor/Miscellaneous Payment Enrollment Form. This form may be obtained from your Regional Finance Office (RFO), (Attachment 1). Once completed, return the "Agency Copy" of the form to the appropriate RFO for processing. To ensure electronic notification of the payment to you, please include your Service e-mail address in the 'Additional Information' block under Agency Information.

Salary Payments

As a condition of employment, all employees are expected to receive salary payments via EFT. Specifically, employees are expected to make a commitment on their first day of appointment to participate in direct deposit of pay or request a waiver of this requirement. Employees will then have up to 2 pay periods from the date of their appointment to complete the information required by the direct deposit transaction.

If you are among the 6 percent of Service employees not receiving salary via EFT, please see your Servicing Personnel Office and complete the SF-1199A, Direct Deposit Sign-Up Form (Attachment 2); or, you may process your enrollment through Employee Express. Failure to enroll could result in possible adverse personnel action.
 
Waivers

In implementing the EFT payment requirement, the Department of the Treasury has indicated that waivers of the EFT payment requirement will be available. Waivers may be provided for employees hired before December- 22, 1996, but will be approved only if severe extenuating circumstances exist which will pose a major hardship on the employee. To request a waiver, an employee must complete the Waiver Request Form (Attachment 3). Waivers approved in the past are no longer valid. Each request will be reviewed on a case-by-case basis and will require the approval of the Regional Director, and/or the Washington Office Division of Finance. Criteria for obtaining a waiver include:

Waiver requests are to be forwarded through the appropriate RFO to the Regional Director and/or Chief, Division of Finance by September 30, 1998.

Questions should be directed to Ms. Shelia Dade, Division of Finance at (703)358-1742, ext. 4.

Attachments


Attachment 3-1
ACH Vendor / Miscellaneous Payment Enrollment Form

To open Attachment 3-1 (available as an Adobe PDF file), click here.


Attachment 3-2
Direct Deposit Signup Form

To open Attachment 3-2 (available as an Adobe PDF file), click here.


Attachment 3-3
WAIVER REQUEST

Memorandum

To:          Regional Director or Chief, Division of Finance

From:      Name of Employee

Subject:  Waiver Request from Electronic Funds Transfer Payment

I request a waiver of the Electronic Funds Transfer (EFT) payment requirement for the following reason(s):

____________________________________________________________________________________
Signature of Employee                                                                                      Date

____________________________________________________________________________________
Concurrence - Regional Finance Officer                                                            Date

____________________________________________________________________________________
Approved/Denied - Regional Director or Chief, Division of Finance                   Date
 
 



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