Conclusion
I continue my discussion on this topic, which has recently resulted in heightened interest.
The disbursements from the confidential funds (CF) and intelligence funds are also not excused from compliance with the substantiation requirements. The Joint Circular 2015-01 requires that the disbursements from CF shall be supported with documentary evidence of payment. What is unique in this type of disbursement is that due to the nature of the expenses being confidential in nature, the cash advance vouchers and liquidation of the same are submitted in a sealed envelope.
Cash advance vouchers are required to be submitted to the Commission on Audit (COA) Team Leader within seven days after the release of the check. The liquidation of the same is required to be submitted to the Intelligence and Confidential Fund Audit Unit (ICFAU) within 30 days after each quarter, or from the approved target date of completion of the project or activity, or after the cash advance had been fully utilized whichever comes first. ICFAU is a unit created under the Office of the COA Chairperson in charge of the audit of CF.
Pending liquidation, the documentary evidence of payment is required to be kept in a vault, which may be inspected by the ICFAU or officers/personnel duly authorized in writing by the COA chairperson if the circumstances so demand.
The Head of Agency (HoA) and the designated Special Disbursing Officer (SDO) of the CF are held to a higher degree of accountability. They are bound to institute and maintain sound and effective internal control measures to discourage and prevent irregular, unnecessary, excessive, extravagant, and unconscionable expenditures as well as promote prudence in the use of government resources by those involved in the confidential and/or intelligence operations.
Apart from the timely liquidation and submission of Accomplishment Reports, they are even required to certify under oath, among others, that they are accountable for the disbursements from the cash advance of CF and/or IF, that the expenses were incurred in connection with the agency’s intelligence and/or confidential operations and activities and that the expenditures are necessary and utilized for legal purposes.
It has also been provided in the Joint Circular that the failure of the accountable officer to liquidate the CF, upon demand by any duly authorized officer, shall be prima facie evidence that he has put such missing funds or property to personal use and benefit. In case of misuse of CF, the Budget Officer, Chief Accountant, Treasurer, and Project Officer may likewise be held accountable with the SDO depending on the participation in the transaction.
Moreover, the failure or refusal to comply with the Joint Circular can be a ground for administrative disciplinary action as well as the disallowance of the cash advance granted, without prejudice to the filing of appropriate criminal charges under existing laws against the erring officials or employees.
Clearly, the Joint Circular provided which agencies are entitled and what rules are to be followed starting from the preparation of plans, allocation of budget, utilization, and post-audit. Implementing the guidelines strictly and properly could foster transparency and accountability in the use of confidential and/or intelligence funds, no matter how confidential the nature of the expenses charged under such funds.
Razzel Ann Vergara-Sagono is a graduate of BSA at Polytechnic University of the Philippines-Lopez, Quezon and a Certified Public Accountant. She also has a Master’s degree in Business Administration conferred by AMA University. She is currently working as internal auditor at the provincial government of Camarines Norte.