The end of the federal government's fiscal year (September 30th) is rapidly approaching, and the usual scramble to make certain that every budget dollar is spent will soon commence. This can provide an agency with a great opportunity to obtain training for its employees. In today's procurement environment, there is a substantial pent-up need for training, since during the past few years training dollars have often fallen victim to budget tightening and sequestration.

Agencies that wisely choose to use their end-of-year dollars for training should make sure, however, that they commit the funds — i.e., actually register for the training — during the current fiscal year (FY), rather than merely setting aside the money for training use. Otherwise, they may fall victim to the "bona fide needs rule," which stipulates that funds be obligated against the appropriation of the fiscal year that the need actually arises. (In 2011, the U.S. Government Accountability Office (GAO) ruled that an agency had improperly obligated training funds against a FY 2010 appropriation because it did not actually register participants until October 2010.)

In general, an agency may charge the cost of a training course beginning in the following fiscal year against the previous year's appropriation when the course meets a bona fide need of the prior fiscal year, scheduling of the course is beyond the agency's control, and the time between procurement and performance is not excessive. But it is critical that agencies actually register for the courses, and not just put the funding aside. Agencies should perform due diligence with their training needs, and know the terms and conditions of the training agencies or contractors that they will employ.

How about your agency?

Tracy Andrle is a Managing Member at the Public Contracting Institute. The Washington, DC-based Public Contracting Institute (PCI) is an instructor-owned, small business dedicated to offering up-to-date, accredited training for government contracts professionals. PCI’s accredited, most up-to-date seminars, webinars, and on-site training meet CLE, CLP, CPE and other continuing education requirements.

Editor’s note: this article was originally posted as a blog entry at the PCI’s blog site.


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