THE UNIVERSITY OF CALIFORNIA
Office of the Vice President--Financial and Business Management
CONTRACT AND GRANT Memo Operating Guidance
April 14, 1982
Invoice Certification Requirement - California State Department of Health Services
Effective January 1, 1982, the Administrative Division of the Department of Health Services began requiring that the DHS program staff person authorizing payment on invoices certify that under penalty of perjury the amounts contained in the invoice are authorized and properly payable (See Enclosure 1).
Shortly after this issuance, the Genetic Disease Section of DHS sent a letter to the University (See Enclosure 2) passing the invoice certification requirement on to the University by requiring that invoices submitted to DHS include the following statement, signed by the University contract liaison person:
I hereby certify under penalty of perjury as follows: That amounts, as contained therein, are properly payable and that such payments are authorized in the amount, for the period, and to the respective payees as indicated, under all governing laws and regulations.
This certification statement extends the personal liability of the University personnel signing the invoice to an unacceptable degree. Therefore, it is suggested that the customary University certification statement or equivalent continue to be utilized on invoices, as follows:
I certify that all expenditures reported (or payment requested) are for appropriate purposes and in accordance with the provisions of the application and award documents.
Subsequently, the UCLA campus informed George Cunningham, the Genetic Disease Section chief, that it would continue using the University certification (See Enclosure 3). He agreed that it would be allowable.
However, if other DHS chiefs attempt to impose the State' s revised certification upon the University, it is recommended that he or she be informed that the University intends to continue utilizing the foregoing University certification, which is the federal certification language as contained in OMB Circular A-21 (refer again to Enclosure 3 as a sample letter). It is also suggested that a copy of the letter to the DHS chief accompany the invoices submitted to DHS if there is a request for the University to use DHS penalty of perjury certification.
If there are any problems in accomplishing the above, please let us know so that we can coordinate efforts with DHS to continue to use the University' s certification statement.
Refer: Mona Litrownik
Index: California, State of
David F. Mears
University Contracts and Grants Coordinator
State of California
To: Section Chiefs and Above
Department of Health Services
Date: December 10, 1981
Subject: Approval of Claims
From: Administration Division 8/1190, 2-4060
On June 30, 1981, you were advised that each invoice submitted to the Accounting Section must contain a certification statement signed by appropriate program staff authorizing payment. ..
Due to the concern raised by same units, the original certification will be modified to reflect the following statement:
"I hereby certify under penalty of perjury as follows:
That amounts, as contained herein, are properly .payable and that such payments are authorized in the amount, for the period, and to the respective payees as indicated, under all governing laws and regulations."
It is the responsibility of each program manager to maintain surveillance of contracts and agreements to assure that expenditures are made in accordance with provisions within the contract and/or agreement and law and rules in existence governing payment of claims.
The Accounting Section relies on this invoice approval for its assurance that the contractor/vendor has complied with specific provisions of the agreement, and the invoice is therefore appropriate and authorized for payment.
Effective January 1, 1982, program staff will be required to certify that invoices do, in fact, meet the criteria given above. The certification statement must be stamped or written on each invoice submitted to the Accounting Office for payment and the responsible person in each office must sign the statement indicating the invoice has been reviewed and approved. Invoices received after January 1, 1982, which do not have the above certification will be returned to the program.
Business Services will be requested to order stamps reflecting the certification statement. These will be distributed as soon as possible. The original stamp may be used in lieu of this modification pending the receipt of
DEPARTMENT OF HEALTH SERVICES
January 6, 1982
T0: Robert S. Sparkes, M.D. UCLA
UCLA School of Medicine
Los Angeles, California 90024
RE: CONTRACT #81-77958
Effective January 1, 1982, the Administrative Division of the Department of Health Services is requiring a written statement certifying that all invoices received are properly payable and legal ....
In order to make this certification we must have a similar statement signed by the person specified in the contract as principal contract liaison.
Any invoices received without the following certification will not be processed but will be returned to the contractor.
"I hereby certify under penalty of perjury as follows: That amounts, as contained therein, are properly payable and that such payments are authorized in. the amount, for the period, and to the respective payees as indicated,. under all governing laws and regulations."
cc: Contract and Grant Accounting Department
UNIVERSITY OF CALIFORNIA, LOS ANGELES
OFFICE OF CONTRACT AND GRANT ADMINISTRATION
LOS ANGELES, CALIFORNIA 90024
February 10, 1982
State of California - Health and Welfare Agency
Department of Health Services
2151 Berkeley Way
Berkeley, California 94704
Chief, Genetic Diseases Section
SUBJECT: Contract No. 81-77958
Dear Dr. Cunnningham:
This letter is a follow-up to our telephone conversation, regarding your letter of January 6, 1982, to Dr. Robert Sparkes requiring his signature on a payment request certification. As I indicated, the only authorized individual on our campus to certify the accuracy of invoices is Mr. Theodore J. Alexander, Manager of Contract and Grant Accounting. Mr. Alexander does certify the accuracy of all invoices submitted. The statement you provided to be signed, however, is unacceptable in that it greatly extends the level of personal responsibility beyond that required by other State agencies or by the Federal government. The statement which Mr. Alexander signs for all of our funding sources is contained in 0MB Circular A-2I, Revised, and is as follows:
"I certify that all expenditures reported (or payment requested) are for appropriate purposes and in accordance with the provisions of the application and award documents."
We will continue to use this certification statement, and strongly urge your Department to find it acceptable and sufficient.
Matthew C. Starr, Ph.D.