An FMS case is a candidate for closure when all ordered articles have been physically delivered, all ordered services have been performed, no orders have been placed against an open blanket order case for 180 days or more, the FMS purchaser has confirmed that no orders are forthcoming, and the purchaser has not submitted a request to keep the case open. There are two types of case closure: accelerated and non-accelerated.

C6.8.1. Accelerated Case Closure (ACC). ACC allows a case to be closed after supply or services completion even if there are outstanding un-liquidated obligations (ULOs) on the case. Under ACC, purchaser funds are placed in a case closure suspense account pending final resolution of the ULOs. This program is voluntary, except for those countries that have FMF-funded programs (See DoD 7000.14-R, Volume 15, Chapter 2 for details.) The DSCA (Business Operations Directorate) maintains the master list of countries that participate in the ACC program. Table C4.T2. identifies the countries or organizations participating in the ACC program. Table C6.T9. gives a brief description of ACC eligibility criteria. ACC cases should be submitted for closure within 24 months after an FMS case is Supply and Services Competition (SSC). A subcategory of ACC is Enhanced Accelerated Case Closure (EACC). EACC targets ACC candidates for first priority processing. EACC cases have been supply or services complete for at least 24 months. The DSCA Business Operations Directorate publishes the official EACC quarterly list of these cases to the Military Departments (MILDEPs) for action. Forced closure is implemented when cases have remained on the DSCA EACC list for more than three calendar quarters. In this situation, the DSCA Business Operations Directorate directs DFAS Indianapolis to 'force' close the case in the Defense Integrated Financial System (DIFS). Note that, based on the performance of case closure activities, the DSCA Business Operations Directorate may choose to suspend or reinstate the EACC quarterly list as required.

Table C6.T9. Accelerated Case Closure Eligibility

C6.8.2. Non-Accelerated Case Closure (Non-ACC). Non-ACC procedures are used to accommodate those countries that have not elected to participate in the ACC process and whose FMS programs are completely financed with national funds (vice with FMF). Refer to Chapter 15 for unique case closure requirements for Building Partners Capacity (BPC) program. IAs begin non-ACC procedures after the following actions are complete (See DoD 7000.14-R, Volume 15, Chapter 2 for details.)

C6.8.2.1. Performance and Billing. Performance reports, submitted to DFAS Indianapolis to report all delivered articles and services, have been processed and bills sent to the purchaser. All estimated billings have been converted to actual billings.

C6.8.2.2. Reimbursement of Costs. Costs of articles and services have been reimbursed from FMS Trust Funds to DoD appropriations or USG equity accounts.

C6.8.2.3. FMS Accounting Balances. IA and DFAS Indianapolis accounting balances have been reconciled and all performance and disbursements have been properly reported and accounted for.

C6.8.2.4. Item Discrepancies. All outstanding SDR claims have been submitted to DFAS Indianapolis.

C6.8.3. Estimated Case Closure Dates. On all LOAs except Foreign Military Sales Order (FMSO) I LOAs, IAs must include a note identifying an estimated case closure date. See Appendix 6 for exact LOA note wording. Cases with long-running contracts may experience closure challenges, but for ACC program cases, the estimated closure date is 24 months after the date of projected final delivery or service performance. For non-ACC program cases, the estimated closure date is estimated to be at 36 months after closure of the longest underlying contract (if applicable). If no contracts apply, the closure date should be within 36 months after final delivery or service performance.

C6.8.4. Case Closure Process.

C6.8.4.1. Case Closure Certificate. Case Managers ensure the case closure certificate and any other necessary supporting documentation are completed in accordance with established procedures. All case closure certificates are sent electronically to DFAS Indianapolis.

C6.8.4.2. Case Closures at Reduced or $0 Value. When a case is closed, the USG will retain funds to pay for estimated administrative costs associated with the case, even if no articles or services have been delivered ($0 delivered value). The minimum non-refundable amount will be the greater of: the value of the combined Small Case Management Line (SCML) and the FMS administrative surcharge, one-half of the FMS administrative surcharge estimated on the case, or the standard FMS administrative surcharge percentage of the expended value. The DSCA (Business Operations Directorate) may approve a reduction of the minimum non-refundable amount when the actual administrative cost on the case is shown to be less than one of the three values above, or if the case is cancelled for the convenience of the USG. If an SCML was not included on the basic case and the case was accepted after 31 July 2006 and before 3 July 2012, an SCML must be added when a case is canceled if the value of the case is reduced to the point that an SCML would have been required. This ensures that at least $15,000 in FMS administrative surcharge fees are collected. Case Managers who want to request that a case be closed at $0 value must contact the DSCA (Business Operations Directorate) for approval. Requests should include the following information: case identifier, date of case acceptance, value of the case, delivered amount, minimum amount of surcharge required per policy, recommended surcharge to be collected, a detailed justification for the amount, and any other information the IA deems applicable. The DSCA (Business Operations Directorate) reply is sent to the requestor and DFAS Indianapolis.

C6.8.4.3. Case Closure in DIFS. DFAS Indianapolis reviews the case closure certificate and takes actions to close the case in DIFS. If DFAS Indianapolis has questions about the closure certificate, it contacts the IA representative listed on the certificate. IAs check the DIFS case closure inventory as needed to determine which cases have been closed. DFAS Indianapolis should close all cases that do not have any outstanding or unresolved issues within 30 days of closure certificate and production of a “C1” closure transaction receipt.

C6.8.4.4. Case Closure - DSCA 1238(Q) Report. The DSCA 1238(Q) report tracks closure objectives, actual closure progress during a given fiscal year; resource allocations to the closure function, when available; and the numbers of ACC cases not closed after more than two years SSC based on the FMS purchaser’s request for the case to remain open. This report is prepared by the MILDEPs each quarter and is sent to the DSCA (Business Operations Directorate), see Figure C5.F3. in Chapter 5 of DoD 5105.65-M, FMS Case Reconciliation and Closure Manual, for report format.