C15.6.1. General. The Implementing Agency (IA) will expend funds or reduce case value before the end of the cancelling year of the funds (i.e., generally the fifth year after the funds expire for new obligation) or other statutorily authorized period. To allow time for residual funds to be redirected or returned before this deadline, DSCA requires that BPC cases funded with expiring/cancelling funds be closed by the IA no later than July 31st of the cancelling year. This means that the IA must ensure that vendors have submitted all invoices and that all outstanding obligations have been paid in full before then. The IA will update the Estimated Closure Date milestone in DSAMS, if appropriate, and begin closure of a BPC case as soon as the case is supply service complete. For further information on case reconciliation and closure, refer to DoD 5105.65-M, Foreign Military Sales (FMS) Case Reconciliation and Closure Manual (RCM).

C15.6.2. Closure Facilitation. Prior to June 30th of the fiscal year preceding funds cancellation, each IA will provide case closure contact information to DSCA (Business Operations Directorate). The individual serving as a closure facilitator for the IA is expected to lead the stakeholders within the respective IA and ensure timely closure of BPC cases. The closure facilitator will direct stakeholders to review cancelling BPC cases as listed in the Security Cooperation Management Suite (SCMS) and identify any case at risk of not closing by July 31st. The closure facilitator will also identify to DSCA (Business Operations Directorate) valid, unliquidated obligations subject to closure/cancellation to determine whether funds are available for future adjustments or payments against such obligations. See DoD Financial Management Regulation (FMR), Volume 3, Chapter 10, 100201.D.

C15.6.3. Reporting Case Financial Status. The IA will input closure status/issues for all cases funded with funds that cancel in the current year on the form at Table C15.T6, available in SCMS (Input Case Option). DSCA (Business Operations Directorate) will download this information monthly beginning in November, bi-weekly beginning in July, and weekly beginning in September.

Table C15.T6. BPC Case Financial Status Update

C15.6.3.1. Reconciling Balances. The IA and DFAS-IN will ensure accounting balances have been reconciled and all performance and disbursements have been properly reported. The IA will also ensure approved outstanding Supply Discrepancy Reports (SDRs) applicable to BPC cases have been submitted to Defense Finance and Accounting Service - Indianapolis (DFAS-IN) for action. BPC cases which have associated open contracts can be closed if no unliquidated obligations exist on those contracts. IAs will prepare the closure certificate and any other necessary supporting documentation in accordance with established procedures. Closure certificates will be sent electronically to DFAS-IN.

C15.6.4. Closure in DIFS. DFAS-IN will review the closure certificate and perform actions to close the pseudo LOA document in the Defense Information Finance System (DIFS). DFAS-IN should close cases containing no inhibitors within 30 days of receipt of the closure certificate and “C1” closure transaction. When DFAS closes the case in DIFS, DIFS sends a transaction to CISIL, MISIL or CMCS to close the case in those systems. When that closure transaction processes, those systems send a transaction to update the status in DSAMS to Closed. IAs can review closure information by referring to their MILDEP systems or to SCIP.

C15.6.5. Financial Activity After Funds Cancel.

C15.6.5.1. Adding Funds to an Open Case. If additional funds are required on a case for which funds have canceled, the IA must contact DSCA (Business Operations Directorate). Under specific conditions, a currently available appropriation may be approved by DSCA (Business Operations Directorate) to pay this requirement. The total of all payments from the current appropriation must not exceed the amount specified in DoD FMR, Volume 3, Chapter 10, 100201.F.

C15.6.5.2. Reopening a Closed Case. It will be necessary for an IA to reopen a BPC case once closed if there is financial activity that impacts the closed case. Should this occur, the IA will send a request to reopen the case, with sufficient justification, to DSCA (Business Operations Directorate) for review and approval.