M28C.V.B.2 M28C.V.B.2 Invoice Payments

2.01 General Information

(Change Date December 18, 2019)

The Invoice Payment Processing System (IPPS) is used by Veteran Readiness & Employment (VR&E) staff to authorize services and supplies and process invoices. IPPS interfaces with Tungsten, which is the system used by vendors to view the details of a service authorization.

Vendors used for VR&E purposes must not register in Tungsten unless a facility code has been issued. VR&E staff members are responsible for ensuring appropriate authorizations of payments, including assignment of a facility code to a vendor prior to instructing a vendor to register in Tungsten.

2.02 Authorizing Services and Supplies

(Change Date August 26, 2019)

The case manager must ensure that the guidelines for determining the levels of authority for program costs outlined in M28C.V.B.1 are properly implemented.

Refer to M28C.V.B.1 for guidelines for authorizing rehabilitation training, services, and supplies.

2.03 Roles and Responsibilities

a. Facility

(Change Date December 9, 2019)

When a facility receives an authorization of funding for a VR&E claimant, the facility must take the steps listed below:

The facility must process a billing invoice for VA in Tungsten after the facility’s drop/add period.

The facility must bill VA only for the actual cost of tuition and fees assessed by the facility for the claimant's training program after the application of the following:

(a) Any waiver of, or reduction in, tuition and fees.

(b) Any scholarship, federal, state, institutional, employer-based aid, or financial assistance that is provided directly to the institution and specifically designated for the sole purpose of defraying tuition and fees (other than loans and Pell grant).

The facility must properly manage and disburse financial assistance. The facility must notify VR&E when a funding designated specifically for payment of tuition and fees was erroneously applied or released to the claimant for other purposes, and VR&E has paid the outstanding costs of tuition and fees.

The case manager must ensure that all errors in accounting and/or disbursing funds are corrected by the facility. Additionally, any funds that are unused by, or recouped from the claimant or another source must be returned to the appropriate funding source including VR&E. Refunds to VR&E by vendors must be handled by issuing a credit memo in Tungsten and retrieved by the case manager in IPPS. Refer to section 2.05.b of this chapter for more information on issuing credit memos.

b. Case Manager

(Change Date December 10, 2019)

The case manager should refer to the IPPS USER GUIDE for detailed information on certifying invoices from submitted by facilities using Tungsten and processed in IPPS.

c. Invoicing

1. Tuition and Fee Payments

(Change Date December 10, 2019)

The case manager must ensure the authorization is sent to the training facility or vendor via IPPS. This will allow the training facility or a vendor to invoice VA for the claimant’s approved training expenses.

For more information on Authorizations in IPPS refer to the IPPS User Guide.

2. Foreign Training Facilities

(Change Date December 18, 2019)

An authorization for training facilities in foreign countries cannot be processed in IPPS since these facilities do not have a U.S. Tax Identification Number.

A completed VAF 28-1905 must be sent to the facility for authorization. These facilities may invoice VA by sending the bill via email or postal delivery.

Refer to M28C.V.C.1 for information on handling foreign cases, including invoice authorization.

3. Tutorial Services

(Change Date July 15, 2022)

Tutorial contracts are required for recurring tutorial assistance and payment that exceeds the $2,500 threshold annually.

Invoicing and payments are processed through the Invoice Processing Payment System (IPPS).

Tutorial services that do not exceed the $2,500 limit may be paid using the government purchase card if the tutor accepts the government purchase card. If the tutor does not accept the government purchase card, the tutorial services may be paid using a purchase order. The CO assistance is required to develop the purchase order.

Refer to M28C.V.B.3 for details on requirements for approval and authorization of tutorial services.

4. National Contract Invoices

(Change Date July 15, 2022)

National Contract invoices are processed through the Invoice Payment Processing System (IPPS), which is an automated web-based system that is maintained by the Administrative and Loan Accounting Center (ALAC).

Refer to M28C.V.B.3 for more guidance on invoicing for National Contracts.

5. Goods or Supplies

(Change Date November 7, 2013)

A facility may provide a claimant with standard supplies that are required for similarly circumstanced individuals and approved by VA.

The case manager must review all invoices to determine if the supplies the claimant received are required or needed to complete the vocational goal outlined in the claimant's rehabilitation plan.

Refer to M28C.V.A.3 for more information on purchasing supplies.

2.04 Reviewing Invoices and Processing Payments

a. Review of Invoices

(Change Date December 18, 2019)

In accordance with 5 CFR 1315.9(b), at a minimum a proper invoice must meet the following requirements:

• Name of vendor
• Invoice date
• Invoice number, account number and/or any other identifying number
• Vendor point of contact name, title and telephone number (whenever possible)
• Claimant’s name and file number with clearly delineated costs per claimant, if applicable
• Description, price and quantity of goods and services rendered with the charges grouped under categories (e.g., tuition, books, fees and supplies)
• Date(s) goods were delivered, or services were provided
• Supporting detailed information, if applicable (e.g., receipts listing itemized costs for books, fees and supplies

If a vendor, such as Barnes and Noble or Follett, has a centralized automated invoice system that creates a comprehensive PDF document that details each line item purchased by the claimant, it is not necessary for a separate detailed invoice to be attached and the invoice must not be rejected. Invoices that do not include signed receipts or confirmation from the claimant must also not be rejected. It is the responsibility of the case manager to obtain confirmation of receipt of goods from the claimant.

Additionally, invoices submitted by a facility for services authorized in IPPS must be aligned to the proper Budget Object Code (BOC). For more information on BOCs, refer to M28C.V.B.1.

b. Receipt of Services and/or Goods

(Change Date June 18, 2024)

The case manager is responsible for ensuring that the claimant received the invoiced services. Receipt of services can be documented in the following ways:

The claimant’s signature on the invoice acknowledging receipt of the invoiced services.

An email or other written confirmation of receipt of invoiced services from the claimant.

A confirmation from e-VA.

The case manager must request written confirmation from the claimant of receipt of the books and/or supplies if the vendor has not included a signed receipt. The documented receipts must be attached in the Notes and Attachments section of the Invoice Approval page in IPPS, a CWINRS case note, or in VBMS. Invoices without confirmation of receipt of goods must not be authorized in IPPS until the confirmation is received.

Prior to approval of an invoice, the case manager must ensure that:

The services provided by the vendor are included in the claimant’s rehabilitation plan of services.

The invoice complies with the requirements outlined in this section.

A case manager must take the following steps to ensure that each invoice is approved and processed correctly:

Review the invoice within seven calendar days of receipt of invoice in IPPS. VA has seven calendar days to return an improper invoice to a vendor, and 21 calendar days from receipt of the proper invoice to pay the invoice.

Advise the vendor of any rejected charges and return documentation of rejected charges to service provider.

Advise the claimant of rejected charges and provide VR-58, Chapter 31 Adverse Decision Letter to include VAF 20-0998, Your Rights to Seek Further Review of our Decision. VR&E staff should follow the procedures on adverse actions as outlined in M28C.III.C.2.

A case manager must reject any invoice received prior to the drop/add period for the program the claimant is attending.

c. Sales Tax and Handling Fees

(Change Date March 23, 2015)

The Department of Veterans Affairs (VA) can pay sales tax under the 38 U.S.C. 3104(a)(7) authority to pay fees. VA is authorized to pay for any mandatory charges (including taxes) if assessed to all students and invoiced accordingly.

VA is a third-party payer but is not a party to the transaction, which is between the claimant and the seller. As appropriate, this should be communicated with training facilities and bookstore vendors.

In accordance with 38 U.S.C. 3104(a)(7), VA may pay a 10 percent handling charges for the cost of books and supplies only. VA may pay both sales tax and the 10 percent handling charge on the same invoice, provided the educational or training institution verifies the supplies are required for all students pursuing the same or similar course under the provision of VAAR 831.7001-3(e). The 10 percent handling charge is only applicable to the cost of supplies and must be applied prior to the application of sales tax.

Example: Cost of supplies is $100.00 and applicable tax is $8.00. In this instance, the 10 percent handling charge would be $10.00, not $10.80.

IPPS requires facilities to separate fees from taxes.

d. Parking Fees

(Change Date December 4, 1998)

In accordance with 38 U.S.C. 3104(a)(7), VA may pay parking fees for a claimant when the case manager determines it necessary to accomplish the purposes of the claimant’s rehabilitation program. In most cases, case managers should treat parking fees that a training facility assesses in the same manner as tuition. Although it is usually not a required payment, driving and parking is a normal requirement for most students at most training facilities. VA may pay parking fees associated with parking lots and garages under this authority if campus parking is not available.

e. Approving Invoices

(Change Date August 26, 2019)

Case managers approve invoices up to a specified limit. Additional approvals are required for invoices above the High Dollar invoice approval levels established for supervisors. For more information on High Dollar Invoice Approval Levels, refer to M28C.V.B.1. Tuition Approval Threshold.

f. Late Payment of Invoices

(Change Date August 26, 2019)

While VR&E staff are required to pay invoices within 21 calendar days, the Veterans Benefits and Transition Act of 2018, Public Law (Pub. L.) 115-407, section 103, requires that all tuition and fees invoices be paid within 60 days of receipt of the invoice. The law also includes a semiannual congressional reporting requirement of any instance in which the VA fails to make the payment within 60 days. To allow time for funds transfer, any invoice approved after day 57 in IPPS will need to include an explanation.

The case manager must select one of the following options in IPPS to explain the reason for late payment:

System Impediment: This includes any technical difficulties that cause a delayed payment. For example, IPPS was down for a few days, case manager computer issues, or technical difficulties paying a specific invoice within the system for some reason.

Routing Issue: This includes situations where the invoice was sent to the wrong contact person. For example, a case manager goes on an extended leave and invoices are not rerouted to another case manager to authorize payment in a timely manner, or a case is transferred between RO’s and the invoice is sent to the originating station.

Delinquent Approval: This includes all instances where the correct case manager was provided the invoice, but he or she does not process it on time.

Unresolved Dispute with Invoice: This would involve situations of disagreements between VR&E and the facility regarding the accuracy of the invoice. For example, VR&E believes that the invoice is incorrect, but the facility insists that it is valid. The time it takes to resolve this dispute could impact the amount of time it takes for the invoice to be paid. The 60-day timeframe does not start until the correct invoice is received by VR&E. However, if after researching it is found that the original invoice received was correct, the 60-day period will be retroactive to the original date of receipt.

Payment Hold for Investigation: This category would only be used in rare circumstances and would involve situations where the Office of Inspector General (OIG) is investigating a facility or when the Secretary prevents the VA from paying a facility for some reason.

VR&E staff may use the Invoice Inquiry System to determine whether an invoice has been paid or if it is still pending payment. Refer to IPPS User Guide for a list of status conditions.

This reporting in IPPS allows VR&E Service to capture the required information regarding the number of cases and reasons for late payment needed for the semiannual report to Congress.

2.05 Debts, Refunds, and Credits

a. Treasury Offset Program

(Change Date November 7, 2013)

Under the provisions of the Debt Collection Improvement Act of 1996, the Treasury Department is authorized to intercept payments (except for benefits) made by federal agencies to vendors who have an unresolved financial debt with the United States (U.S.) Government. When the debt number is matched to the TIN or SSN, the payment may be intercepted by TOP.

VR&E staff may receive inquiries from vendors about past or current payments that are missing. The following information resources may be used to help determine whether the payment was offset by TOP or is missing for other reasons:

VA FSC records a transaction OS-15 in FMS that documents when a payment has been offset by TOP.

FSC staffs a toll-free customer service line (1-877-353-9791) and will provide information to include the debt number and the amount of offset.

FSC provides a check tracing service that can be initiated in a local VA Regional Office (RO) when the payment does not appear to have been offset by TOP.

Uninterrupted service to claimants participating in the VR&E Program is essential to positive rehabilitation outcomes; therefore, VR&E staff are encouraged to assist vendors in determining the reasons for missing payments. When the reason for missing payment(s) is TOP offset, vendors should be advised to work directly with the Department of Treasury to resolve any issues. The Department of Treasury provides toll free debt management service at 1-800-304-3107.

b. Credit Memos

(Change Date March 3, 2022)

A credit memo is a credit issued by a vendor against previously invoiced charges. Credit memos must be submitted by the facilities, schools, or vendors using IPPS via the Tungsten Network.

The procedures for processing credit memos are outlined below:

When a facility/school/vendor is overpaid, such as tuition due to a claimant withdrawal from training after the add or drop period, the facility/school/vendor submits a credit memo via Tungsten Network.

The credit memo is routed to the case manager who originated the claimant’s authorization in IPPS.

The case manager selects the credit memo in IPPS on the “My Work” tab, then reviews and validates the credit memo.

If the case manager accepts the credit memo, the appropriate BOC from the drop-down menu is selected and the amount to apply is entered. When entering the amount, a negative symbol (-) must be entered before the number and no dollar sign is needed. Proceed to Step 5.

If the case manager refuses the credit memo, select the appropriate BOC from the drop-down menu on the “My Work” screen. Then select Refuse and click on the refusal reason in the drop-down menu. Users can add additional information in the comments section if the reason for refusal needs more clarification. However, if "Other" is selected as the reason for refusal, additional comments must be added to clarify the reason for refusal. IPPS will then send the vendor a letter noting the credit memo was rejected. No further action is needed.

Select Accept and manually enter the Support Services Division (SSD) employee’s email address to transmit the information to SSD. The date is auto populated with the current date.

SSD receives a system notification of the accepted credit memo, except for those offices noted in Step 5 where an email will be sent.

SSD downloads the credit memo document from IPPS, except for those offices noted in Step 5 where an attachment from an email must be opened.

SSD/Finance establishes the debt in the Centralized Administrative Accounting Transaction System (CAATS) and sends a collection letter to the facility/school/vendor.

When the facility/school/vendor submits the payment for the debt, SSD Finance processes the collection and applies the funds to the debt in CAATS.

Any payment submitted without a proper credit memo established in the Tungsten Network will be returned to the facility/school/vendor by SSD.

All credits must be paid via check, not electronic funds transfer.