MARADMIN 661/19 - Manpower Audit Advisory 1-19: Audit Compensating Controls to Dependency Application and the NAVMC 10922

Scope

MARADMIN 661/19 publishes the inaugural Manpower Audit Advisory (MAA) in support of the Marine Corps Financial Statement Audit for M&RA lines of business Military Pay (MILPAY) and Civilian Pay (CIVPAY). The advisory announces immediate changes to dependency application compensating controls in response to Notice of Finding and Recommendation (NFR) 2019-FIN-002. Officers no longer self-attest BAH entitlement. Substantiating source documentation now uploads to the Official Military Personnel File (OMPF). MCO 1751.3 will fold the changes into its next update. Applicability is the Marine Corps Total Force.

Audience

• Officers applying for BAH entitlement. Sign the NAVMC 10922 as the claimant only. Officer self-attestation as the attesting officer is barred.
• Administrative personnel with By-Direction authority. Sign as the attesting officer on the NAVMC 10922.
• Certifying officers. Certify the dependency transaction into MCTFS.
• S-1 staff and adjutants. Upload substantiating documents (marriage certificate, dependent birth certificate, divorce decree) and the completed NAVMC 10922 to the OMPF Field Folder.
• Marine Corps Administrative Analysis Team (MCAAT). Verifies the effectiveness of the compensating controls during unit visits.
• HQMC MX Branch. Assists units in meeting audit readiness standards.
• Commanding officers. Confirm the controls are in place. Hold S-1 accountable for source document upload to the OMPF.

Compensating controls effective immediately

1. Officers are no longer permitted to sign as the attesting officer on their own dependency application.
2. Every Marine applying for Dependency Application status completes a NAVMC 10922 and signs as the claimant. Only administrative personnel with By-Direction authority sign as the attesting officer. The certifying officer is the individual certifying the transactions into MCTFS.
3. Substantiating and source documentation, including marriage certificate, dependent birth certificate, and divorce decree, uploads to the OMPF along with the completed NAVMC 10922. Documents stay in the OMPF Field Folder.

Action items

1. Recall every officer at the unit who self-attested a dependency application. Replace with a By-Direction attestation and re-upload the package to the OMPF.
2. Audit the unit OMPF Field Folder against MCTFS to identify dependency transactions missing source documents.
3. Coordinate with the OMPF support office to upload missing source documents.
4. Schedule the MCAAT visit. Confirm the compensating controls verify.
5. Train S-1 personnel on the new attestation rule. By-Direction signature only.

Connection to higher policy

• CMC White Letter 02-19. Full Support to Marine Corps Financial Statement Audit, 2019-11-08.
• DoD Financial Statement Audit Guide, 2018-05. OUSD(C) DCFO.
• DoD Internal Control Over Financial Reporting (ICOFR) Guide, 2018-05. OUSD(C) DCFO.
• SECNAVINST 5200.35G. DON Managers Internal Control Program (MICP).
• Notice of Finding and Recommendation (NFR) 2019-FIN-002. Dependency Applications for Military Pay Entitlements. The trigger for the advisory.

Connection to Marine Corps doctrine

• MCO 1751.3. Marine Corps Dependency Determination and Support Program for Basic Allowance for Housing and Travel and Transportation Allowance, 2015-05-05. The next update folds in the controls.
• NAVMC 10922. Dependency Application. The form the controls govern.
• Marine Corps Total Force System (MCTFS). System of record for certified dependency transactions.
• Official Military Personnel File (OMPF). Source document storage location.
• MX Branch. Audit readiness support.
• MCAAT. Audit verification team. Apply the IGMC FAC for personnel administration audit posture as well.

Status

Released 2019-12-02, DTG R 021555Z DEC 19. Originator CMC MRA DAG SECT Washington DC. Release authorized by Lieutenant General M. A. Rocco, Deputy Commandant, Manpower and Reserve Affairs. Applicability is the Marine Corps Total Force. POCs include J. D. Kenkel (M&RA Financial Statement Audit Liaison), M. R. Brandon (M&RA MILPAY Audit Liaison), K. J. Rafferty (M&RA CIVPAY Audit Liaison), and CWO5 R. L. Summers (MCAAT OIC). Effective immediately. Active until folded into MCO 1751.3.