ML20207T233
| ML20207T233 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1987 |
| From: | Johnson G NRC OFFICE OF RESOURCE MANAGEMENT (ORM) |
| To: | Brady R NRC |
| Shared Package | |
| ML19310E127 | List:
|
| References | |
| FRN-51FR40438, RULE-PR-73 AC27-2-55, NUDOCS 8703230333 | |
| Download: ML20207T233 (2) | |
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l- - UNITED STATES NUCLEAR REGULATORY COMMisslON [ .) !..O[4} waswiuoron. o.c. 20sss e JAN0 g g;g FOTE T0: Raymond J. Brady, Director Division of Security FROM: Graham D. Johnson, Director l l Divisen of Accounting and Finance, RM i
SUBJECT:
REQUEST COR COMMENTS RE: PROPOSAL FROM LICENSEE FOR NRC TO BILL MONTHLY 70R FINGERPRINT CARDS SUBMITTED As requested, RM/A's comments re: subject proposal follow:
- 1. Impact Upon RM/A Staff To bill approximately 100 licensees for approximately 26,600 fingerprint cards per month would increase the workload of the Division of Accounting and Finance significantly. The billing procedures alone would take approximately one to one and one-half days per month for one person.
Establishing a receivable, monitoring the receipt of payment, calculating interest on late payments, sending notices of nonpayment, and other administrative procedures for collection require additional time which cannot be estimated without experience. Depending upon whether SEC would submit the cards to FBI be' fore payment or whether SEC would require RM/A notification to SEC of payments i received prior to submission of cards to the FBI could create additional hours for RM/A to provide copies of payment documents to SEC. This activity could take one person one day per month.
- 2. Internal Controls It appears that internal control requirements would increase for both RM/A and SEC to track cards and monitor funds since there would not be a matching between the inflow of applications and funds.
- 3. Cash Management Under the Deficit Reduction Act of 1984 and 31 CFR 206, the NRC is required to promote effective cash management through improved billing, collection, and deposit procedures that result in improved availability of funds to the U.S. Treasury. An Agency collection system should minimize total costs to the Government, including known or estimated personnel costs, interest costs, etc. The licensee proposal is inconsistent with these cited authorities.
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r 4 MRC Appropriated Funds The intent of the rule is to allow NRC to collect $2 per application to cover costs of implementing and operating this program. If NRC must - - wait 60 days to start receiving payments from licensees, NRC witl not only have to pay a data entry contractor but will also be in the position of paying the FBI out of NRC's appropriated funds and replacing the appropriated funds upon collection of fees from the licensee. This. proposed procedure places a burden upon the NRC staff to control appro-priated versus nonappropriated funds. In addition, NRC is acting as a
" middle-man" between the licensee and the FBI. It is not appropriate nor good cash management to involve NRC appropriated funds in this project solely for the benefit of the Itcensee. .
- 5. Additional Comnents Fingerprint applications are not dissimilar to other application forms that require payment in advance. For example: -
nuclear material license application (NRC) application for membership in an organization (Private) application for driver's license (State) Therefore, it is appropriate to require payment with the applicatinn rather than upon billing by NRC. Billing by NRC is only appropriate where payment is for. actual goods and services rendered and it is not possible to determine amount in advance. Summary The licensee's proposal would increase known or estimated agency personnel costs and interest costs to the Government. NRC has a responsibilit under the Deficit Reduction Act of 1984 and 31 CFR 206 to develop a collection mechanism that expedites credit and availability of monies to the U.S. Treasury. Implementation of a billing and collection system, which unduly increases costs to the Government, solely for the benefit of licensees, is 3 not appropriate. l.0/ Graham D. Johnson, Director
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