Title
Reinstituting Selective Pre-Audit, COA Circular 2009-002
Law
Coa Circular No. 2009-002
Decision Date
May 18, 2009
The Commission on Audit reinstitutes selective pre-audit for government transactions to enhance financial oversight and prevent irregular disbursements, focusing on key areas such as cash advances, salaries, infrastructure projects, and procurement activities.

Law Summary

Commission on Audit's Authority and Historical Context

  • COA holds exclusive authority over audit scopes, methods, rules, and regulations.
  • Previously lifted pre-audit activities in 1995 but now revisits policy due to increased irregular disbursements.
  • Reinstitutes selective pre-audit as a preventive measure against anomalies and inadequate internal controls.

Definition and Scope of Pre-Audit and Post-Audit

  • Pre-audit: examines supporting documents before payment and recording.
  • Objectives include verifying compliance with laws, fund availability, legitimacy, approval, and authenticity.
  • Post-audit: covers similar areas plus tracing transactions to books of accounts and final determination of legality and necessity.
  • Post audit will not duplicate pre-audit unless necessary.

Coverage of Selective Pre-Audit

  • Applies to national agencies, local government units, and government-owned corporations listed in an annex.
  • Transactions include cash advances, salaries, infrastructure payments, procurement, funds to NGOs, fund transfers, trust fund disbursements, and disposal of property.
  • Other entities like national high schools and barangays initially exempt.
  • Further coverage subject to evaluation of internal controls.

Specific Rules on Cash Advances

  • Pre-audit required except for payroll, intelligence, petty cash, and local travel advances.
  • Liquidation must be audited before recording.
  • Strict guidelines on granting, use, and liquidation timing.
  • Cash advances must be for lawful specific purposes, properly bonded, and cannot be transferred or used for previous advance liquidation.

Payment of Salaries and Terminal Leave Benefits

  • Pre-audit applies only to first payment after appointment by transfer/reinstatement and last payment before transfer.
  • All terminal leave benefits payments subject to pre-audit.

Infrastructure Projects

  • Covers government construction-related projects defined broadly including IT, sanitation, energy, and buildings.
  • Pre-audit required for contract amounts meeting set thresholds varying by agency and location.
  • Only advance payments, first and last progress billings, and first payments under variation orders are pre-audited.
  • Mandatory inspections for first and last billing; random inspections possible.
  • Technical and legal reviews required, including cost reasonableness evaluations.

Payments for Road Right-Of-Way

  • All claims subject to pre-audit following RA No. 8974 and its implementing rules.

Procurement of Capital Assets, Goods, and Services

  • Includes land, buildings, supplies, labor, and services.
  • Pre-audit applies to first and last payments for contracts exceeding monetary thresholds based on agency and locality.
  • Some emergency procurements exempt.
  • Government-to-government procurements excluded.

Payments Through Automatic Debit Advice (ADA)

  • Pre-audit required for documents supporting ADA payments for foreign or local funded projects.
  • Also applies to approved disbursement vouchers for procurements paid through ADA.

Releases to NGOs/POs

  • All releases to NGOs/POs subject to pre-audit.
  • No new releases unless previous ones liquidated and post-audited.

Transfers of Funds Between Government Agencies

  • All fund transfers subject to pre-audit except certain intra-government and emergency transfers.

Disbursements from Local Government Trust Funds

  • Pre-audit applies only to trust funds from the national government or government corporations.

Disposal of Property

  • Pre-audit required for negotiated sales of real property at or above P1 million and unserviceable property valued at P500,000 or more.
  • Specific approval hierarchies for disposal based on value.
  • Valuations by qualified inspectors required.
  • Sales of real property are subject to COA approval regardless of amount.

Responsibilities for Conducting Pre-Audit

  • Assigned to heads of auditing units, Supervising Auditors or Audit Team Leaders.
  • Procedures for designation of alternates during absences.

Duties of Agency Officials

  • Must ensure no payment without pre-audit evidence.
  • Responsible for submission of documents and liquidation reports.
  • Maintain detailed records and ensure no splitting of contracts or claims.
  • Submit procurement plans and maintain logs of pre-audit transactions.

Duties of COA Officials

  • Audit transactions within prescribed timeframes (2-5 working days).
  • Monitor cash advances and initiate demand letters for late liquidation.
  • Withhold payments and initiate criminal cases for non-compliance.
  • Ensure compliance with technical and inspection requirements.
  • Maintain logs and conduct post-audit incorporating pre-audit results.

Evidence of Audit Action

  • Pre-audit indicated by stamp on disbursement vouchers and supporting documents.
  • Deficiencies must be reported within 24 hours.
  • Technical review of certain contracts mandated.
  • Issuance of Credit Notices upon liquidation within 30 days.
  • Credit Notice issuance is prerequisite for subsequent advances or releases.

Appeal Procedures

  • Aggrieved parties may appeal per COA's Revised Rules of Procedure.

Oversight Committee

  • Assistant Commissioners designated to monitor and evaluate selective pre-audit implementation.
  • Authority to recommend inclusion or exclusion of transactions.
  • Develops criteria for exemptions based on risk-calibrated audit framework.

Penalties

  • Violations related to cash advances penalized under PD No. 1445 Sections 89 and 128.
  • Failure to submit transactions for pre-audit grounds for administrative actions and possible disallowance.

Repealing Clause

  • Revokes or modifies inconsistent COA circulars and memoranda.

Effectivity

  • Circular effective July 1, 2009.

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