CG NPFC-CM01 NPFC FOSC Financial Management Checklist

Rev: July 2016

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WHEN A DISCHARGE OR RELEASE OCCURS

Determine funding source. ____OPA/OSLTF ____CERCLA/Superfund

For more information on OPA, the OSLTF, CERCLA, and Superfund, see About NPFC on 

NPFC’s home page (http://www.uscg.mil/npfc/About_NPFC/default.asp).

Department of Homeland Security

U.S. Coast Guard

National Pollution Funds Center

2703 Martin Luther King, Jr. Ave., SE

Washington, D.C. 20593-7605

202-795-6000 www.uscg.mil/npfc

FOSC Financial Management Checklist

for Oil Spills & HAZMAT Release

Step-by-step guidance for USCG & EPA FOSCs who are using the

OPA/OSLTF or CERCLA/Superfund and must monitor cost 

documentation during response to a spill or release.

OSLTF Funding is available for federal oil 

removal activities under the authority of 

Section 311(c) of the FWPCA, 33 U.S.C. 

1321(c). In general, when:

 There is a discharge of oil or a

substantial threat of a discharge of oil

 EITHER into or on U.S. navigable 

waters, adjoining shoreline, or the 

waters of the U.S. exclusive 

economic zone.

 OR that may affect natural resources 

belonging to the U.S. or under U.S. 

exclusive management authority.

The FOSC may:

 Remove or arrange for removal of a 

discharge and mitigate or prevent a 

substantial threat of a discharge;

 Direct or monitor all Federal, State, 

and private actions to remove a 

discharge;

 Remove and, if necessary, destroy a 

vessel discharging or threatening to 

discharge (may require Commandant 

approval).

For Coast Guard FOSCs, Coast Guard 

CERCLA Funding applies if the 

requirements for Response Authorities in 

Section 104 of CERCLA, 42 U.S.C. 9604 are 

met. In general, when:

 There is a release of a hazardous 

substance (other than oil) or substantial 

threat of a release into the environment 

that presents an imminent and substantial 

threat to public health or welfare.

 OR there is a release of a pollutant or 

contaminant that may present an imminent 

and substantial danger to the public health 

and welfare,

The FOSC may:

 Take action to remove or arrange for the 

removal of and provide for remedial action 

relating to such hazardous substance, 

pollutant, or containment at any time.
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Collect incident information.

Name of incident: _____________________________________________________________

Date of incident or discovery: ____________________________________________________

Location (body of water, city, state): ______________________________________________

Latitude and longitude: _________________________________________________________

Type of oil/substance: __________________________________________________________

_____ Visual Observation

_____ Field Testing

_____ Lab analysis

_____ Report by knowledgeable party

_____ Other: _____________________________________________

__________________________________________________

__________________________________________________

Quantity of oil/substance: _______________________________________________________

____________________________________________________________________________

Description of substantial threat: _________________________________________________

____________________________________________________________________________

__________________________ __________________________________________________

____________________________________________________________________________

Potential quantity of total oil discharge/HAZMAT release: _____________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________
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Collect source and responsible party information.

* Social Security/Tax Identification Number (SSN/TIN). The Debt Collection Improvement Act (31U.S.C. 

3701) requires the FOSC/IC to obtain the SSN or TIN of the RP in order to pursue cost recovery.

Estimate the OSLTF/CERCLA funding ceiling required (These totals should 

include all Coast Guard resources, if deployed to the response, e.g. Strike Team, 

PIAT, NPFC, etc.). THE COAST GUARD CEILING “ONLY” REPRESENTS 

ESTIMATED “DIRECT COSTS”, AS DESCRIBED BELOW.

Note: EPA FOSC’s use a similar sheet for estimated their costs.

 Name of vessel, facility, private residence, etc.: 

_________________________________________________________

 How was source/RP identified? ____ FOSC investigation ____Visual Observation

____ Reported by third party

____ Reported by RP

____ Other: ________________________________

 Collect the following information on all parties connected to this incident, whether 

individual or company (record on IRAT):

o Name

o SSN/TIN*

o Address (address, city, state, zip code, & phone number)

Estimated CG Direct Costs

(reflected against the ceiling):

Contractor costs: _______________

Travel costs: ___________________

Purchases: ____________________

PRFA (OGA) costs: ______________

Total (Ceiling): _________________

(To be requested via CANAPS)

Estimated CG Indirect Costs

(tracked, but NOT reflected against ceiling)

Personnel: _____________________

Equipment: ____________________

Note: The information collected by Coast Guard personnel should be recorded on the NPFC Incident Report 

and Transmittal Form (IRAT) (page 2). The bullets below are provided to help guide you through what 

information is needed.

For more information on direct and indirect 

costs and tracking these on the Electronic 

CG-5136 workbook, click here: 

(www.uscg.mil/NPFC/Response/Cost%20Do

cumentation/CG5136.ASP)
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Access CANAPS to get FPN/CPN and request ceilings

(https://npfc.uscg.mil/CANAPS/).

Note: (1) CG FOSC can access an FPN up to $500,000 via CANAPS.

(2) EPA FOSC can access an FPN up to $50,000.00 via CANAPS.

(3) Any request higher than these threshold limits requires NPFC Case Officer to 

approve.

(4) Refer to CANAPS message for accounting line and Document Control Number 

(DCN) construction.

If you cannot access CANAPS:

1. Contact another FOSC who can submit the request as a surrogate for you.

2. Contact the NPFC Command Duty Officer (CDO) (see box at bottom of this page).

3. As the FOSC, you are authorized to obligate up to $50,000 for response actions.

CERCLA Only. If the estimated ceiling is:

 Equal to or greater than $250,000, contact your NPFC Regional Manager for assistance in 

submitting an Action Memorandum to EPA before obligating the amount,

 Less than $250,000, document the finding of imminent and substantial endangerment in 

POLREP one.

Contact the NPFC for assistance. Assigned Case Officer: ______________________

OSLTF Responses

Federal Project Number: ____________

Final Authorized ceiling: _____________

CERCLA Responses

CERCLA Project Number: ________________

Final Authorized ceiling: _________________

Any FOSC can be a surrogate for any other FOSC in their agency; any EPA FOSC can open an 

FPN for any other EPA FOSC, and any USCG FOSC can open a project for any other USCG 

FOSC. In addition, a USCG FOSC can open a project for an EPA FOSC.

The finding at a minimum must include:

 The hazardous substance(s), pollutant(s), or contaminant(s) involved;

 A description of what is affected or threatened (people, animals, crops, drinking water, etc.);

 A statement indicating that this situation presents an imminent and substantial threat to public 

health, welfare, or the environment; and

 A description of the response action necessary to neutralize the threat.

Gulf Coast & Midwest Team I 202-795-6067

Southeast Team II 202-795-6069

West Coast, Alaska, Hawaii Team III 202-795-6073

Northeast & Great Lakes Team IV 202-795-6088

If your regional manager is not available:

Call the duty officer’s cell phone at or Call the NPFC Command Duty Officer (CDO)

(202) 494-9118 or e-mail at NPFC.CDO@ by contacting the National Response Center (NRC)

uscg.mil. at 1-800-424-8802 or (202) 267-2675.
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Download the Electronic CG-5136 Workbook for ceiling management and for

documenting all the costs on both FPN and CPN cases:

(www.uscg.mil/npfc/Response/Cost%20Documentation/cg5136.asp)

The workbook consists of three levels of information:

♦ Project Summary – used to monitor ceiling, track overall costs and provides a burn 

rate of costs.

♦ Summary Page – provides an overall summary of cost for each day and each cost 

category.

♦ Daily Summary – is where all the cost data is entered which rolls up to the two 

levels above.

Actively manage the funds assigned to the FPN/CPN (CG FOSCs Only)

CG FOSCs shall within three (3) business days after receiving an FPN/CPN and ceiling 

from CANAPS:

• Open FPD and ensure access to the account line established for the incident.

• Verify that the planned amount is the authorized ceiling from CANAPs. If it 

is not, contact the NPFC Case Officer.

Upon receipt of the funds through CANAPS, the FOSC is designated as the Program 

Element (PE) Manager. The FOSC is responsible for the control of the OSLTF/CERCLA 

Funds provided for the removal.

• PE Managers may be assigned by individual who are staff-trained in financial 

management. However, the PE Manager is directly accountable for funds 

trusted to his or her control.

• The specific responsibilities of the PE Manager are detailed in the Financial 

Resources Management Manual (FRMM), COMDTINST M7100.3D, Section 

(3.H.10).

Critical Functions. The FOSC shall:

• Record all obligations in FPD as they are incurred.

• Ensure that reconciliation of financial management systems is performed in 

accordance with current CG guidance.

• Adhere to CG UDO (Undelivered Orders) policy and procedures including 

maintaining source documentation for valid obligations and procurements, 

validating open obligations, and de-obligating open obligations that are no 

longer needed.

 

 
CG NPFC-CM01 NPFC FOSC Financial Management Checklist

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Follow the NPFC’s guidance for use of funds and to arrange response actions. 

Contract through SILC (cob1) and use Pollution Removal Funding Authorizations 

(PRFAs) for Other Government Agencies (OGAs). EPA FOSCs use their START 

(Superfund Technical and Response Team) or ERRS (Emergency and Rapid 

Response Services) contractor’s, but may use USCG BOA contracts, if needed.

During Cleanup – Every Day

Monitor Contractors.

Collect contractor daily worksheets or delivery tickets and/or Pollution Incident Daily

Resource Reports.

Date-stamp all invoices upon receipt. (Prompt Payment act applies; payment is due to 

the contractor within 30 days.) Within 10 days of receipt of invoices, certify that work 

was performed as ordered (as FOSC, you should not certify work that was not 

ordered) and forward to SILC (cob1).

MIPRs (Military Interdepartmental Purchase Request):

Coordinate with SILC (cob1) when DOD assets are being requested and a DD-448 must 

be issued. Comply with the requirements of SILC and the FINCEN’s SOP. A DD-448-2

is used for Acceptance of MIPR.

The document number assigned to the MIPR must be unique and remain the same 

throughout the life of the agreement.

Keep NPFC Case Officer in the loop when these services are requested.

Oil spill response contractors may use the Parts E1 to E4 of the CG-5136 form to track and submit 

daily costs. These forms are available on NPFC’s Web site:

(www.uscg.mil/npfc/Response/Cost%20Documentation/cg5136.asp) as well as in the URG.

Follow the 10-10-10 Rule!

1) Forward invoices to SILC (cob1) within 10 days.

2) SILC (cob1) forwards payment authorization to FINCEN within 10 days of receipt.

3) FINCEN pays the contractor within 10 days of receipt.

Resources on NPFC’s Web Site (www.uscg.mil/npfc)

The NPFC’s User Reference Guide (URG) includes guidance on contracting 

(www.uscg.mil/npfc/urg/default.asp).

PRFA forms and instructions are available on NPFC’s Web site 

(www.uscg.mil/npfc/Response/Cost%20Documentation/prfa.asp) as well as in the URG.
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Monitor Coast Guard Units.

Monitor other government agencies (OGAs).

Consolidate all daily reports for your unit onto the Pollution Incident Daily Resource 

Reports (CG-5136). (This should cover all unit resources involved in removal activity).

• To expedite tracking all CG costs, you should use the Electronic CG-5136 

Workbook. See job aid for completing the electronic 5136 workbook located 

at this website:

(www.uscg.mil/NPFC/Response/Cost%20Documentation/CG5136.ASP)

Collect all official records for aircraft, cutters, and small boats by accessing ALMIS and 

print the documents. Official Navigation Record should also be collected from all 

cutters involved in the response.

For a SONS or when a UAC is established, ICS-213RR CG Resource Request Forms for 

equipment and vehicles shall be submitted with the CG-5136 form.

Keep copies of all travel claim packages. (Members are also required to keep copies 

of all travel claim packages for 6 years and 3 months.)

Each travel claim package must include:

 Copy of signed original orders (which must be signed by an approving official and Funds 

Certifying Officer, including those generated by Direct Access).

 Copy of all signed amendments.

 Copy of Travel Voucher Summary (TVS)

In addition, if a Government Travel Request (GTR) was used, include a copy of the airfare itinerary 

to show the GTA account was used to pay the airfare.

Issue Pollution Removal Funding Authorizations (PRFAs) and definitive scopes of work 

(SOWs) to other Federal and state agencies participating in the FOSC-directed 

response.

Collect OGA SF-1080 or SF-1081 vouchers and supporting documentation in 

accordance with the PRFA.

Review OGA SF-1080 or SF-1081 voucher and certify that work was performs as 

ordered.

PRFA forms and instructions are available on NPFC's Web site:

(www.uscg.mil/npfc/Response/Cost%20Documentation/prfa.asp) as well as in the URG.

SF-1080 or SF-1081 forms and instructions are available on NPFC’s Web site:

(www.uscg.mil/npfc/Response/Cost%20Documentation/sf1080.asp) as well as in the URG.
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Validate all obligations and track them against the ceiling.

Use CANAPS if you must increase the ceiling (https://npfc.uscg.mil/CANAPS/

Contact your NPFC Case Officer or the SILC (cob1) Contracting Officer, as 

appropriate, anytime you need assistance.

After the Response Action Is Completed

Certify contractor invoices within 10 “Calendar Days” of receipt of invoices.

Forward certified contractor invoices to SILC (cob1), as appropriate.

Ensure all direct expenses (obligations) are entered on the CG Dailies or the Electronic 

CG-5136 Workbook and have been entered into Finance Procurement Desktop (FPD)

by the unit.

In addition:

• Enter all indirect expenses (anticipated costs/estimates of Coast Guard 

resources based on Coast Guard Standard Rates such as CG personnel, 

vehicles, aircraft, boats, cutters, and Strike Team resources). CG aircraft, 

cutters, and boats should also be supported by official records found in 

ALMIS. Note: These costs are tracked but do not impact the ceiling of the 

incident.

• During a SONS or when a UAC is established, the FSC will ensure a copy of all 

ICS-213RR’s for equipment and vehicles are collected and attached to the 

5136 dailies.

Note: Obligations include:

 Travel orders;

 GTR’s;

 Contractors;

 PFRAs (for OGAs);

 MIPRs;

 Purchase Orders;

 Credit Card Purchases;

USCG Standard Rates are available on NPFC’s Web site:

(www.uscg.mil/npfc/Response/Cost Documentation) as well as in the URG.

For example, if you have reached $40K against the $50K ceiling, and you expect the total costs to exceed $50K, 

increase your ceiling to accommodate the anticipated needs of the response.

Ensure that all certification for receipt of services is in accordance with the standard SILC (cob1) and Finance Center 

procedures. (Contact appropriate SILC (cob1) contracting officer if questions arise, or if invoice cannot be certified. 

The FOSC certifies receipt of invoiced goods and services in quantities indicated; the cognizant contracting officer 

verifies costs).
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Keep copies of all certified contractor invoices for the unit’s files.

De-Obligate remaining unused funds in FPD when all invoices have been paid.

Compile an inventory of all equipment purchases.

Within 120 days of completion of cleanup, send the Financial Summary report to 

the NPFC.

All reportable property and highly pilferable property must be disposed of at DRMS 

and should not be kept at the unit.

Provide disposition reports on all property and comply with COMDTINST M4500.5

(Series)

 

 

The Financial Summary report includes:

 Incident Report and Transmittal (IRAT)

 FOSC Pollution Daily Resource Reports.

 Contractor Invoices & Daily Resource Reports

 Other Government Agencies Resource Documentation (SF1080/1081 with 

invoices, Daily Resource Reports, PRFAs with SOWs)

 Inventory of Equipment Purchased

If you are using the Electronic CG-5136 form (i.e., the Excel spreadsheets) and you 

also generate or collect handwritten invoices, dailies, and notes, do not throw them away. 

They should become part of your case file. In court, the electronic forms may not be 

considered “original” documentation.

The Incident Report and Transmittal form serves as a coversheet to the project’s Financial 

Summary report. It is available on NPFC’s Web site:

(www.uscg.mil/npfc/Response/Cost%20Documentation/irat.asp) as well as in the URG.
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Retain records according to the USCG’s Records Schedule; keep case file for:

 Major spills for 10 years before forwarding them to NARA as permanent 

records.

 Medium and minor spills for 20 years before destroying them.

 The NPFC may request a longer retention period for a particular case to support 

cost recovery or other litigation efforts.

OSLTF case files are subject to auditing by the NPFC; they must contain all paperwork 

relevant to the response effort, including but not limited to:

 Procurement paperwork

 Travel documentation

 News clips

 Credit card information paperwork

 Polreps

More information on OSLTF internal controls and audits is available on NFPC’s Web site:

http://www.uscg.mil/npfc/Response/Cost%20Documentation/default.asp