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FUND MANAGEMENT DURING INCIDENTS FOR CG FOSCs

I. OVERVIEW

The FOSC is the key individual responsible for financial management during incidents, 

whether oil, chemical, or disasters (ESF-10). Every direction the FOSC issues and every 

resource the FOSC calls upon has the potential to use funds from the ceiling that NPFC has 

issued for the incident. The FOSC has a range of tools to help address this responsibility, but 

most important is the Finance Section Chief (FSC) who is designated through the ICS 

(Incident Command System), which exists for every response. The FSC may be from the 

local unit for a small spill or brought in from the Strike Team or IMAT for a larger incident. 

(This augmentation can always be paid for by the fund used.)

The FOSC’s financial management responsibilities, as Program Element Manager, are 

enumerated in the Coast Guard’s FRMM (Financial Resource Management Manual). The 

FRMM details the responsibilities of the Program Element Manager for the funds assigned to 

the specific FPN/CPN/DPN. While the duties associated with Program Element Manager 

can be delegated in the same manner as FOSC duties can be delegated to FOSC(R), the 

responsibility remains with the FOSC/Sector Commander.

Funding for pollution response is distinct and independent of the unit’s annual AFC-30 

Operating Funds budget. Pollution response funds are in different Congressional 

Appropriations that cannot be used interchangeably with CG OE. The Sector and FOSC’s 

FSC must take care to ensure that unit operating funds are not intermingled with pollution 

incident funds. Furthermore, the rules that govern the use of pollution response funds are in 

statute, and the Coast Guard is regularly audited to ensure these rules are obeyed. When in 

question about appropriate use of response funds, discuss in advance with the NPFC Case 

Officer.

The NPFC will provide the FOSC with the Ceiling/Planned Amount for each response. 

All funds the FOSC uses must be recorded on the CG-5136 daily records, obligated in the 

Finance and Procurement Desktop (FPD), tracked as resulting expenditures are incurred, and 

reconciled against weekly Program Element Status (PES) reports to ensure that FPD and the 

Core Accounting System (CAS) agree with each other. When the response ends and all 

spending is done, NPFC will work with the FOSC to pull back all unused funds and then 

secure the FPN/CPN/DPN/Program Element in the Coast Guard’s CAS so that no further 

spending will take place for that incident.

II. SPECIFIC REQUIREMENTS

a. FOSC/Sector Financial Systems. When the CANAPS message is received, it 

must be routed through the unit’s logistics department, so that the unit can give 

itself FPD access to the new account line. The new account line will appear in 

FPD as soon as it is processed by FINCEN, normally the next business day. The 

Planned Amount/Ceiling will promptly follow. If the FPD Planned Amount does 

not agree with the NPFC Ceiling message, notify the NPFC Point of Contact 

named in the message immediately.

b. Ceiling Management. 
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i. The FOSC must always know the current financial status of a response. 

On large, complex cases (ceiling over $100K) the FOSC should compare 

the authorized ceiling against cumulative obligations daily. For smaller 

cases, this must be done for each POLREP issued. 

ii. The CG-5136 Summary form provides a simple procedure to allow this 

comparison. The purpose of this daily comparison between ceiling and 

cumulative obligations is to ensure the FOSC does not commit more funds 

than are available. If additional funds become necessary, the FOSC 

should promptly use CANAPS to request an increase to the Ceiling. 

Note: This process depends on entering on the 5136 Daily Form all 

obligations incurred during that day. See below for the definition of 

obligations. While this entry duplicates the official entry in FPD, it only 

requires the DCN and amount obligated to be recorded, and facilitates the 

quick comparison that is operationally necessary.

c. Obligations. When the FOSC directs an action that will result in OSLTF, 

CERCLA, or Stafford Act expenses to be paid by the CG, that order or direction 

constitutes grounds for recording an obligation. An obligation by definition is 

often an estimate of the final cost – but must be recorded immediately in the CG 

Financial Systems (FPD) so that there is a record of this potential payable. This is 

mandated by GAO, the FAR, and CG FRMM.

i. Examples of Obligations:

1. Contracts with vendors (SILC will record BOA Authorizations to 

Proceed),

2. Purchases,

3. Travel Orders,

4. Reserve ADT orders created in Direct Access,

5. Pollution Removal Funding Authorizations (PRFAs) with other 

government agencies supporting the FOSC (eg: spill trajectories by 

NOAA),

6. Local procurements for lodging, meeting facilities, or the rental of 

equipment needed by the FOSC.

ii. If a question arises whether an action should be recorded as an obligation, 

contact the NPFC Case Manager identified on the CANAPS ceiling 

message.

d. Recordkeeping

i. The FOSC must keep an organized, daily record of both CAS obligations 

and NON-CAS costs (CG assets) used for the response.

ii. For CAS obligations, the FOSC must use FPD and the CG-5136 Forms to 

track the Ceiling/Planned Amount, Obligations, and the resulting available 

ceiling balance.
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iii. For NON-CAS costs, the FOSC must record the use of CG assets 

deployed to the incident for the response. These costs CAN NOT be 

recorded in FPD/CAS, but are equally critical for incident financial 

management. They are a key part of the bill the Coast Guard sends the 

spiller for the costs of the spill.

iv. Use the CG-5136 Daily Form to record what assets are used each day. 

The CG-5136 form allows for entry of the following types of CG 

resources, based on hours used. Examples of assets used: 

1. Personnel (Active Duty, Civilian)

2. Boats

3. Cutters

4. Aircraft

5. Specialized CG Pollution Response Equipment (boom, pumps, 

etc.) (See current edition of COMDTINST 7310.1 – Standard 

Rates)

e. Reporting. When an incident is funded by OSLTF, CERCLA, or the Stafford Act 

(FEMA), the FOSC must report in every POLREP/SITREP the FPN/CPN/DPN, 

the authorized ceiling, and the cumulative removal obligations to date for the 

incident. The NPFC must be included as an Info Addressee on these messages.

f. Reconciliation. The Sector serving as FOSC is the designated Program Element 

Manager for those funds assigned to the response/incident. The FOSC/R is 

responsible to ensure that incident accounts are appropriately reconciled as 

required by the FRMM. 

i. The unit requesting funds should ensure that the individual who will be 

responsible for reconciling these accounts has access to each account in 

FPD, and ensuring that the reconciler is an authorized reconciler on the 

Unit UAP. The process of reconciling these cases is no different than 

reconciling the unit’s OE account. It is imperative however that the 

reconciler communicates with the FOSC/R in order to ensure that 

transactions hitting the account are valid.

ii. Weekly PES reconciliation is required for these accounts to ensure FPD 

and CAS are in agreement. PES Reports are generated when there is 

activity within an account. Once the incident is closed and existing 

transactions have processed, NPFC will execute an FTA pulling any 

remaining planned amount balance back into the Emergency Fund (or 

other funds). NPFC will coordinate with FINCEN to close the cost center 

disabling the ability to create new obligations. Although the account will 

not ‘go away’, PES reports will not be generated as long as there aren’t 

any new transactions hitting against the account.

iii. OOVA and other related processes apply.
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iv. Currently pipeline certification is completed for annual appropriations. 

An FOSC/R is required to coordinate pipeline certification for CERCLA 

and Disaster cases open during the current FY with the Logistics 

Department Head. All CERCLA and Disaster cases under the purview of 

the Sector should be certified in the same manner as they certify their OE 

accounts. The unit should act as certifier and Management Review 

Official, and the District will act as ATU certifier.

v. The OSLTF is a ‘no-year’ appropriation and currently does not require 

pipeline certification. However, the unit shall ensure obligations are 

appropriately recorded in accordance with current obligation policy as 

amended in ALCGFINANCE messages.

III. INCIDENT FUND MANAGEMENT - RELATED TOPICS

a. Use of CG RESERVISTS: CG FOSCs responding to major spills frequently need 

additional personnel to augment their ICS response structure. CG Reservists 

often are used in this capacity. The OSLTF, CERCLA, or Stafford Act funds can 

be used to pay for Reservist orders when the Reservists are directly involved in 

the response and directly working in the FOSC’s ICS system. 

Caution: If reservists are being used as “backfill” at another command so that 

active duty CG personnel can be deployed to support the FOSC, the response 

funds cannot be used – another source of CG funding must be provided.

i. The need for CG Reservists shall be documented using the ICS 214 form, 

approved by the FOSC.

ii. CG PERSRUs shall use Direct Access to issue the orders, employing the 

accounting line for the incident that was issued by CANAPS. Direct 

Access has been programmed so it can accept OSLTF, CERCLA

(Reimbursable) and Stafford Act (Reimbursable) funds, but special rules 

apply. Contact CG Personnel Command if assistance is needed. It is 

critical that the correct account line for the incident is used – or the 

charges could be applied to the wrong Appropriation and the CG could be 

at risk of an Anti-Deficiency Act violation.

iii. Direct Access will issue a set of Orders that includes pay, allowances, and 

travel under the same TONO. Do NOT issue separate travel orders for CG 

reservists.

iv. The CG PERSRU will ensure that all orders issued result in obligations 

being recorded in FPD/CAS. Doc Type 71 Reservist orders result in 

automatic obligations in FPD/CAS, but Doc Type 72 Reservist Orders 

must be manually obligated in FPD/CAS by the CG PERSRU issuing the 

orders.

v. As CG Reservists report in to the FOSC, the ICS Documentation Section 

shall collect a copy of the orders for personnel management and 

subsequent cost documentation. Likewise, the ICS Documentation 
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Section must track the demobilization process for these personnel. [More 

detail on what ‘tracking’ the demob process entails?]

vi. Orders that are issued but not used shall be promptly de-obligated in 

FPD/CAS when they are cancelled in Direct Access.

b. Credit Cards. Credit card purchases are problematic and not the preferred method 

of obtaining supplies/services for small/short duration responses.

i. Local Credit Card Procurements will require coordination with the local 

cardholder and the local reconcilers. If a credit card purchase is needed 

for a response, the unit will need to determine whether or not they have a 

purchase card associated with the oil spill response accounts (Approp 

“SZ”) or a reimbursable card for CERCLA/Disaster ESF-10 responses. 

If they do, the card holder can either change the default Line of 

Accounting (LOA) currently associated with the card, via FINCEN, to the 

new LOA established for the response, or keep the LOA as the default 

account and use Purchase Card Application (PCA) to update the 

accounting data fields (primarily the Program element field) as the charges 

hit against the system. It is highly recommended that you make your 

accounting line adjustments in PCA to avoid having to do PES error 

adjustments in FPD after the fact.

ii. If no response card (Approp “SZ”) is available, the unit can make 

purchases utilizing their existing unit purchase cards and then submit PES 

error adjustments in FPD to move the charges from their OE account to 

the appropriate response account. The FOSC/R is responsible for ensuring 

Credit Card obligations are recorded in FPD. Any charges not associated 

with the correct account line will need to have a PES error submitted in 

order to have the charges hit against the correct accounting line. Follow 

existing CG procedures to change the accounting line associated with a 

credit card. 

c. CG Civilian Overtime. The CG frequently deploys its civilian workforce to major 

incidents. Civilian pay is recorded on the CG 5136 using CG Standard Rates. 

Include any overtime in hours worked for a given day. However, any overtime a 

CG civilian performs results in additional pay for that individual and can be 

directly funded by the respective fund.

i. Authorizing Overtime: The FOSC shall use the ICS 214 form to 

document the need for CG Civilian Overtime Pay, specifying the 

Employee’s Name, home unit, pay schedule (GS or WG), and grade, and 

the hours authorized for the respective pay period (PPD 1 through 26). 

This must be done in advance and a copy provided to the employee and 

his/her home unit.

ii. Paying Overtime: 
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1. The civilian worker shall report to his/her home unit timekeeper 

the hours of overtime actually performed, and provide a copy of 

the FOSC approved ICS 214 as supporting documentation.

2. There are pay ceilings that limit the amount of overtime that can be 

paid to any civilian employee. The home unit timekeeper must 

ensure these ceilings are tracked to ensure they are not exceeded. 

Personnel will not be paid in excess of any pay ceiling that exists 

in the CG Civilian Pay system.

3. The CG Civilian Pay System shall record the overtime hours 

worked and ensure the person is paid accordingly. However, it 

cannot differentiate the overtime used for the incident from other 

overtime performed by the person. This can result in the civilian 

employee’s home unit overtime payroll account being charged

those costs.

iii. It may become necessary to replenish the home unit overtime account.

1. To do so, the home unit must forward to the AFC-08 Manager a 

copy of the ICS-214 form(s) approved by the FOSC along with an 

accounting of the overtime actually paid from the unit’s account.

2. Send a copy of this documentation package to the NPFC Case 

Officer at the same time. Identify the FPN/CPN/DPN that applies 

to the documentation package.

3. The home unit can do this at any time during the incident, but 

should do it within 90 days of the response being concluded. 

4. The AFC-08 Manager may then replenish the unit’s overtime 

payroll account.

iv. The AFC-08 Manager then works with the NPFC to shift the specific 

overtime expense in CAS from AFC-08 to the appropriate response fund.