SIT Invoicing Issue in DPS

There has been a lot of concern expressed by TSPs about a potential problem dealing with SIT in DPS. Specifically, there is concern that they will not be able to bill for the entire storage time if the DPS issued SIT control number reflects a different Julian date than the actual date the shipment went into storage.

There have been a number of instances where storage has been authorized by PPSO, but for various reasons, the authorization had not been entered into DPS until days, or even weeks, later, which resulted in SIT control number reflecting a Julian date later than the date the shipment went into SIT. The concern is that DPS would only allow TSPs to invoice for the storage starting on the Julian date reflected in the SIT control number, not the day the shipment actually went into storage.

We have been watching a number of shipments that fall into this situation, and have been waiting for them to deliver out of storage so we can invoice them to see what would occur. We have recently been able to invoice a handful of these, and the invoices have paid for the full amount of storage time, regardless of the Julian date reflected in the SIT control number. Therefore, it appears that a SIT control number issued after the fact will not prevent TSPs from collecting the full amount due them for storage.

While this is certainly good news for the short term, there is still a concern about the long term implication of this issue. When GSA is doing audits a couple of years from now, will they start issuing overcharges based on the fact that the SIT control number indicates a different date into SIT than the TSP billed? Based on past experience with defending GSA notices of overcharge, this would seem to be a very real possibility, and those overcharges would be very challenging to contest.

The ideal solution would be to allow the PPSO to backdate the SIT control number so that it reflects the date that the shipment was authorized to be placed into storage. Until that change is made, this issue will still cause a lot of concern for TSPs, if not in the near term, then probably at some point down the road.

Related Posts

1. SIT Control Number Issue Resurfaces - August 31st, 2010
2. New DPS Invoicing Transmission Issue Identified - November 8th, 2010
3. DPS SIT Conversion Issue Clarified - April 22nd, 2010