Should program costs managed by and executed within a major headquarters activity be reported?
• Answer:- Yes, if a headquarters is the program manager for a program and not just the holder of the funds, the costs should be counted. As a program manager, the headquarters usually develops policy, allocates and distributes resources, and controls execution of the program and may even directly execute the program. Total obligations (TOA) should be limited to costs directly in support of the MHA and not include operational elements of expense for programs centrally funded or if managed in the headquarters but executed elsewhere in the Department. Personnel managing those centrally funded programs, however, should be included in the MHA account if they are assigned to an MHA (per paragraph 4.1.1.- 4.1.3. of the directive) or if they meet the criteria of paragraph 3.1.1 of the directive, e.g., “primarily responsible for overseeing, directing, controlling subordinate organizations or units through: (1) allocation and distribution of resources, (2) mid- and long-range planning, programm
