Could Washington county commissioners approve several payment vouchers on one signed transmittal instead of signing each voucher?

Plain-English summary

In 1965, the Washington Attorney General concluded that county commissioners could approve a group of payment vouchers by signing a transmittal rather than each voucher. The state auditor's prescribed form identified every claim by voucher number, claimant, purpose, and amount, bore the commissioners' signatures, and called for approval to be recorded in board minutes. The method changed the paperwork, not the board's responsibility to approve each expenditure.

A county auditor could not reject otherwise proper claims simply to force individual signatures on each voucher. The opinion preserved the auditor's ability to reject a particular expenditure clearly beyond the commissioners' legal authority or a voucher defective in form or substance.

Currency note

This opinion was issued in 1965. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

Common questions

Did every commissioner have to sign every voucher separately?
No. The AG approved a signed transmittal that identified each voucher and was reflected in the board minutes.

Could the county auditor refuse all transmittal-approved claims?
No. The auditor could not reject them just because the commissioners used that approval method.

When could an auditor reject one of those vouchers?
The opinion allowed rejection where the expenditure was clearly beyond the board's authority or the voucher was otherwise defective in form or substance.

Background and statutory framework

The opinion relied on the state auditor's accounting authority in RCW 43.09.200 and the county claims process in RCW 36.22.040 and RCW 36.22.050. It found no statute requiring commissioners' signatures on each voucher face. The board still had to approve each claim and keep a corresponding record.

Citations and references

• Statutes discussed: RCW 43.09.200; RCW 36.22.040; RCW 36.22.050; RCW 36.32.120.

Source

• Landing page: https://www.atg.wa.gov/ago-opinions/counties-commissioners-vouchers-transmittal-or-blanket-method-approval-auditor

Original opinion text

Attorney General John J. O'Connell

COUNTIES ‑- COMMISSIONERS ‑- VOUCHERS ‑- TRANSMITTAL OR BLANKET METHOD OF APPROVAL ‑- AUDITOR ‑- AUTHORITY TO REJECT ‑- LIMITED TO UNLAWFUL EXPENDITURE OR DEFECTIVE VOUCHER IN FORM OR SUBSTANCE.

(1) The transmittal or blanket method of voucher approval by which the approval of county vouchers by the board of county commissioners is indicated on a transmittal form attached to a group of vouchers rather than on the face of each is permitted under the laws of this state.

(2) The county auditors do not have the authority to refuse to accept claims approved under the transmittal voucher approval system unless the particular expenditure authorized by the board of county commissioners is beyond its legal authority or unless the voucher is in some other respect defective in form or substance.

February 11, 1965

Honorable R. DeWitt Jones
Prosecuting Attorney
Clark County
301 Court House
Vancouver, Washington 98660

Cite as: AGO 65-66 No. 8

Dear Sir:

By letter previously acknowledged you have requested an opinion of this office on questions which we paraphrase as follows:

(1) Is the transmittal or blanket method of voucher approval by which the approval of county vouchers by the board of county commissioners is indicated on a transmittal form attached to a group of vouchers rather than on the face of each voucher legal under the laws of Washington?

(2) Does the county auditor have the discretion to refuse to accept claims approved under the transmittal voucher approval system and compel commissioners to approve each voucher individually?

We answer your first question in the affirmative and your second question in the negative.

[[Orig. Op. Page 2]]

ANALYSIS

(1) Bulletin No. 53, March 30, 1960, issued by the office of the State Auditor, Division of Municipal Corporations, recognizes the program of blanket or transmittal voucher approval, subject to the acceptance and approval of the legislative body of each municipality, and prescribes the form, with explanatory comment, under which vouchers may be certified and forwarded. The prescribed form requires the signatures of each board member, and incorporates each voucher by reference to its number, claimant, purpose, and amount. The auditor's bulletin also expressly recognizes the necessity of a corresponding record of approval in the minutes of the board.

It is clearly within the power of the state auditor to prescribe such a form for use in municipal corporations which elect to use the transmittal voucher approval method. RCW 43.09.200 directs that the state auditor, through the division of municipal corporations, shall:

". . . formulate, prescribe, and install a system of accounting and reporting, which shall be uniform for every public institution, and every public office, and every public account of the same class.

"The system shall exhibit true accounts and detailed statements of funds collected, received, and expended for account of the public for any purpose whatever, and by all public officers, employees, or other persons.

"The accounts shall show the receipt, use, and disposition of all public property, and the income, if any, derived therefrom; all sources of public income, and the amounts due and received from each source; all receipts, vouchers, and other documents kept, or required to be kept, necessary to isolate and prove the validity of every transaction; all statements and reports made or required to be made, for the internal administration of the office to which they pertain; and all reports published or required to be published, for the information of the people regarding any and all details of the financial administration of public affairs."

[[Orig. Op. Page 3]]

For a discussion of the auditor's power under this statute, see, AGO 63-64 No. 28 [[to Cliff Yelle, State Auditor on May 31, 1963]], and as to the nature of a voucher see AGO 59-60 No. 107 [[to Cliff Yelle, State Auditor on March 15, 1960]]. Copies of both opinions are enclosed for your reference.

In our opinion, the system of blanket or transmittal voucher approval is a procedural matter, for the expeditious handling of claims, and its use does not affect either the substance of a claim or the nature of the county commissioners' function in approving claims. Therefore, the state auditor through his division of municipal corporations may lawfully recognize the "blanket voucher method" of voucher approval for adoption by boards of county commissioners, and may implement that system under RCW 43.09.200,supra, if that method of voucher approval does not conflict with any statute. In determining whether any such conflict exists or not, it is necessary to examine the provisions of both chapter 42.24 RCW and the provisions of Title 36 RCW, relating to disbursement of county funds.

Under chapter 42.24 RCW, all county officers disbursing county funds are required to take "itemized vouchers" as a condition precedent to such disbursal. The voucher must be certified by the disbursing officer (RCW 42.24.010) and by the person presenting the claim (RCW 42.24.030) except that in the case of municipal officers' and employees' salaries the certificates are made by the payroll officer (RCW 42.24.030).

After the submission of a claim via a formal "voucher" the first step in presenting it to the county commissioners for their approval is outlined in RCW 36.22.040, as follows:

"The county auditor shall audit all claims, demands, and accounts against the county which by law are chargeable to the county, except such cost or fee bills as are by law to be examined or approved by some other judicial tribunal or officer. Such claims as it is his duty to audit shall be presented to the board of county commissioners for their examination and allowance."

Thereafter, under RCW 36.32.120, it is the duty of the county commissioners to "(5) allow all accounts legally chargeable against the county not otherwise provided for, . . ."

[[Orig. Op. Page 4]]

We find nothing in these or any other statutes which requires the county commissioners to indicate their approval of vouchers by each of their signatures on each individual voucher. All that is required is their formal approval as to each item of county expense, and an appropriate record of such approval prior to payment. That objective is of course clearly accomplished by the individual method of voucher approval whereby each county commissioner signs his name as indicating approval on each individual voucher. In our opinion it is also clearly accomplished by adherence to the form prescribed by the state auditor, whereby each board member signs a certificate indicating his approval of a group of vouchers by number, claimant, purpose and amount of each voucher approved, and such approval is also indicated in the minutes.

(2) For ease of reference we repeat your second question: Does the county auditor have the discretion to refuse to accept claims approved under the transmittal voucher system and compel the commissioners to approve each voucher individually?

In our opinion the county auditor has no discretion or choice in the matter. RCW 36.22.050 provides in pertinent part as follows:

"For claims allowed by the county commissioners, and also for cost bills and other lawful claims duly approved by the competent tribunal designated by law for their allowance, he [the county auditor] shall draw a warrant on the county treasurer, . . ."

The county auditor's duty under this statute is ministerial, and he may not question the act of the commissioners when they act within the scope of their statutory authority in exercising the discretion vested in them. See, State ex rel. Becker v. Wiley, 16 Wn.2d 340, 133 P.2d 507 (1943);State ex rel. Piper v. Pratt, 31 Wn.2d 725, 198 P.2d 814 (1948), at pages 727-728.

In our opinion it is discretionary with each board of county commissioners whether to indicate its approval on the face of each separate voucher or to indicate such approval on a transmittal as approved by the state auditor's Bulletin No. 53. Therefore unless the county auditor has facts indicating [[Orig. Op. Page 5]] that a particular expenditure authorized by the board is clearly beyond its authority, or the voucher is in some other respect defective in form or substance, he has no authority to reject it.

We trust this information will be of assistance to you.

Very truly yours,

JOHN J. O'CONNELL
Attorney General