United States General Accounting Office

GAO Report to Congressional Committees

October 1997 FINANCIAL

MANAGEMENT

Implementation of the

Federal Financial

Management

Improvement Act of

1996

GAO/AIMD-98-1

GAO United States

General Accounting Office

Washington, D.C. 20548

Comptroller General

of the United States

B-277956 

October 1, 1997

The Honorable Fred Thompson

Chairman

The Honorable John Glenn

Ranking Minority Member

Committee on Governmental Affairs

United States Senate

The Honorable Dan Burton

Chairman

The Honorable Henry A. Waxman

Ranking Minority Member

Committee on Government Reform and Oversight

House of Representatives

As required by the Federal Financial Management Improvement Act

(FFMIA) of 1996, Public Law 104-208, this letter provides a status report on

efforts to implement the act’s requirements and on the adequacy of

accounting standards for the federal government. The Congress enacted

FFMIA to improve federal accounting practices and increase the

government’s ability to provide more reliable financial information. Under

FFMIA, beginning with the fiscal year ended September 30, 1997, auditors

for each of the 24 major departments and agencies named in the Chief

Financial Officers (CFO) Act of 1990 must report whether the agencies’

financial management systems comply substantially with federal financial

management systems requirements, applicable federal accounting

standards, and the U. S. Government Standard General Ledger (SGL)1

 at the

transaction level.

To aid congressional oversight and keep the Congress advised on the

status of federal financial management, the act provides that the General

Accounting Office (GAO) report on implementation of the act by October 1

of 1997, and each year thereafter. Specifically, GAO’s report is to summarize

information concerning (1) compliance with the act’s requirements,

including whether the CFO agencies’ financial statements have been

prepared in accordance with applicable accounting standards and (2) the

adequacy of applicable accounting standards for the federal government.

1

The SGL provides a standard chart of accounts and standardized transactions that agencies are to use

in all their financial systems.

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In this, our first FFMIA report, we discuss (1) the act’s requirements,

(2) efforts underway to implement the act, (3) challenges that agencies

face in achieving full compliance with those requirements, and (4) the

status of federal accounting standards.

Results in Brief It is too early to tell the extent to which the 24 agencies named in the CFO

Act will be in compliance with FFMIA requirements for fiscal year 1997

because auditor reports discussing the results of the fiscal year 1997

financial statement audits will generally not be available until March 1,

1998, which is the statutory reporting deadline. The Office of Management

and Budget (OMB) and the CFO agencies have initiated efforts to implement

the act’s requirements and improve financial management systems.

Although auditors performing financial audits under the CFO Act are not

required to report on FFMIA compliance until March 1, 1998, prior audit

results and agency self-reporting all point to significant challenges that

agencies must meet in fully implementing systems requirements,

accounting standards, and the SGL.

Regarding the adequacy of accounting standards, the Federal Accounting

Standards Advisory Board (FASAB) has successfully developed a good

initial set of accounting standards. To date, FASAB has recommended, and

OMB and GAO have issued, two statements of accounting concepts and eight

statements of accounting standards tailored to the federal government’s

unique characteristics and special needs. OMB has integrated these

concepts and standards in its guidance to agencies on the form and

content of their financial statements.

Background The overall purpose of FFMIA is to ensure that agency financial

management systems comply with federal financial management systems

requirements, applicable accounting standards, and the SGL in order to

provide uniform, reliable, and thus more useful financial information. With

such information, government leaders will be better positioned to help

invest scarce resources, reduce costs, oversee programs, and hold agency

managers accountable for the way they run government programs.

The 1990 CFO Act laid the legislative foundation for the federal government

to provide taxpayers, the nation’s leaders, and agency program managers

with reliable financial information through audited financial statements.

Under the CFO Act, as expanded by the Government Management Reform

Act of 1994, 24 major agencies, which account for 99 percent of federal

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outlays, are required to annually prepare organizationwide audited

financial statements beginning with those for fiscal year 1996. Table 1 lists

the 24 CFO agencies and their reported fiscal year 1996 outlays.

Table 1: The 24 CFO Agencies’ Fiscal

Year 1996 Net Outlays Dollars in billions

Agency

Reported fiscal

year 1996 outlays

Department of Agriculture $ 54.3

Department of Commerce 3.7

Department of Defense 285.8

Department of Education 29.7

Department of Energy 16.2

Department of Health and Human Services 319.8

Department of Housing and Urban Development 25.5

Department of the Interior 6.7

Department of Justice 12.0

Department of Labor 32.5

Department of State 5.0

Department of Transportation 38.8

Department of the Treasury 364.6

Department of Veterans Affairs 36.9

Agency for International Development 5.3

Environmental Protection Agency 6.0

Federal Emergency Management Agency 3.1

General Services Administration 0.7

National Aeronautics and Space Administration 13.9

National Science Foundation 3.0

Nuclear Regulatory Commission 0.1

Office of Personnel Management 42.9

Small Business Administration 0.9

Social Security Administration 375.2

Total $1,682.6

Source: Budget of the United States Government, Fiscal Year 1998. We did not independently

verify this information.

Financial audits address the reliability of information contained in

financial statements, provide information on the adequacy of systems and

controls used to ensure accurate financial reports and safeguard assets,

and report on agencies’ compliance with laws and regulations. Building on

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the CFO Act audits, FFMIA requires, beginning with the fiscal year ended

September 30, 1997, that each of the 24 CFO agencies’ financial statement

auditors report on whether the agency’s financial management systems

substantially comply with federal financial management systems

requirements, applicable accounting standards, and the SGL.

Financial Management

System Requirements

The financial management systems policies and standards prescribed for

executive agencies to follow in developing, operating, evaluating, and

reporting on financial management systems are defined in OMB Circular

A-127, “Financial Management Systems,” which was revised in July 1993.

Circular A-127 references the series of publications entitled Federal

Financial Management Systems Requirements, issued by the Joint

Financial Management Improvement Program (JFMIP),2

 as the primary

source of governmentwide requirements for financial management

systems.

JFMIP initially issued Core Financial System Requirements, the first

document in its Federal Financial Management Systems Requirements

series, in January 1988. An updated version reflecting changes in

legislation and policies was released in September 1995. This document

establishes the standard requirements for a core financial system to

support the fundamental financial functions of an agency. Framework for

Federal Financial Management Systems was published in January 1995

and describes the basic elements of a model for an integrated financial

management system in the federal government, how these elements

should relate to each other, and specific considerations in developing and

implementing such an integrated system. In this regard, FFMIA defines

financial management systems as “financial systems”3

 and the financial

portions of “mixed systems”4

 necessary to support financial management,

including automated and manual processes, procedures, controls, data,

hardware, software, and support personnel dedicated to the operation and

maintenance of the system.

2

JFMIP is a cooperative undertaking of OMB, the Department of the Treasury, the Office of Personnel

Management, and GAO working with operating agencies to improve financial management practices

throughout the government. The program was initiated in 1948 and was given statutory authorization

in the Budget and Accounting Procedures Act of 1950 (31 U.S.C. 3511 (d)).

3

A financial system includes an information system of one or more applications that is used for

(1) collecting, processing, or reporting data about financial events; (2) supporting financial planning or

budgeting; (3) accumulating and reporting cost information; or (4) supporting the preparation of

financial statements.

4

A mixed system is an information system that supports both financial and nonfinancial functions.

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Other documents in the JFMIP series provide requirements for specific

types of systems covering personnel/payroll, travel, seized/forfeited asset,

direct loan, guaranteed loan, and inventory systems. Table 2 lists the

publications in the Federal Financial Management System Requirements

Series and their issue dates.

Table 2: Publications in the Federal

Financial Management System

Requirements Series

Federal Financial Management System Requirements (FFMSR)

document Issue date

FFMSR-0 Framework for Federal Financial Management Systems January 1995

FFMSR-1 Core Financial System Requirements September 1995

FFMSR-2 Personnel/Payroll System Requirements May 1990

FFMSR-3 Travel System Requirements January 1991

FFMSR-4 Seized/Forfeited Asset System Requirements March 1993

FFMSR-5 Direct Loan System Requirements December 1993

FFMSR-6 Guaranteed Loan System Requirements December 1993

FFMSR-7 Inventory System Requirements June 1995

In addition to these eight documents, JFMIP is developing additional

systems requirements for managerial cost accounting. This document was

issued as an exposure draft in April 1997.

Federal Accounting

Standards

Federal accounting standards, which agency CFOs use in preparing

financial statements and in developing financial management systems, are

recommended by FASAB. In October 1990, the Secretary of the Treasury,

the Director of OMB, and the Comptroller General established FASAB to

recommend a set of generally accepted accounting standards for the

federal government. FASAB’s mission is to recommend reporting concepts

and accounting standards that provide federal agencies’ financial reports

with understandable, relevant, and reliable information about the financial

position, activities, and results of operations of the U.S. government and

its components.

FASAB recommends accounting standards after considering the financial

and budgetary information needs of the Congress, executive agencies,

other users of federal financial information, and comments from the

public. The Secretary of the Treasury, the Director of OMB, and the

Comptroller General then decide whether to adopt the recommended

standards. If they do, the standards are published by OMB and GAO and

become effective. As discussed further in the section “Status of Federal

Accounting Standards,” this process has resulted in issuance of two

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statements of accounting concepts and eight statements of accounting

standards. GAO published these concepts and standards in FASAB Volume 1,

Original Statements, Statements of Federal Financial Accounting Concepts

and Standards, in March 1997.

The U.S. Standard General

Ledger

In 1984, OMB tasked an interagency group to develop a standard general

ledger chart of accounts for governmentwide use. The resulting SGL was

established and mandated for use by the Department of the Treasury in

1986. Further, OMB Circular A-127, Financial Management Systems,

requires agencies to record financial events using the SGL at the

transaction level.

The SGL provides a uniform chart of accounts and pro forma transactions

used to standardize federal agencies’ financial information accumulation

and processing, enhance financial control, and support budget and

external reporting, including financial statement preparation. Use of the

SGL improves data stewardship throughout the government, enabling

consistent analysis and reporting at all levels within the agencies and at

the governmentwide level. It is published in the Treasury Financial

Manual. The Department of the Treasury’s Financial Management Service

is responsible for maintaining the SGL.

FFMIA Process and

Reporting Requirements

As part of a CFO agency’s annual audit, the auditor is to report whether the

agency’s financial management systems substantially comply with federal

financial management systems requirements, applicable accounting

standards, and the SGL. If the auditor determines that an agency’s financial

management systems do not substantially comply with these

requirements, the act requires that the audit report (1) identify the entity

or organization responsible for management and oversight of the

noncompliant financial management systems, (2) disclose all facts

pertaining to the failure to comply, including the nature and extent of the

noncompliance, the primary reason or cause of the noncompliance, the

entity or organization responsible for the noncompliance, and any relevant

comments from responsible officers or employees, and (3) include

recommended corrective actions and proposed time frames for

implementing such actions.

The act assigns to the head of an agency responsibility for determining,

based on a review of the auditor’s report and any other relevant

information, whether the agency’s financial management systems comply

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B-277956 

with the act’s requirements. This determination is to be made no later than

120 days after the receipt of the auditor’s report, or the last day of the

fiscal year following the year covered by the audit, whichever comes first.

If the head of an agency determines that the agency does not comply with

the act’s requirements, the agency head, in consultation with the Director

of OMB, shall establish a remediation plan that will identify, develop, and

implement solutions for noncompliant systems. The remediation plan is to

include corrective actions, time frames, and resources necessary to

achieve substantial compliance with the act’s requirements within 3 years

of the date the noncompliance determination is made. If, in consultation

with the Director of OMB, the agency head determines that the agency’s

financial management systems are so deficient that substantial compliance

cannot be reached within 3 years, the remediation plan must specify the

most feasible date by which the agency will achieve compliance and

designate an official responsible for effecting the necessary corrective

actions.

Under the FFMIA process, the auditor’s and the agency head’s

determinations of compliance may differ. In such situations, the Director

of OMB will review the differing determinations and report on the findings

to the appropriate congressional committees.

The act also contains additional reporting requirements. OMB is required to

report each year on the act’s implementation. In addition, each inspector

general (IG) of the 24 CFO agencies is required to report to the Congress, as

part of its semiannual report, instances in which an agency has not met the

intermediate target dates established in its remediation plan and the

reasons why.

Guidance Issued for

Assessing Compliance

With FFMIA

Requirements

Efforts are underway to implement FFMIA and improve the quality of

financial management systems. OMB recently issued implementation

guidance in a memorandum dated September 9, 1997, for agencies and

auditors to use in assessing compliance with FFMIA. This is interim

guidance to be used in connection with audits of federal financial

statements for fiscal year 1997.

OMB’s guidance emphasizes implementation of federal financial

management improvements by fully describing in separate sections each

of the requirements under the act, which are (1) federal financial

management systems requirements, (2) applicable federal accounting

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standards, and (3) the SGL at the transaction level. Each section begins by

identifying and discussing the executive branch policy documents that

previously established the requirement. Information is also provided on

the meaning of substantial compliance and the types of indicators that

should be used in assessing whether an agency is in substantial

compliance. For example, one indicator of substantial compliance with

financial management systems requirements would include financial

management systems that meet the requirements of OMB Circular A-127.

Likewise, an indicator of substantial compliance with financial accounting

standards would include an agency that has no material weaknesses in

internal controls that affect its ability to prepare auditable financial

statements and related disclosures in accordance with federal accounting

standards.

Information is also provided for the auditor to consider in evaluating and

reporting audit results, as well as other reporting requirements. The

guidance states that the auditor shall use professional judgment in

determining substantial compliance with FFMIA. Further, substantial

noncompliance in any one or more of the three requirements of FFMIA

would result in substantial noncompliance with FFMIA. For example, an

agency could have an unqualified5

 opinion on its financial statements

indicating that the financial statements are prepared in accordance with

applicable federal accounting standards, yet have financial management

systems that are not in substantial compliance with financial management

systems requirements. This situation would preclude the agency from

being in substantial compliance with FFMIA. Finally, the guidance also

directs auditors to follow the reporting guidance, with respect to

compliance, contained in OMB Bulletin 93-06.6

We have been discussing with OMB some refinements to this bulletin, with

particular focus on four areas: (1) clarifying, based on information

provided in OMB’s implementation guidance, that the auditor should

perform tests of the reporting entity’s compliance with the requirements of

FFMIA, (2) including in the reporting entity’s management representation

5

An unqualified or “clean” opinion on an agency’s financial statements indicates that the auditor

concludes that the principal statements and accompanying notes are free from material misstatement

and are presented fairly in conformity with established accounting principles applied on a consistent

basis.

6

OMB Bulletin 93-06, Audit Requirements for Federal Financial Statements, establishes requirements

and guidance for auditors to follow in auditing federal financial statements. OMB Bulletin 93-06

requires an auditor’s report at the completion of an audit, comprised of at least the following three

parts: (1) a report containing an opinion on the reporting entity’s financial statements, (2) a report on

internal control structure, and (3) a report on the reporting entity’s compliance with applicable laws

and regulations.

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letter a representation about whether the reporting entity’s financial

management systems are in substantial compliance with FFMIA

requirements, (3) clarifying that the auditor’s report on the reporting

entity’s compliance with applicable laws and regulations state that the

auditor performed sufficient compliance tests of FFMIA requirements to

report whether the entity’s financial management systems comply

substantially with FFMIA requirements, and (4) separately stating in the

auditor’s report whether such tests disclosed any instances in which the

reporting entity’s financial management systems did not comply

substantially with FFMIA requirements.

Finally, we have discussed with OMB the requirement in the act, that if the

reporting entity does not comply substantially with FFMIA requirements,

the auditor’s report needs to

• identify the entity or organization responsible for the financial

management systems that have been found not to comply with FFMIA

requirements;

• disclose all facts pertaining to the noncompliance, including

• the nature and extent of the noncompliance, such as the areas in which

there is substantial but not full compliance;

• the primary reason or cause of the noncompliance;

• the entity or organization responsible for the noncompliance; and

• any relevant comments from reporting entity management or employee

responsible for the noncompliance; and

• state recommended remedial actions and the time frames to implement

such actions.

We are also exploring other tools to assist the CFO and IG communities in

implementing OMB’s interim guidelines. OMB plans to review its interim

guidelines and replace them during 1998 with revisions to appropriate OMB

policy documents.

Agencies are also taking steps to improve the quality of their financial

management systems. According to the CFO Council’s and OMB’s Status

Report on Financial Management Systems, dated June 1997, agencies are

reporting plans to replace or upgrade operational applications within the

next 5 years. For applications that are now under development or in the

process of a phased implementation, reported plans are also in place to

fully implement the SGL at the transaction level and comply with federal

financial management system requirements. This report indicates that

many agencies are also reporting considering greater use of commercial

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off-the-shelf software, cross-servicing, and outsourcing as they seek more

effective ways to improve their financial management systems. Successful

implementation of these efforts will be instrumental in achieving future

compliance with FFMIA requirements.

Challenges in

Implementing the Act

Agencies face significant challenges in achieving substantial compliance

with the act’s requirements in the near future. The majority of agencies did

not receive an unqualified opinion on their fiscal year 1996 financial

statements. In addition, fiscal year 1996 financial management systems

inventory data, self-reported by agencies and summarized in the CFO

Council’s and OMB’s June 1997 Status Report on Federal Financial

Management Systems, reveal that the majority of agencies’ financial

systems did not comply with federal financial management systems

requirements or the SGL at the transaction level prior to FFMIA’s effective

date.

An inability to prepare timely and accurate financial statements suggests

that agencies find it difficult to effectively implement applicable federal

accounting standards. A financial statement audit provides a meaningful

measure of compliance with applicable federal accounting standards. An

unqualified opinion is one of several indications that the agency’s financial

management systems support the preparation of accurate and reliable

financial statements with minimal manual intervention. However, for fiscal

year 1996, only 6 of the 24 CFO agencies received unqualified opinions on

their organizationwide financial statements. Further, according to OMB’s

Federal Financial Management Status Report & Five-Year Plan, only 13 CFO

agencies anticipate being able to obtain unqualified opinions on their fiscal

year 1997 financial statements.

Our past audit experience has indicated that numerous agencies’ financial

management systems do not maintain and generate original data to readily

prepare financial statements. Consequently, many agencies have relied on

ad hoc efforts and manual adjustments to prepare financial statements.

Such procedures can be time-consuming, produce inaccurate results, and

delay the issuance of audited statements. In addition, agencies’ lack of

reliable and consistent financial information on a regular, ongoing basis

undermines federal managers’ ability to effectively evaluate the cost and

performance of government programs and activities.

Also, the current status of federal financial management systems portends

potential problems in agencies complying fully with federal financial

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management systems requirements and the SGL as mandated by the act.

When FFMIA was enacted, federal agencies lacked many of the basic

systems needed to provide uniform and reliable financial information.

Agencies are still struggling to comply with governmentwide standards

and requirements, although they have recently exhibited some progress in

implementing and maintaining financial management systems that comply

with federal financial system requirements and the SGL.

For instance, according to the CFO Council’s and OMB’s FY 1995 Status

Report on Federal Financial Management Systems, issued in June 1996,

only 29 percent of agencies’ financial management systems were reported

to be in compliance with JFMIP federal financial management system

requirements. In addition, agencies had fully implemented the SGL in only

40 percent of the operational applications to which they reported it

applied. The fiscal year 1996 status report, issued in June 1997, showed

some improvement, with 36 percent of agencies’ financial management

systems reported as complying with federal financial management system

requirements and full SGL implementation reported in 45 percent of the

applications to which agencies reported it applied. However, these

statistics indicate that the majority of agencies’ financial management

systems still lacked compliance with financial management systems

requirements and full SGL implementation in fiscal year 1996.

Status of Federal

Accounting Standards

Using a due process and consensus building approach, FASAB has

successfully provided the federal government with an initial set of

accounting standards. To date, FASAB has recommended, and OMB and GAO

have issued, two statements of accounting concepts7 and eight statements

of accounting standards with various effective dates ranging from fiscal

year 1994 through fiscal year 1998. These concepts and standards, which

are listed in table 3, underpin OMB’s guidance to agencies on the form and

content of their financial statements.

7

Effective dates do not apply to Statements of Federal Financial Accounting Concepts.

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Table 3: Statements of Federal

Financial Accounting Concepts

(SFFAC) and Standards (SFFAS) and

Their Effective Dates Concepts

SFFAC No. 1 Objectives of Federal Financial Reporting

SFFAC No. 2 Entity and Display

Standards

Effective for

fiscal year

SFFAS No. 1 Accounting for Selected Assets and Liabilities 1994

SFFAS No. 2 Accounting for Direct Loans and Loan Guarantees 1994

SFFAS No. 3 Accounting for Inventory and Related Property 1994

SFFAS No. 4 Managerial Cost Accounting Concepts and Standards 1997a

SFFAS No. 5 Accounting for Liabilities of the Federal Government 1997

SFFAS No. 6 Accounting for Property, Plant, and Equipment 1998

SFFAS No. 7 Accounting for Revenue and Other Financing Sources 1998

SFFAS No. 8 Supplementary Stewardship Reporting 1998

aFASAB has recommended to OMB, the Department of the Treasury, and GAO that this statement

be deferred until 1998.

In addition to the two concepts and eight standards, FASAB is working on

standards relating to management’s discussion and analysis of federal

financial statements, social insurance, the cost of capital, natural

resources, and computer software costs.

The objectives of federal financial reporting are to provide users with

information about budgetary integrity, operating performance,

stewardship, and systems and controls. With these as the objectives of

federal financial reporting, the federal government can better develop new

reporting models that bring together program performance information

with audited financial information and provide congressional and other

decisionmakers with a more complete picture of the results, operational

performance, and the costs of agencies’ operations.

FFMIA is intended to improve federal accounting practices and increase the

government’s ability to provide credible and reliable financial information.

Such information is important in providing a foundation for formulating

budgets, managing government program operations, and making difficult

policy choices. Efforts are underway both in assisting agencies in

implementing the act’s requirements and to assist auditors in measuring

compliance with the act’s requirements. However, long-standing problems

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with agencies’ financial management systems suggests that agencies will

have difficulty, at least in the short term, achieving compliance with the

act’s requirements. Successful implementation of the act and resulting

financial management improvements depend on the united effort of all

organizations involved, including agency CFOs, IGs, OMB, the Department of

the Treasury, and GAO.

In performing our work, we evaluated OMB’s implementation guidance for

FFMIA. In addition, we reviewed the CFO Council’s and OMB’s June 1997 and

1996 Status Report on Federal Financial Management Systems and OMB’s

June 1997 Federal Financial Management Status Report & Five-Year Plan.

We did not verify or test the reliability of the data in these reports. Further,

we reviewed fiscal year 1996 audit results for the 24 CFO agencies and

applicable federal accounting standards. We conducted our work from

July through September 1997 at GAO headquarters in Washington, D.C. in

accordance with generally accepted government auditing standards. We

provided a draft of this report to OMB and Treasury and they generally

concurred with its contents. We have incorporated their comments as

appropriate.

We are sending copies of this letter to the Chairmen and Ranking Minority

Members of the Subcommittee on Oversight of Government Management,

Restructuring, and the District of Columbia, Senate Committee on

Governmental Affairs; the Subcommittee on Government Management,

Information, and Technology, House Committee on Government Reform

and Oversight; other interested congressional committees; the Director,

Office of Management and Budget; the Secretary of the Treasury; heads of

the 24 CFO agencies; agency CFOs and IGs; and other interested parties. We

will also make copies available to others upon request.

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This letter was prepared under the direction of Gloria L. Jarmon, Director,

Civil Audits/Health and Human Services, who may be reached at

(202) 512-4476 if you or your staffs have any questions. Major contributors

to this letter are listed in appendix I.

James F. Hinchman

Acting Comptroller General

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Page 15 GAO/AIMD-98-1 Status of FFMIA
Appendix I 

Major Contributors to This Report

Accounting and

Information

Management Division,

Washington, D.C.

Deborah A. Taylor, Assistant Director

Maria Cruz, Senior Audit Manager

Anastasia Kaluzienski, Audit Manager

(919130) Page 16 GAO/AIMD-98-1 Status of FFMIA
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