EXECUTIVE OFFICE OF THE PRESIDENT 

 OFFICE OF MANAGEMENT AND BUDGET 

 WASHINGTON, D.C. 20503 

 

September 4, 2007 

OMB BULLETIN NO. 07-04 

TO THE HEADS, INSPECTORS GENERAL, AND CHIEF FINANCIAL OFFICERS OF 

EXECUTIVE DEPARTMENTS AND ESTABLISHMENTS 

SUBJECT: Audit Requirements for Federal Financial Statements 

1. Purpose. This Bulletin, which includes an attachment and Appendices A-H, establishes minimum 

requirements for audits of Federal financial statements. The Bulletin is issued under the authority of 

the Budget and Accounting Act of 1921 (42 Stat. 20), as amended, and the Budget and Accounting 

Procedures Act of 1950 (64 Stat. 832), as amended. It implements the audit provisions of the Chief 

Financial Officers (CFO) Act of 1990 (Pub. L. No. 101-576), as amended, the Government 

Management Reform Act (GMRA) of 1994 (Pub. L. No. 103-356), and the Federal Financial 

Management Improvement Act of 1996 (Pub. L. No. 104-208, title VIII). The requirements of this 

Bulletin are set forth in the attachment.

2. Applicability. The provisions of this Bulletin apply to audits of financial statements of executive 

departments, agencies, and government corporations (Appendices A, C, and D) and certain 

components of these agencies (Appendix B). Effective for fiscal year 2008, the provisions in 

Paragraphs 2.8, 6.11, and 7.13 of the Bulletin will no longer apply. Instead, OMB and agency officials 

with responsibility for performance management will develop a separate framework for independent 

verification and validation of performance data starting for fiscal year 2008.

3. Rescissions. The provisions of this Bulletin supersede the provisions in OMB Bulletin No. 06-03, 

Audit Requirements for Federal Financial Statements; OMB Memorandum M-07-12, Guidance to 

OMB Bulletin No. 06-03, Audit Requirements for Federal Financial Statements, on Auditing 

Allocation Transfers; and OMB Memorandum M-04-11, Service Organization Audits. 

4. Effective Date. The provisions of this Bulletin are effective immediately for audits of financial 

statements, unless stipulated otherwise. Audit reports shall be submitted to the agency head in 

sufficient time to enable the agency head to meet the deadline for submitting the audited financial 

statements no later than 45 days after the fiscal year-end. 

5. Inquiries. Further information concerning this Bulletin may be obtained from the Office of 

Management and Budget, Office of Federal Financial Management at 202-395-3993. 

6. Copies. Individual copies of this bulletin may be obtained from the OMB website at 

http://www.whitehouse.gov/omb/financial/index.html. 

Stephen S. McMillin 

Acting Director 

Attachment 
TABLE OF CONTENTS 

SUMMARY OF SIGNIFICANT CHANGES................................................................................................. 1

SECTION 1: BACKGROUND........................................................................................................................ 4

SECTION 2: DEFINITIONS .......................................................................................................................... 4

SECTION 3: FREQUENCY OF AUDIT ....................................................................................................... 7

SECTION 4: RESPONSIBILITY FOR AUDIT............................................................................................ 7

SECTION 5: COMMUNICATION................................................................................................................. 8

Restatements ................................................................................................................................................. 8 

SECTION 6: SCOPE OF THE AUDIT........................................................................................................ 11

Service Organizations................................................................................................................................. 14 

SECTION 7: AUDIT REPORT .................................................................................................................... 14

Audit Report................................................................................................................................................ 14 

Report on Internal Control .......................................................................................................................... 17 

Report on Compliance with Applicable Laws and Regulations ................................................................. 17 

Compliance with FFMIA.................................................................................................................... 18 

Compliance with OMB Circular No. A-123, Appendix A ................................................................. 19 

Status/Comments/Distribution .................................................................................................................... 20 

Subsequent Discovery of Facts................................................................................................................... 21 

SECTION 8: MANAGEMENT REPRESENTATION LETTER.............................................................. 21

SECTION 9: LEGAL REPRESENTATION LETTERS AND MANAGEMENT'S SCHEDULES ...... 23

SECTION 10: COMMUNICATING OTHER DEFICIENCIES............................................................... 24

SECTION 11: AGREED-UPON PROCEDURES: RETIREMENT, HEALTH BENEFITS, AND LIFE 

INSURANCE WITHHOLDINGS/CONTRIBUTIONS AND SUPPLEMENTAL 

SEMIANNUAL HEADCOUNT REPORT SUBMITTED TO THE OFFICE OF PERSONNEL 

MANAGEMENT (OPM) ................................................................................................................. 25

SECTION 12: INSPECTOR GENERAL OVERSIGHT............................................................................ 26

SECTION 13: AUDIT OF THE SPECIAL-PURPOSE FINANCIAL STATEMENTS.......................... 26

Audit Report................................................................................................................................................ 28 

Section on Internal Control......................................................................................................................... 29 

Section on Compliance with the TFM ........................................................................................................ 29 

Status/Comments/Distribution .................................................................................................................... 30 

Communicating Other Deficiencies............................................................................................................ 30 

Intragovernmental Balances: Supplementary and Agreed-Upon Procedures (AUP)................................. 30 

SECTION 14: SIGNIFICANT DUE DATES AND CONTACT INFORMATION FOR FINANCIAL 

STATEMENTS AND RELATED REPORTS ............................................................................... 31

TABLE OF APPENDICES............................................................................................................................. 32

APPENDIX A: Executive Departments and Agencies Subject to the CFO Act......................................... 33 

APPENDIX B: Components of Executive Departments and Agencies...................................................... 34 

APPENDIX C: Accountability of Tax Dollars Agencies ........................................................................... 35 

APPENDIX D: Government Corporations................................................................................................. 37 

APPENDIX E: General Laws..................................................................................................................... 38 

APPENDIX F: Illustrative Management Representation Letter—Special-Purpose Financial Statements. 39 

APPENDIX G: Illustrative Independent Auditors’ Report on Special-Purpose Financial Statements....... 41 

APPENDIX H: Illustrative Agreed-Upon Procedures on Intragovernmental Material Differences .......... 45 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements i
SUMMARY OF SIGNIFICANT CHANGES 

SECTION 

TITLE 

PARAGRAPH 

NUMBER(S) CHANGES 

Definitions 2.5 & 2.8 • Clarified that “significant deficiencies” found 

under FISMA must also be reported as material 

weaknesses under FMFIA and (formerly or) as 

a lack of substantial compliance under FFMIA 

if related to financial management systems. 

• Clarified that internal controls should be 

designed with applicable laws, regulations, 

government-wide polices, and laws identified 

by OMB that are listed in Appendix E. 

• Indicated that “Reliability of Performance 

Reporting” will be excluded from the “Internal 

Control” definition effective starting in fiscal 

year 2008. 

Communication 5.3-5.6 & 

5.7-5.11 

• Added a section on Previously-Issued 

Financial Statements. 

• Added a section on Misstatements Affecting 

Previously-Issued Financial Statements. 

Scope of the Audit 6.5, 6.11, 

& 6.16 

• Added a discussion to clarify auditors’ roles 

when auditing allocation transfers. 

• Indicated that the requirement for the auditor to 

obtain an understanding of the components of 

internal control relating to the existence and 

completeness assertions relevant to the 

performance measures included in the MD&A 

and reporting thereupon if these internal 

controls have not been properly designed and 

placed in operation will be excluded from the 

scope of the audit effective starting in fiscal 

year 2008. 

• Updated Service Organizations section for 

improved alignment with AU § 324, Service 

Organizations.

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 1
SECTION 

TITLE 

PARAGRAPH 

NUMBER(S) CHANGES 

Audit Report 7.7-7.8, 

7.11, 7.13, 

7.20, 7.21-

7.22, & 

7.26 

• Expanded the requirements for reporting on 

restated financial statements. 

• Added a requirement for following AU § 552, 

Reporting on Condensed Financial Statements 

and Selected Financial Data when reporting 

on a “Highlights” or similar document. 

• Indicated that the requirement for the report to 

state that, with respect to the internal control 

objective relating to the performance measures 

included in the MD&A, the auditor obtained an 

understanding of the design of internal controls 

relating to the existence and completeness 

assertions and determined whether they have 

been placed in operation will be excluded from 

the internal control report effective starting in 

fiscal year 2008. 

• Added further discussion, in a footnote, for 

reporting on when financial management 

systems substantially comply with FFMIA 

section 803(a) requirements. 

• Updated the Compliance with OMB Circular 

No. A-123, Appendix A section to reflect, 

among other things, management’s discretion 

in planning for and implementing their A-123, 

Appendix A program. 

• Added the Agency Financial Report (if 

applicable) and a footnote about OMB’s 2007 

PAR Pilot, of which it is a part, as one of the 

entity’s documents that should include the 

audit report. 

Legal Representation 

Letters and 

Management’s 

Schedules 

9.6 • Changed the date from the end of fieldwork to 

the audit completion date for informing FMS, 

via email, of any subsequent changes in cases 

that arise after the final representation letter 

(Per SAS No. 103 changes for dating the audit 

report). 

Audit of the SpecialPurpose Financial 

Statements 

13.33 • Added a requirement for OMB to contact those 

entities and their respective OIGs that meet 

certain criteria related to intragovernmetal 

material differences so that Agreed-Upon 

Procedures can be developed with FMS for the 

third quarter of fiscal year 2007. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 2
SECTION 

TITLE 

PARAGRAPH 

NUMBER(S) CHANGES 

Appendix E NA • Deleted the Federal Financial Management 

Improvement Act of 1996 (FFMIA), Pub. L. 

No. 104-208, title VIII because FFMIA is not a 

law directed at the fair presentation of the 

financial statements. This change clarified that 

auditors are required to test and report on an 

entity’s compliance with FFMIA as indicated 

in Paragraphs 6.13 and 7.20. 

Appendix H NA • Added this Appendix as an illustrative example 

of the Agreed-Upon Procedures to be 

developed by FMS and those entities and their 

respective OIGs that meet certain criteria 

related to intragovernmental material 

differences. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 3
 

AUDIT REQUIREMENTS FOR FEDERAL FINANCIAL STATEMENTS 

SECTION 1: BACKGROUND 

1.1 The Government Management Reform Act (GMRA) of 1994 (Pub. L. No. 103-356) 

amended the requirements of the Chief Financial Officers (CFO) Act of 1990 (Pub. L. No. 101-

576) by requiring, among other things, the annual preparation and audit of organization-wide 

financial statements of the 24 major executive departments and agencies (Appendix A). The 

GMRA also requires audited financial statements of components of executive departments and 

agencies designated by the Director of the Office of Management and Budget (OMB), which are 

identified in Appendix B. 

1.2 The Accountability of Tax Dollars Act (ATDA) of 2002 (Pub. L. No. 107-289) 

(Appendix C) amended the CFO Act further to extend the requirements of the annual preparation 

and audit of organization-wide financial statements to the remainder of the executive agencies 

not already required to do so through another provision of Federal law. 

1.3 The Government Corporation Control Act (59 Stat. 597, codified at 31 U.S.C. § 841-869) 

(Appendix D) requires, among other things, the annual preparation and audit of organizationwide financial statements of “mixed-ownership” and “wholly owned” Government corporations. 

SECTION 2: DEFINITIONS 

For the purposes of this Bulletin, the following definitions apply: 

2.1 Annual Financial Statement means the financial statement of a reporting entity as 

described in Section 3515 of Title 31 of the United States Code and OMB Circular No. 

A-136, Financial Reporting Requirements, as revised (A-136). The “Annual Financial 

Statement” will consist of: 

• Management's Discussion and Analysis (part of RSI). 

• Basic Statements. The basic statements1

 will include: 

o Balance Sheet. 

o Statement of Net Cost. 

o Statement of Changes in Net Position. 

o Statement of Budgetary Resources. 

o Statement of Custodial Activity, if applicable. 

o Statement of Social Insurance, if applicable. 

o Related Note Disclosures. 

• Required Supplementary Stewardship Information (RSSI), if applicable. 

• Required Supplementary Information (RSI). 

• Other Accompanying Information, if applicable. 

 

1

 This list is included in the A-136, which prescribes the Basic Statements that will be prepared. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 4
2.2 Codification of Statements on Auditing Standards is a codification of Statements on 

Auditing Standards (AU) issued by the American Institute of Certified Public Accountants 

(AICPA). The AICPA's standards of field work and reporting and related Statements on 

Auditing Standards are incorporated in U.S. Government Auditing Standards unless specifically 

excluded or modified by generally accepted government auditing standards (GAGAS). 

2.3 Federal Financial Management Improvement Act of 1996 (FFMIA) (Pub. L. No. 

104-208, title VIII) section 803(a) requirements are Federal financial management systems 

requirements, applicable Federal accounting standards, and the United States Standard General 

Ledger at the transaction level. The 24 major CFO Act agencies are required to establish and 

maintain financial management systems that comply substantially with these requirements. 

Agencies subject to the ATDA and Government Corporation Control Act are not subject to the 

requirements of FFMIA, with the exception of a government corporation that is also a 

component of a CFO Act agency. Those government corporations are subject to FFMIA similar 

to all other components of the CFO Act agencies. The government corporations, however, are 

not required to report separately on compliance with FFMIA in their management reports. 

2.4 Federal Managers’ Financial Integrity Act (FMFIA) (Pub. L. No. 97-255, codified 

at 31 U.S.C. § 3512) requires Executive Branch agencies to establish and maintain effective 

internal control. The heads of agencies must annually evaluate and report on the effectiveness 

of the internal control (Section 2) and financial management systems (Section 4) that protect the 

integrity of Federal programs. 

2.5 Federal Information Security Management Act (FISMA) (Pub. L. No. 107-296, as 

amended by Pub. L. No. 108-177) requires agencies to provide information security controls 

commensurate with the risk and potential harm of not having those controls in place. The heads 

of agencies and Offices of Inspectors General are required to annually report on the 

effectiveness of the agencies’ security programs. “Significant deficiencies” found under 

FISMA must also be reported as material weaknesses under FMFIA and as a lack of substantial 

compliance under FFMIA if related to financial management systems. 

2.6 Generally Accepted Accounting Principles (GAAP) for Federal government entities 

are identified in Statement on Auditing Standards (SAS) No. 91, Federal GAAP Hierarchy, 

Amendment to SAS 69, The Meaning of Present Fairly In Conformity With Generally Accepted 

Accounting Principles, which is codified in AU § 411 of the AICPA's Codification of 

Statements on Auditing Standards. Federal financial statements will be prepared in accordance 

with A-136. The requirements of A-136 are generally accepted accounting principles because 

they constitute “practices that are widely recognized and prevalent in the federal government” 

under category (D) of the Federal GAAP Hierarchy. 

2.7 Independent Auditor means an auditor who meets the independence standards 

specified in the U.S. Government Auditing Standards. An independent auditor may include an 

agency’s Office of Inspector General (OIG) and/or an independent public accountant (IPA). 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 5
2.8 Internal Control as it relates to the Basic Statements is a process, affected by 

the agency's management and other personnel, designed to provide reasonable 

assurance that the following objectives are met: 

• Reliability of financial reporting - transactions are properly recorded, processed, 

and summarized to permit the preparation of the Basic Statements in accordance 

with generally accepted accounting principles, and assets are safeguarded against 

loss from unauthorized acquisition, use, or disposition. 

• Compliance with applicable laws, regulations, and government-wide policies - 

transactions are executed in accordance with laws governing the use of budget 

authority, government-wide policies, laws identified by OMB in Appendix E of 

this Bulletin, and other laws and regulations that could have a direct and material 

effect on the Basic Statements. 

• Reliability of performance reporting - transactions and other data that support 

reported performance measures are properly recorded, processed, and summarized 

to permit the preparation of performance information in accordance with criteria 

stated by management. Effective starting in fiscal year 2008, this definition will 

be excluded from the Internal Control definition. 

2.9 Management Letter means a letter prepared by the auditor which discusses findings 

and recommendations for improvements in internal control, which were identified during the 

audit and were not required to be included in the auditors’ report on internal control, and other 

management issues. 

2.10 Management's Discussion and Analysis (MD&A) is a clear and concise description of 

the reporting entity’s performance measures, financial statements, systems and controls, 

compliance with laws and regulations, and actions taken or planned to address problems.2

 The 

MD&A is included in each annual financial statement as required supplementary information. 

The A-136 provides additional guidance on the composition of the MD&A. 

2.11 Material Weakness is a significant deficiency, or combination of significant 

deficiencies, that result in a more than remote3

 likelihood that a material misstatement of the 

financial statements will not be prevented or detected. This material weakness definition aligns 

with the same material weakness definition used by management to prepare an agency’s FMFIA 

assurance statement. 

2.12 Reporting Entity means one of the executive departments, agencies, government 

corporations and components of such departments and agencies listed in Appendices A–D, or an 

 

2

 Statement of Federal Financial Accounting Standards (SFFAS) No. 15, Management's Discussion and Analysis 3

 The term “remote” is defined in SFFAS No. 5, Accounting for Liabilities of the Federal Government, as the chance 

of the future event or events, occurring is slight. Therefore, the likelihood of an event is “more than remote” when it 

is at least reasonably possible. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 6
agency, bureau, or other organization that represents a meaningful unit for program 

management, for which a financial statement is prepared, and for which management chose to 

have an audit performed in accordance with this Bulletin. 

2. 13 Significant Deficiency 4 is a deficiency in internal control, or a combination of 

deficiencies, that adversely affects the entity’s ability to initiate, authorize, record, process, or 

report financial data reliably in accordance with generally accepted accounting principles such 

that there is more than a remote5 likelihood that a misstatement of the entity’s financial 

statements that is more than inconsequential6 will not be prevented or detected. The term 

“significant deficiency” replaces the former term “reportable condition.” This “significant 

deficiency” definition aligns with the “reportable condition” definition used by management to 

prepare an agency’s FMFIA assurance statement. 

2.14 U.S. Government Auditing Standards (also referred to as generally accepted 

government auditing standards or GAGAS) are those standards issued by the Comptroller 

General of the United States. 

2.15 Government Accountability Office/President’s Council on Integrity and Efficiency 

Financial Audit Manual (GAO/PCIE FAM) provides methodology and guidance for 

performing audits of federal financial statements in compliance with relevant auditing and 

attestation standards and OMB guidance. References to the FAM do not establish requirements 

for auditors. 

2.16 U.S. Standard General Ledger (USSGL) means the uniform chart of accounts 

prescribed by the Department of the Treasury in its Treasury Financial Manual (TFM) 

(http://www.fms.treas.gov/ussgl/). 

SECTION 3: FREQUENCY OF AUDIT 

Audits will be performed annually. 

SECTION 4: RESPONSIBILITY FOR AUDIT 

For purposes of this Bulletin, the following responsibilities apply: 

4.1 For the 24 major CFO Act executive departments and agencies and selected 

components of such departments and agencies listed in Appendices A and B, the audits 

 

4

 The revision to the definition of significant deficiency, and related effective date, is consistent with the SAS No. 

112, Communicating Internal Control Related Matters Identified in an Audit. 5

 The term “remote” is defined in footnote 3. 

6

 A misstatement is inconsequential if a reasonable person would conclude, after considering the possibility of 

further undetected misstatements, that the misstatement, either individually or when aggregated with other 

misstatements, would clearly be immaterial to the financial statements. If a reasonable person would not reach such 

a conclusion regarding a particular misstatement, that misstatement is more than inconsequential. (SAS No. 112) 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 7
of financial statements will be performed by the OIG of the executive department or 

agency or by an IPA as determined by the OIG. 

4.2 For the executive branch entities subject to the ATDA and Government Corporation 

Control Act, the audits of financial statements will also be performed by the OIG of the 

executive entity or by an IPA as determined by the OIG. If the entity does not have an OIG, the 

financial statement audit will be performed by an IPA as determined by management. 

4.3 The CFO Act of 1990, as amended, provides that, in lieu of an audit otherwise required, 

the Comptroller General of the United States may, at his or her discretion and following 

consultation with the OIG, perform the audit of the CFO Act executive departments and 

agencies and Government Corporation Control Act and ATDA entities. 

SECTION 5: COMMUNICATION 

5.1 There will be open, timely, and frequent communication between the entity’s 

management, including the CFO, and the OIG (and the audit firm, if the audit is contracted) 

throughout the audit process. The purpose of this communication is to ensure that all parties are 

kept up-to-date on the progress and results of the audit and to alleviate unexpected issues that 

may occur at the end of the audit. Matters that should be communicated include, but are not 

limited to, the following: 

• The audit timetable and changes thereto, 

• Issues or problems arising in the conduct of the audit, including the inability or 

difficulty in gaining access to records or inadequate cooperation of entity 

personnel, and 

• Potential audit findings as they are developed, including indications of material 

misstatements or unsupported amounts in the financial statements, significant 

deficiencies and material weaknesses in internal control, and non-compliances 

with laws and regulations. 

5.2 Auditors must bring misstatements to management’s attention, present proposed 

adjustments to management, and require that management’s representation letter address the 

unadjusted misstatements. (See Paragraph 8.7 for a discussion of a summary of unadjusted 

misstatements to be attached to management’s representation letter and see Paragraph 8.4 for 

management’s materiality threshold used for reporting items in the management representation 

letter). Auditors are encouraged to use GAO/PCIE FAM Section 540, Evaluate Misstatements, 

and subsequent revisions, for reviewing misstatements with management. 

Misstatements in Previously-Issued Financial Statements

5.3 The nature or amount of known or likely material misstatement(s) in previously-issued 

audited financial statement(s) may lead the auditor to believe that the auditor’s report would or 

could reasonably have been affected if the auditor had known of the misstatement(s) when the 

auditor issued the auditor’s report. When this condition exists, the auditor will advise 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 8
management to communicate the following information to those charged with governance,7

oversight bodies, funding agencies, and others who are relying or are likely to rely on the 

financial statement(s): 

• The nature and cause(s) of the known or likely material misstatement(s), 

• The amount(s) of known or likely material misstatement(s) and the related effect(s) 

on the previously-issued financial statement(s) (e.g., disclosure of the specific 

financial statement(s) and line item(s) affected). If this information is unknown, 

then the disclosure includes information that is known and a statement that 

management cannot determine the amount(s) and the related effect(s) on the 

previously-issued financial statement(s) without further investigation, and 

• A notice that (1) a previously-issued financial statement(s) will or may be restated 

and, therefore, (2) our auditors have advised us that the related auditor’s report is 

no longer reliable. 

Management’s communication and disclosure should be in writing and made to the (1) 

Congress, OMB, Treasury, and GAO; (2) public on the Internet pages where the agency’s 

previously-issued financial statements that were affected by the material misstatement(s) or 

likely material misstatement(s) are published; and (3) OMB in the agency’s next quarterly 

financial statements and in subsequent quarterly financial statements until the specific 

amount(s) of the material misstatement(s) and the related effect(s) of such on the previouslyissued financial statement(s) are known and reported. 

5.4 The auditor will evaluate the adequacy of management’s disclosure about the known or 

likely material misstatement(s) to report users, including those charged with governance, 

oversight bodies, and funding agencies. When performing this evaluation, the auditor will 

consider whether (1) management acted timely to determine the financial statement effects of 

the likely material misstatement(s); (2) management acted timely to communicate with 

appropriate parties; and (3) management disclosed the nature and extent of the known or likely 

material misstatement(s) on Internet pages where the agency’s previously-issued financial 

statements are published. 

5.5 The auditor will notify those charged with governance if the auditor believes that 

management is unduly delaying its determination of the effect(s) of the misstatement(s) on a 

previously-issued financial statement(s). 

5.6 The auditor will evaluate the timeliness and appropriateness of management’s decision 

whether to issue restated financial statement(s). Management may separately issue the restated 

financial statement(s) or may present the restated financial statement(s) on a comparative basis 

with those of a subsequent period. Ordinarily, the auditor would expect management to issue 

restated financial statement(s) as soon as practicable. However, it may not be necessary for 

 

7

 Governance is defined by Government Auditing Standards as those responsible for overseeing the entity’s strategic 

direction and the fulfillment of its obligations related to the entity’s accountability. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 9
management to separately issue the restated financial statement(s) and the auditor’s report when 

issuance of the subsequent period audited financial statements is imminent.8

Misstatements Affecting Previously-Issued Financial Statements

5.7 If the auditor becomes aware of a material misstatement(s) or likely misstatement(s) 

affecting a previously-issued financial statement(s), then the auditor will advise the agency’s 

management to determine the specific amount(s) of the material misstatement(s) or likely 

material misstatement(s) and the related effect(s) of such on the previously-issued financial 

statement(s) as soon as reasonably possible. 

5.8 If the specific amount(s) of the material misstatement(s) and the related effect(s) of such 

on a previously issued financial statement(s) are known and the issuance of the subsequent 

period audited financial statements is not imminent, then the auditor will advise the agency’s 

management promptly to: 

• Issue revised fiscal year financial statements before issuing the current fiscal year’s 

financial statements; 

• Communicate the issuance of the revised financial statements to those charged 

with governance, oversight bodies, funding agencies, and others who are relying or 

are likely to rely on the financial statement(s). This includes communication (1) in 

writing to the Congress, OMB, Treasury, and GAO and (2) to the public on the 

Internet pages where the agency’s previously issued financial statements that were 

affected by the material misstatement(s) are published; and 

• Disclose the following information, at a minimum, in the agency’s restatement 

note: (1) the nature and cause(s) of the misstatement(s) that led to the need for 

restatement, and (2) the specific amount(s) of the material misstatement(s) and the 

related effect(s) on the previously-issued financial statement(s) (e.g., year(s) being 

restated, specific financial statement(s) affected and line items restated, actions the 

agency’s management took after discovering the misstatement), and the impact on 

the financial statements as a whole (e.g., change in overall net position, change in 

the audit opinion). 

5.9 If the specific amount(s) of the material misstatement(s) and the related effect(s) of such 

on a previously-issued financial statement(s) are known and issuance of the subsequent period 

audited financial statements is imminent, then the auditor will disclose restatements in the 

auditor’s report as listed in Paragraph 7.8 and advise agency’s management to: 

• Issue restated financial statement(s) as part of the current year’s comparative 

financial statements; 

 

8

 For purposes of this guidance, imminent means within 90 days of determining the effect of the misstatement(s) on 

the previously issued financial statements. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 10
• Communicate the restatement to those charged with governance, oversight bodies, 

funding agencies, and others who are relying or are likely to rely on the financial 

statement(s). This includes communication (a) in writing to the Congress, OMB, 

Treasury, and GAO and (b) to the public on the Internet pages where the agency’s 

previously-issued financial statements that were affected by the material 

misstatement(s) are published; and 

• Disclose the following information, at a minimum, in the agency’s restatement 

note: (1) the nature and cause(s) of the misstatement(s) that led to the need for 

restatement and (2) the specific amount(s) of the material misstatement(s) and the 

related effect(s) on the previously-issued financial statement(s) (e.g., year(s) being 

restated, specific financial statement(s) affected and line items restated, actions the 

agency’s management took after discovering the misstatement), and the impact on 

the financial statements as a whole (e.g., change in overall net position, change in 

the audit opinion). 

5.10 If the specific amount(s) of the misstatement(s) and the related effect(s) of such on a 

previously-issued financial statement(s) remain unknown when the current year’s financial 

statements are issued, then the auditor will follow Paragraph 7.7 when issuing the auditor’s 

report and advise the agency’s management as required in Paragraph 5.2. 

5.11 The auditor will notify those charged with governance, oversight bodies, and funding 

agencies when management (1) does not take the necessary steps to promptly inform report users 

of the situation or (2) does not restate with appropriate timeliness the financial statements in 

circumstances when the auditor believes they need to be restated. The auditor will inform these 

parties that the auditor will take steps to prevent future reliance on the auditor’s report. The steps 

taken will depend on the facts and circumstances, including legal considerations. This includes 

communication in writing to the Congress, OMB, Treasury, and GAO as well as any other users 

known to rely on the previously-issued financial statement(s). 

SECTION 6: SCOPE OF THE AUDIT 

6.1 Financial statements will be audited in accordance with U.S. Government Auditing 

Standards and the provisions of this Bulletin. 

6.2 The auditor will determine whether the Basic Statements and related notes 

present fairly, in all material respects, the assets, liabilities, and net position; net costs; 

changes in net position; budgetary resources; and, if applicable, custodial activity and 

social insurance in conformity with the accounting principles generally accepted in the 

United States. 

6.3 If consolidating statements are presented, the auditor will consider the consolidating 

statements supplemental information and report in accordance with Section 7, unless the 

auditor's objective is to express an opinion on the consolidating statements. 

6.4 If the auditor is unable to determine whether the Basic Statements are fairly presented 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 11
because, for example, of the auditor's inability to obtain sufficient competent evidential matter 

due to inadequate accounting records, the auditor will, to the extent practical, obtain sufficient 

evidence about closing balances to enable the auditor to opine on the subsequent year's financial 

statements. 

6.5 When auditing allocation transfers9

 from a Federal entity (referred to as the parent) to 

another agency or department (referred to as the child), the parent’s auditor (whether the Office 

of Inspector General or a contractor) is responsible for ensuring that the child’s information 

receives the audit coverage that, in the auditor’s professional judgment, is required as part of the 

parent’s annual financial statement audit (i.e., the amount should be subject to the same annual 

financial statement auditing procedures and materiality considerations as all other funding 

sources). As such, the two agencies and/or departments may need to coordinate to ensure that 

the parent auditor’s needs, as they relate to the allocation transfer, are met. Such coordination 

should take place during the early planning phase of the annual financial statement audit. 

6.6 The auditor will perform the procedures described in AU § 558, Required 

Supplementary Information, for the following: 

• Required Supplementary Information (i.e., Management's Discussion and Analysis, 

Deferred Maintenance, Stewardship Land, and Heritage Assets) 

• Required Supplementary Stewardship Information (i.e., Stewardship investments: 

non-Federal physical property (such as highways), human capital (expenditures for 

training and education), and research and development). 

6.7 The auditor will assess whether the other accompanying information, or its manner of 

presentation, is materially consistent with the information in the Basic Statements. 

6.8 With respect to the internal control objectives (See Paragraph 2.8, definition of internal 

control.) relating to the Basic Statements, the auditor will obtain an understanding of the 

components of internal control (See AU § 319.) and assess the level of control risk relevant to 

the assertions embodied in the classes of transactions, account balances, and disclosure 

components of the financial statements. Such controls include relevant information technology 

(IT) general and application controls and controls relating to intra-entity and intra-governmental 

transactions and balances. For those internal controls that have been properly designed and 

placed in operation, the auditor will perform sufficient tests to support a low level of assessed 

control risk. Those internal controls that have not been properly designed or placed in operation 

and those internal controls that are found to be ineffective will be reported in accordance with 

Section 7 of this Bulletin. 

6.9 In obtaining an understanding of the components of internal control, particularly the risk 

 

9

 Effective for FY 2007, the A-136 changed the financial reporting requirements for transferring, or “allocating,” 

budget authority from one entity to another within or to another Federal department (i.e., parent/child reporting). 

According to the A-136, the department (i.e., parent) that transfers budget authority to another Federal entity (i.e., 

child) must report all budgetary and proprietary activity in its financial statements, whether material to the parent or 

not. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 12
assessment component, and assessing control risk, the auditor will obtain an understanding of the 

process by which the agency identifies and evaluates weaknesses required to be reported under 

FMFIA and related agency implementing procedures. 

6.10 The auditor will compare material weaknesses disclosed during the audit with those 

material weaknesses reported in the agency's FMFIA report that relate to the financial statements 

of the entity under audit and document material weaknesses disclosed by audit that were not 

reported in the agency’s FMFIA report. The auditor should consider whether the failure to detect 

and report material weaknesses constitutes a significant deficiency or material weakness in the 

entity’s internal control. 

6.11 With respect to the internal control objective relating to performance measures, the 

auditor will obtain an understanding of the components of internal control relating to the 

existence and completeness assertions relevant to the performance measures included in the 

MD&A. Those internal controls that have not been properly designed and placed in operation 

will be reported in accordance with Section 7 of this Bulletin. The objective of gaining an 

understanding of internal control in this subparagraph is to report deficiencies in the design of 

internal control, rather than to plan the financial statement audit or to audit the performance 

measures and results. As a result, the auditor’s understanding of internal controls in this area is 

more limited in nature than the auditor’s understanding of internal controls over financial 

reporting. Management has a responsibility for assessing the completeness and reliability of the 

performance data. (See Section 230 of OMB Circular No. A-11, Preparation, Submission, and 

Execution of the Budget for additional information on management’s responsibility.) Effective 

starting in fiscal year 2008, this requirement will be excluded from this section of the Bulletin. 

6.12 With respect to compliance with applicable laws and regulations, the auditor will 

perform tests of compliance with laws and regulations, including laws governing the use of 

budget authority, laws, regulations, and government-wide policies identified by OMB in 

Appendix E of this Bulletin, or any other laws and regulations that could have a direct and 

material effect on the Basic Statements. 

6.13 The auditor will perform tests of the entity’s compliance with FFMIA, section 803(a) 

requirements. This provision only applies to entities listed in Appendix A. Agencies subject to 

the ATDA and Government Corporation Control Act are not subject to the requirements of 

FFMIA, with the exception of government corporations that are also components of one of the 

24 major CFO Act agencies. Those government corporations are subject to FFMIA similar to 

all other components of the CFO Act agencies, including components listed in Appendix B. 

The government corporations, however, are not required to report separately on compliance 

with FFMIA in its management reports. 

6.14 The auditor will obtain written representation from management as part of an audit 

conducted in accordance with this Bulletin. (See AU § 333, Management Representations.) In 

addition to the standard representations included in AU § 333, additional representations are 

required that are unique to the Federal Government. The additional representations are 

provided in Section 8 of this Bulletin. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 13
Service Organizations

6.15 A service organization is an entity or component of an entity that provides services to a 

user organization in which those services are part of the user organization’s information system 

(e.g., processing of transactions). A user organization is an entity or component of an entity 

whose financial statements are being audited and has engaged a service organization. 

6.16 With respect to obtaining assurance on the internal control of a service organization, the 

auditor of the user organization will utilize, as necessary, the service organization’s auditors’ 

report10 on the services provided to the user organization. Service organizations must either 

provide its user organizations with an audit report on whether (1) internal controls were 

designed properly to achieve specified objectives and placed into operation as of a specified 

date and (2) the controls that were tested were operating effectively to provide reasonable 

assurance that the related control objectives were met during the period specified or allow user 

auditors to perform appropriate tests of controls at the service organization. (See AU § 324, 

Service Organizations.)

6.17 If the service organization uses another service organization (subservicer), the service 

organization is responsible for requesting or obtaining appropriate audit coverage.11 

6.18 Such audit reports should be submitted to user organizations within a reasonable time 

but no later than September 30 to allow the auditor of the user organization to use the audit 

report during the audit of the user organization’s financial statements. 

SECTION 7: AUDIT REPORT 

7.1 An audit report,12 or separate audit reports, on the Basic Statements, internal control, 

and compliance with applicable laws and regulations will be prepared at the completion of the 

audit. The audit report(s) will be submitted to the agency head in sufficient time to enable the 

agency head to meet the due date for submitting the audited financial statement which is no later 

than 45 days after the fiscal year end. The audit results will be discussed with management as 

soon as practical but, in any case, prior to issuance of the audit report. 

7.2 The audit report(s) will state that the audit was performed in accordance with U.S. 

Government Auditing Standards and the provisions of this Bulletin. 

Audit Report

7.3 The audit report(s) will include either an opinion as to whether the reporting entity's 

Basic Statements are fairly presented in all material respects in conformity with the accounting 

principles generally accepted in the United States of America, or a disclaimer of opinion. (See 

AU § 508.) 

 

10 These reports are also referred as SAS 70 reports. 

11 For additional guidance in this area, please see the AICPA audit guide for “Service Organizations: Applying SAS 

No. 70, as amended.” 

12 An illustrative auditor’s report can be found in the GAO/PCIE FAM Section 500, Reporting, and subsequent 

revisions. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 14
7.4 If the Basic Statements are materially affected by a departure from generally accepted 

accounting principles, the auditor will issue a qualified or adverse opinion and include an 

explanatory paragraph that describes the material departure(s) from those standards and, if 

practical, the effects of the departure(s) on assets, liabilities, and net position; net costs; changes 

in net position; budgetary resources; and, if applicable, custodial activity and social insurance. If 

the effects of the departure(s) are disclosed in a note to the Basic Statements, the explanatory 

paragraph may be shortened by referring to it. 

7.5 If the auditor disclaims an opinion, the report will describe why the auditor was unable to 

conduct the audit in accordance with U.S. Government Auditing Standards and this Bulletin. If 

material weaknesses and significant deficiencies prevented the conduct of the audit in 

accordance with U.S. Government Auditing Standards and this Bulletin, such conditions will be 

included in the report on internal control along with recommendations for correcting the 

condition(s). 

7.6 When there is a change in accounting principles, for example, changes to comply with 

SFFASs, the auditors’ report on the Basic Statements will include an explanatory paragraph 

identifying the nature of the change and referring the reader to the note to the Basic Statements 

that discusses the change in detail. 

Reporting on Restatement of Previously-Issued Financial Statements

7.7 If at the time of issuance of the auditor’s report a material misstatement(s) or likely 

material misstatement(s) has been identified in any of the previously-issued financial statements 

and the specific amount(s) of the misstatement(s) and the related effect(s) of such are unknown, 

then the auditor will update the auditor’s report on the previously-issued financial statement(s) as 

appropriate. Furthermore, the auditor’s report will disclose, at a minimum, the following: 

• A statement disclosing that a material misstatement(s) or potential material 

misstatement(s) affects a previously-issued financial statement(s) but the specific 

amount(s) of the misstatement(s) and the related effect(s) of such are unknown; 

• A reference to the note(s) to the financial statements that discusses the restatement 

or potential restatement; 

• A description of the following, if not already provided in the agency’s note(s) to 

the financial statements: (1) the nature and cause(s) of the misstatement(s) or 

likely misstatement(s), and (2) an estimate of the magnitude of the misstatement(s) 

or potential misstatement(s) and the related effect(s) of such on a previously-issued 

financial statement(s) (e.g., disclosure of the specific financial statement(s) and 

line items affected) that are known and a statement that the specific amount(s) and 

the related effect(s) of such cannot be determined without further investigation; 

and 

• A statement disclosing that a restatement(s) to a previously-issued financial 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 15
statement(s) will or may occur. 

Reporting on Restated Financial Statements

7.8 When management restates a previously-issued financial statement(s),13 the auditor will 

perform audit procedures sufficient to reissue or update the auditor’s report on the restated 

financial statement(s). The auditor will fulfill these responsibilities whether the restated 

financial statement(s) are separately issued or presented on a comparative basis with those of a 

subsequent period. The auditor will include the following information in an explanatory 

paragraph in the reissued or updated auditor’s report on the restated financial statement(s): 

• A statement disclosing that a previously-issued financial statement(s) has been 

restated; 

• A statement that the previously-issued financial statement(s) was materially 

misstated and that the previously-issued auditor’s report (including report date) is 

withdrawn and replaced by the auditor’s report on the restated financial 

statement(s); 

• A reference to the note(s) to the restated financial statement(s) that discusses the 

restatement; 

• A description of the following if not already provided in the note(s) to the financial 

statement(s): (1) the nature and cause(s) of the misstatement(s) that led to the need 

for restatement and (2) the specific amount(s) of the material misstatement(s) and 

the related effect(s) on the previously-issued financial statement(s) (e.g., year(s) 

being restated and the specific financial statement(s) affected and line items 

restated) and the impact on the financial statements as a whole (e.g., change in 

overall net position, change in the audit opinion); and 

• If applicable, a reference to the report on internal control containing a discussion 

of any significant internal control deficiency identified by the auditor as having 

failed to prevent or detect the misstatement and what action management has taken 

to address the deficiency. 

MD&A, RSSI, RSI, Other Accompanying Information, and Highlights

7.9 When reporting on MD&A, required supplementary stewardship information, and 

required supplementary information, the auditor will follow AU § 558, Required Supplementary 

Information. 

7.10 When reporting on other accompanying information, the auditor will follow AU § 551. 

7.11 When reporting on a “Highlights” or similar document, the auditor will follow AU § 552, 

 

13 SFFAS No. 21, Reporting Corrections of Errors and Changes in Accounting Principles, instructs agencies on 

when to issue a restatement. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 16
Reporting on Condensed Financial Statements and Selected Financial Data. 

Report on Internal Control

7.12 A report on internal control will at a minimum,14 state that, with respect to internal 

control over financial reporting, the auditor obtained an understanding of the design 

effectiveness of internal controls, determined whether they have been placed in operation, 

assessed control risk, and performed tests of the reporting entity's internal controls. 

7.13 The report shall state that, with respect to the internal control objective relating to the 

performance measures included in the MD&A, the auditor obtained an understanding of the 

design of internal controls relating to the existence and completeness assertions and determined 

whether they have been placed in operation. Effective starting in fiscal year 2008, this 

requirement will be excluded for the report on internal control. 

7.14 The report will state that either the objective (1) was not to provide an opinion on internal 

control and therefore does not express such an opinion or (2) was to provide an opinion on 

internal control15 and reference the separate audit report, if one will be issued separately instead 

of in conjunction with the audit of the financial statements. 

7.15 The report will describe significant deficiencies and material weaknesses identified 

during the audit. 

7.16 The report will identify those material weaknesses disclosed by the audit that were not 

reported as material weaknesses in the reporting entity’s FMFIA report. 

Report on Compliance with Applicable Laws and Regulations

7.17 A report on the reporting entity's compliance with applicable laws, regulations, and 

government-wide policy requirements include noncompliance with laws and regulations 

disclosed by audit, except for those instances of noncompliance that, in the auditor's judgment, 

are clearly inconsequential. In meeting this requirement, the auditor will list those laws and 

regulations that tests disclosed reportable instances of noncompliance. 

7.18 With respect to laws and regulations tested for which the audit disclosed no reportable 

instances of noncompliance, the report will state that the audit disclosed no reportable instances 

of noncompliance with these laws and regulations. A listing of these laws and regulations is not 

required. 

7.19 The report will state either the objective (1) was not to provide an opinion on compliance 

with applicable laws and regulations and therefore does not express such an opinion, or (2) was 

 

14 An opinion on internal control over financial reporting can be rendered if desired or mandated by statute. An 

opinion can be issued either in accordance with the AICPA Statements of Standards for Attestation Engagements, 

AT 501, Codification of Statements on Auditing Standards, or in accordance with Auditing Standard No. 5, An Audit 

of Internal Control Over Financial Reporting That is Integrated with An Audit of Financial Statements, promulgated 

by the Public Company Accounting Oversight Board. 

15 Ibid. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 17
to provide an opinion on compliance and reference the separate audit report. 

Compliance with FFMIA 

7.20 Section 803(b) of FFMIA requires the auditor to report whether the reporting entity’s 

financial management systems substantially comply16 with FFMIA section 803(a) 

requirements.17 Auditors are reminded that “significant deficiencies” found under FISMA must 

also be reported as material weaknesses under FMFIA and as a lack of substantial compliance 

under FFMIA if related to financial management systems. (See Paragraph 2.5 of this Bulletin.) 

To meet the requirement, for each of the three FFMIA section 803(a) requirements, the audit 

report will reflect instances in which the reporting entity’s systems did not substantially comply 

with the requirement, or state that the audit disclosed no instances in which the reporting entity’s 

systems did not substantially comply. If the audit disclosed no instances of substantial 

noncompliance with any of the three FFMIA section 803(a) requirements, a single statement to 

this effect is sufficient. Where tests disclosed that the reporting entity’s systems did not 

substantially comply with one or more of the three requirements, the auditors’ report on 

compliance, (or an accompanying schedule that is referenced in the compliance report) should 

group findings together based on the requirement they relate to (i.e., Federal financial 

management systems requirements, applicable Federal accounting standards, or the USSGL), as 

required by FFMIA: 

• Identify the entity or organization responsible for the financial management systems that 

were found not to comply with the requirements. 

• Include all facts pertaining to the noncompliance, including the nature and extent of the 

noncompliance, the primary reason or cause of the noncompliance, and any relevant 

comments from reporting entity management or employees responsible for the 

noncompliance. 

• Provide recommended remedial actions. 

 

16 Additional guidance on compliance with Section 803(b) of FFMIA can be found on the OMB website, 

http://www.whitehouse.gov/omb/financial/ffmia_implementation_guidance.pdf. All of the financial management 

system requirements referenced in Section 7 of OMB Circular No. A-127, Financial Management Systems are 

important, but not essential to substantially comply with the three FFMIA Section 803(a) requirements. The Act is 

intended to ensure that agencies use financial management systems that provide reliable, timely, and consistent 

information. Agencies that can: 1) prepare financial statements and other required financial budget reports using 

information generated by the financial management system(s); 2) provide reliable and timely financial information 

for managing current operations; 3) account for their assets reliably, so that they can be properly protected from loss, 

misappropriation, or destruction; and do all three in a way that is consistent with Federal GAAP and the USSGL are 

substantially compliant with FFMIA. 

17 Agencies subject to the ATDA and Government Corporation Control Act are not subject to the requirements of 

FFMIA, with the exception of government corporations that are also components of one of the 24 major CFO Act 

agencies. Those specific government corporations are subject to FFMIA similar to all other components of the 

CFO Act agencies. The government corporations; however, are not required to report separately on compliance 

with FFMIA in their management reports, if applicable. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 18
Compliance with OMB Circular No. A-123, Appendix A 

7.21 The OMB Circular No. A-123, Management’s Responsibility for Internal Control (A123) implements the requirements of FMFIA. The A-123 contains Appendix A18 which 

provides an assessment process that management should implement in order to properly evaluate 

and improve internal controls over financial reporting. The assessment process should provide 

management with the information needed to properly support a separate assertion as to the 

effectiveness of the internal controls over financial reporting, as a subset of the overall FMFIA 

report. 

7.22 Auditors may elect, but are not required to report separately on agencies’ compliance 

with the A-123, Appendix A. If auditors report separately on agencies’ compliance with the A123, Appendix A, auditors should consider whether: 

• Management established an organizational structure to effectively implement, direct, and 

oversee the assessment process. The A-123 suggests a Senior Management Council and 

a Senior Assessment Team or equivalent structures. The oversight of the assessment 

process may also be incorporated into existing offices or functions within the 

organization that currently monitor the effectiveness of the organization’s internal 

control. 

• Management evaluated controls at the entity level and considered the components of 

internal control as defined in the A-123 and GAO’s Standards for Internal Control in the 

Federal Government (www.gao.gov). 

• Management established an approach to determine the scope of the assessment. The 

scope of the assessment includes identifying significant financial reports and key 

processes/controls/transactions. Management has discretion in determining both the 

breadth and depth of the scope of financial reporting. The breadth of financial reporting 

encompasses the specific financial reports included within the scope of the assessment 

and should include at least the annual and quarterly entity-wide financial reports. The 

depth of financial reporting are the boundaries of where the financial reporting process 

meets the operating processes on an entity-wide basis as well as the extent of coverage at 

the component unit and multiple locations. 

• Management evaluated and documented the processes and controls as required by the A123, Appendix A. 

• Management documented its decisions on determining the scope, materiality, testing 

methodology, and other significant decisions related to this assessment. Management 

also documented its decisions for what, when, where and how to test the controls, and 

documented the tests and results. Management can and should use discretion when 

developing the testing approach that is required to support its statement of assurance. 

The management assurance required by the agency head should be directly related to the 

 

18 The requirements of Appendix A are applicable to the 24 CFO Act agencies. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 19
amount of test work performed, as determined by scope, risk, and materiality 

determinations made by management. 

• Management used the results of its testing, and considered information gathered during 

the financial statement audit, to support its conclusion whether internal controls over 

financial reporting were properly designed and operating effectively. 

• Management’s assurance statement describes any scope limitation, and is consistent with 

the evidence gathered during the testing process, including information gathered during 

the financial statement audit. 

• Management has plans in place and a process to continue assessing controls in 

accordance with the A-123, Appendix A. 

• Management has a process in place to monitor implementation of corrective actions to 

resolve deficiencies in internal controls, including material weaknesses. 

Auditors should understand that Management has discretion in planning for and implementing 

their A-123, Appendix A program. Consequently, a determination of non-compliance should be 

made if management’s A-123 implementation was poorly designed and executed. 

7.23 Auditors should also consider that certain agencies elected to complete the A-123, 

Appendix A assessment over multiple years, which is also permissible under the A-123. For 

those agencies the following was required: 

• Submission of a plan that: (i) states why the agency requires more than one year to 

execute its plan; (ii) provides for identifying, testing, and assessing a significant 

percentage of its key business processes and controls in each year; (iii) demonstrates how 

the agency will meet the A-123, Appendix A requirements by September 2008; and (iv) 

is reviewed and accepted by OMB; 

• Implementation of their A-123 assessment process in substantial accordance with the 

OMB-approved plan; and 

• Submission of an assurance statement by the agency head that accurately reflects the 

amount of work completed (e.g., agencies that are implementing a multi-year plan will 

need to identify a scope limitation) and the results of the assessments performed. 

 

Status/Comments/Distribution

7.24 When preparing the audit report(s), the auditor will report the status of known but 

uncorrected material findings and recommendations from prior audits that affect the current 

audit objectives. 

7.25 The auditor should obtain and report the views of the reporting entity’s responsible 

officials concerning the auditor’s findings and recommendations included in the audit report, 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 20
including corrective actions taken or planned and comments on the status of corrective actions 

taken on prior findings. These comments will be included in the report on internal control or 

report on compliance, as applicable. If corrective actions are not necessary, an explanatory 

statement will be included in the audit report. (See Chapter 5 of the U.S. Government Auditing 

Standards for further guidance.) 

7.26 Copies of the audit report(s) will be distributed to the head of the executive department 

or agency and subsequently included in the department’s or agency’s Performance and 

Accountability Report (PAR), Agency Financial Report (if applicable),19 or the corporation’s 

Management Report. 

Subsequent Discovery of Facts

7.27 With respect to the subsequent discovery of facts existing at the date of the auditors’ 

report, the auditor will follow the steps in AU § 561, Subsequent Discovery of Facts Existing at 

the Date of the Auditor’s Report. If the auditor concludes that the previously-issued audit report 

is not reliable and action should be taken to prevent future reliance on the report, the auditor 

will communicate such facts to the audited entity. The auditor will also make the appropriate 

disclosure of the facts to persons who may be relying on the auditor’s reports such as legislative 

or regulatory oversight bodies, federal inspector(s) general, funding entities, and other oversight 

bodies if the audited entity fails to do so in a timely manner. 

7.28 Revised financial statements and the auditors’ report(s) should be issued as soon as 

practical after the effect on the previously issued financial statement and auditor’s report can be 

determined. If the audited entity’s subsequent-period financial statements and the related 

auditors’ report will be issued imminently, the appropriate disclosures can be made in the 

subsequent-period statements instead of reissuing the earlier statements. For this purpose, 

“imminent” is defined as within 90 calendar days of the subsequent-period financial statements 

planned issue date. (See Paragraphs 5.3 through 5.11 and 7.8 for further discussions.) 

7.29 The A-136 provides guidance on how the audited entity’s management should correct 

errors in the financial statements and the specific information to be included in the financial 

statement notes when restatement is required. 

SECTION 8: MANAGEMENT REPRESENTATION LETTER 

8.1 In accordance with AU § 333, Management Representations, the auditor will obtain 

written representations from management for all financial statements for the periods covered by 

the auditors’ report(s). The auditor will also obtain a summary of unadjusted misstatements to 

accompany the management representation letter. In accordance with the A-136, Section V, the 

management representation letter and accompanying summary of unadjusted misstatements are 

 

19 OMB has established a pilot for FY 2007 in which agencies may choose to produce an alternative to the 

consolidated PAR. The pilot has 3 required parts: 1) an Agency Financial Report; an Annual Performance Report; 

and a “Highlights” document. See Section II of the A-136 for further details. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 21
required for the audits of entity financial statements and the special-purpose financial statements 

used to compile the Financial Report of the United States Government (FR). 

8.2 The management representation letter will be on the audited entity’s letterhead. The 

representations should be dated in accordance with AU § 333. To ensure the management 

representation letter is prepared timely, a draft letter should be provided to and discussed with 

management as early as possible in the audit and updated for circumstances found throughout 

the audit. 

8.3 The management representation letter will be obtained from the highest levels of the 

audited entity. The officials who sign the management representation letter should be those 

who, in the auditor’s view, are responsible for and knowledgeable, directly or through others, 

about the matters in the management representation letter. These officials generally should be 

the head of the entity, the CFO, and any others deemed responsible for matters presented in the 

management representation letter. 

8.4 The management representation letter will specify management’s materiality threshold, 

used for reporting items in the management representation letter. Items below this threshold 

would not be considered exceptions or reported as such in the representation letter.20

8.5 The representations to be included in the management representation letter are part of 

the evidential matter to be considered by the auditor in its audit of the entity’s financial 

statements. The AU § 333 discusses specific representations that should be obtained from 

management. The representations obtained will depend on the circumstances of the engagement 

and the nature and basis of presentation of the financial statements. In addition to the 

representations given in AU § 333, the auditor generally should consider the need to obtain 

representations on other matters based on the circumstances of the audited entity. The auditor 

should refer to the guidance detailed in the GAO/PCIE FAM Section 1001, Management 

Representations, and subsequent revisions. The sample management representation letter 

presented in the GAO/PCIE FAM Section 1001A, Example Management Representation Letter, 

and subsequent revisions should be used as guidance and representations should be deleted if 

inapplicable or customized to the situation of the entity being audited. 

8.6 In addition to the representations discussed in the above paragraph, management is 

required to include a representation that addresses the consistency of budgetary data reported on 

the Statement of Budgetary Resources and the budgetary data submitted through FACTS II to 

prepare the year-end SF 133s, Reports on Budget Execution and Budgetary Resources. 

Management will use the following sample representation: 

The information presented on the Department’s Statement of Budgetary Resources is 

reconcilable to the information submitted on the Department’s year-end Reports on 

Budget Execution and Budgetary Resources (SF 133s). This information will be used as 

 

20 Management and the auditor should reach an understanding on a materiality level. For guidelines on establishing 

the materiality level for the management representation letter, see the GAO/PCIE FAM Section 1001, Management 

Representations, and subsequent revisions. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 22
input for the fiscal year 20xx actual column of the Program and Financing Schedules 

reported in the fiscal year 20xz Budget of the U.S. Government. Such information is 

supported by the related financial records and related data. 

8.7 A summary of unadjusted misstatements will be attached to the entity’s management 

representation letter. Overall guidance on evaluating misstatements is provided in AU § 312, 

Evaluating Audit Findings. Agencies will use the schedule submitted with the management 

representation letter for the entity’s audit and include all the information necessary to prepare 

the government-wide summary of unadjusted misstatements (i.e., include an additional column 

identifying the effect of the current year’s uncorrected misstatements on the Closing Package 

line items). Agencies are encouraged to use the format of the schedule of unadjusted 

misstatements presented in the GAO/PCIE FAM Section 595D, Example Summary of 

Unadjusted Misstatements, and subsequent revisions and: 

• Identify the effect of the current year’s unadjusted misstatements. 

• Identify the carry-forward effect of the prior year’s unadjusted misstatements. 

• Distinguish between those affecting intragovernmental accounts and those affecting 

accounts with the public. 

• Be prepared for each affected department-wide financial statement. 

8.8 The management representation letter will be consistent with the auditors’ report(s). If a 

representation is contradicted by other audit evidence, the auditor will investigate the 

circumstances and consider the reliability of the representation. Based on the circumstances, the 

auditor will then consider whether it is appropriate to rely on other management representations. 

8.9 The auditor will also obtain additional written representations, and a summary of 

unadjusted misstatements, for the special-purpose financial statements used to compile the FR. 

(See Section 13 and Appendix F, Illustrative Management Representation Letter for SpecialPurpose Financial Statements of this Bulletin for further guidance.) 

SECTION 9: LEGAL REPRESENTATION LETTERS AND MANAGEMENT'S 

SCHEDULES 

9.1 In accordance with AU § 337, Inquiry of a Client’s Lawyer Concerning Litigation, 

Claims, and Assessments, the auditor will request entity management to send a letter of inquiry 

to those lawyers with whom management consulted concerning litigation, claims, and 

assessments.21 (See the GAO/PCIE FAM Section 1002B, Example Legal Letter Request, and 

subsequent revisions, for an illustrative letter of inquiry from entity management to legal 

counsel.) Management should document in a schedule how the information contained in the 

legal counsel’s response(s) was considered in preparing the financial statements. In accordance 

with the A-136, Section V, legal representation letters and management’s schedules are required 

 

21 Management and the auditor should agree on a materiality level to use in the letter of inquiry. For guidelines on 

setting the materiality level for the legal letter see the GAO/PCIE FAM Sections 1002, Inquiries of Legal Counsel, 

and subsequent revisions. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 23
for the audits of entity financial statements and the special-purpose financial statements used to 

compile the FR. 

9.2 Legal counsels will consider the guidance contained in the American Bar Association’s 

Statement of Policy Regarding Lawyer’s Responses to Auditors’ Request for Information

(December 1975) in preparing their responses. (Refer to the Department of Justice website for 

guidance on how to prepare a legal letter, www.usdoj.gov/civil/forms/forms.htm, and see the 

GAO/PCIE FAM Section 1002C, Example Legal Representation Letter, and subsequent 

revisions, for an illustrative response letter from legal counsel to the auditor.) 

9.3 The auditor’s request to entity management to send a letter of inquiry to entity counsel 

should follow AU § 337, and its interpretations (AU § 9337). Management’s schedule should be 

provided as soon as practical after the legal counsel’s response is provided to the auditor. 

9.4 To satisfy management’s responsibilities under SFFAS No. 5, Accounting for Liabilities 

of the Federal Government, as amended, related to contingent liabilities arising from litigation, 

and to facilitate the audit thereof, the CFO will prepare a schedule to document how the 

information contained in the legal counsel’s response was considered in preparing the financial 

statements. (See the GAO/PCIE FAM Section 1002D, Example Management Summary 

Schedule, and subsequent revisions, for the format to be used for management’s schedule.) 

9.5 The timing of legal letter requests, responses, and related management’s schedules will 

be coordinated between entity legal counsel, entity management, and the auditor. All due dates 

will be in accordance with the due dates established in the A-136, Section V and Attachment B. 

9.6 Updated legal responses and management schedules will only include changes from the 

interim responses/schedules, or a statement that there are no changes. After applying applicable 

audit procedures, interim and updated legal letters will be submitted by the OIG to FMS and 

GAO no later than the dates established in the A-136, Attachment B. The OIG will inform FMS, 

via email, of any subsequent changes in cases that arise after the final representation letter but 

prior to the end of the government-wide financial statement audit completion date (per SAS No. 

103, Audit Documentation that changed the dating of the audit report date from the fieldwork 

date to the audit completion date). Contact information for these agencies can be found in the A136, Attachment C. 

SECTION 10: COMMUNICATING OTHER DEFICIENCIES 

Other deficiencies in internal control, that are not required to be included in the audit report, but 

that the auditor considers necessary to communicate, may be separately communicated to 

management of the reporting entity either orally or in writing via management letter or separate 

report. If a written document containing other deficiencies in internal control is issued or will be 

issued, the auditor must refer to that document in the auditors’ report on internal control. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 24
SECTION 11: AGREED-UPON PROCEDURES: RETIREMENT, HEALTH 

BENEFITS, AND LIFE INSURANCE WITHHOLDINGS/CONTRIBUTIONS AND 

SUPPLEMENTAL SEMIANNUAL HEADCOUNT REPORT SUBMITTED TO THE 

OFFICE OF PERSONNEL MANAGEMENT (OPM) 

11.1 The Agreed-Upon Procedures (AUPs) will be performed annually in accordance with 

Statements of Standards for Attestation Engagements, AT § 201, Agreed-Upon Procedures 

Engagements. The AUPs are designed to assist OPM in assessing the reasonableness of the 

Retirement, Health Benefits, and Life Insurance withholdings/contributions as well as 

semiannual headcount information submitted by agencies. The sufficiency of the procedures is 

solely the responsibility of the Inspector General and the Chief Financial Officer of OPM and 

will be applied to the 12 months ended August 31 of each year. 

11.2 Refer to http://www.opm.gov/oig/ for the current AUPs required by OPM. 

11.3 The auditor of each payroll provider will apply the AUPs separately (1) for each entity 

designated as subject to the CFO Act in Appendix A and (2) each entity not designated as 

subject to the CFO Act that has 30,000 or more employees. 

11.4 Although the auditor must perform the AUPs separately for each applicable entity, the 

auditor will combine the results into a single report. 

11.5 The auditor of the payroll provider is the principal auditor for the purpose of performing 

the AUPs. The auditors of customer agencies will participate to the extent necessary to ensure 

that the AUPs are performed effectively and within the established time frames. 

11.6 In light of the migration of payroll servicing responsibilities under the e-Payroll 

initiative, the payroll provider as of March 31 will be responsible for assuring that the AUPs are 

performed and reported upon. 

11.7 The report on the performance of the AUPs will be submitted no later than October 1. 

To the extent practical, management’s comments on the auditor’s findings will be included in 

the report. 

11.8 If a specific AUP cannot be performed, the auditor must propose to OPM’s OIG in 

writing no later than July 15 at the address in 11.9 an alternative procedure that would 

accomplish the AUPs’ objectives. In addition, auditors will notify OPM’s OIG by September 1

of any other anticipated difficulties in completing the procedures and submitting the required 

report by October 1. 

11.9 Agencies will submit three copies of the report on the application of these procedures to 

OPM’s OIG at the address below or, alternatively, may email the report as a PDF attachment to 

wwscott@opm.gov, with a cc: to Finance@opm.gov. 

 

U.S. Office of Personnel Management 

Office of Inspector General 

Room 6400 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 25
1900 E Street, N.W. 

Washington, DC 20415 

Attention: W.W. Scott, Jr. 

SECTION 12: INSPECTOR GENERAL OVERSIGHT 

12.1 The OIG will: 

• Ensure that audits and audit reports are completed timely and in accordance with 

the requirements of this Bulletin. This responsibility pertains to audits conducted 

by OIG staff, and IPAs under contract with the OIG. 

• Provide technical advice and liaison to agency officials and IPAs. 

• Obtain and review the most recent and subsequent peer review reports of IPAs 

under contract with the OIG to ensure that IPAs have an appropriate internal 

system of quality control in place. 

• Review responses to audit reports and report significant disagreements to the 

audit followup official per OMB Circular No. A-50, Audit Followup (A-50). 

• Monitor and report on management's progress in resolving audit findings related 

to audits made pursuant to this Bulletin, in accordance with the Inspector General 

Act of 1978, as amended, the provisions of the A-50, and FFMIA. 

12.2 The OIG is encouraged to use GAO/PCIE FAM Section 650, Using the Work of Others,

and subsequent revisions, to help design and perform oversight procedures when using IPAs 

and other specialists in the audit of agency financial statements. 

SECTION 13: AUDIT OF THE SPECIAL-PURPOSE FINANCIAL STATEMENTS 

13.1 The GMRA requires the Secretary of the Treasury, in coordination with the Director of 

the OMB, to annually prepare and submit to the President and the Congress an audited financial 

statement for the preceding fiscal year for the executive branch of the United States Government, 

namely the FR.

13.2 The Department of the Treasury’s Financial Management Service (FMS) prepares the FR 

using special-purpose financial statements and accompanying notes submitted by the significant 

entities22 to the FR and adjusted trial balances from the remainder of the entities included in the 

FR. 

 

22 The significant entities to the Financial Report of the U.S. Government (FR) are identified in the Department of 

the Treasury’s Financial Manual (TFM) Volume I, Part 2, Chapter 4700. 

http://www.fms.treas.gov/factsi/index.html and the A-136 www.whitehouse.gov/omb. The significant entities to the 

FR are referenced in the TFM as the “verifying agencies,” in relation to their responsibilities within the 

Government-wide Financial Report System (GFRS). 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 26
13.3 The special-purpose financial statements include the reclassified balance sheet, statement 

of net cost, statement of changes in net position, statement of social insurance (if applicable) and 

the accompanying notes. The special-purpose financial statements and accompanying notes are 

required to be audited and audit reports are to be submitted to the FMS, OMB, and GAO. An 

illustrative auditors’ report is provided in Appendix G. 

13.4 Audits will be performed annually and on comparative statements. For agencies in the 

initial year of implementation, the audit will apply only to that initial year’s special-purpose 

financial statements and accompanying notes. 

13.5 For purposes of this section, the significant entities to the FR, as identified in the TFM 

Chapter 4700, will subject their special-purpose financial statements to an audit by the OIG of 

the agency or by an independent auditor IPA as determined by the OIG. If the agency does not 

have an OIG, the financial statement audit will be performed by an IPA as determined by 

management. 

13.6 Communication during the audit of the special-purpose financial statements will follow 

the same principles as defined in Section 5 of this Bulletin. 

13.7 The special-purpose financial statements will be audited in accordance with U.S. 

Government Auditing Standards and the provisions of this Bulletin. The audit of the specialpurpose financial statements will encompass and leverage the audit work performed relative to 

the general purpose financial statements (referred to as “basic statements and related notes” 

elsewhere in the Bulletin). The purpose of the audit of the special-purpose financial statements 

is not to duplicate the audit work performed relative to the general purpose financial statements, 

but to provide an additional level of assurance on the process of reclassifying the agencies 

audited general purpose financial statements to the formats of the special-purpose financial 

statements pursuant to the presentation requirements set forth in the TFM Chapter 4700. 

13.8 The auditor will determine whether the special-purpose financial statements and 

accompanying notes fairly present, in all material respects, the financial position, net costs, 

changes in net position, and social insurance (if applicable) in conformity with the accounting 

principles generally accepted in the United States of America and the presentation requirements 

set forth in the TFM Chapter 4700. 

13.9 The internal control relating to the special-purpose financial statements reporting will 

encompass the internal control relating to the general purpose financial statements, upon which 

the special-purpose financial statements are based. The auditor will also obtain an understanding 

of the internal control over the financial reporting process for the special-purpose financial 

statements and perform tests of those controls. Providing an opinion on the internal control 

relating to the special-purpose financial statements reporting is not an objective of this audit. 

 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 27
13.10 The reporting on compliance with laws and regulations will encompass the compliance 

reporting related to the general-purpose financial statements upon which the special-purpose 

financial statements are based. In addition, regarding compliance with the TFM Chapter 4700, 

the auditor will perform tests of compliance with that Chapter that could have a direct and 

material effect on the special-purpose financial statements. Providing an opinion on the 

compliance with the TFM Chapter 4700 requirements is not an objective of this audit. 

13.11 The auditor will obtain written representations from management as part of an audit 

conducted in accordance with this Bulletin. It is encouraged that the audit of the financial 

reporting process for the special-purpose financial statements be conducted simultaneously with 

the audit of the general-purpose financial statements. In this circumstance, management may 

combine its representations for the audits of the special-purpose financial statements and the 

general-purpose financial statements. (See Appendix F: Illustrative Management 

Representation Letter for the Special-Purpose Financial Statements.) 

13.12 A summary of unadjusted misstatements will also be attached to the management 

representation letter. Agencies will use the schedule submitted with the management 

representation letter for the entity’s audit and include an additional column identifying the effect 

of the current year’s uncorrected misstatements on the Closing Package line items. Agencies are 

encouraged to use the format of the schedule in the GAO/PCIE FAM Section 595D, Example 

Summary of Unadjusted Misstatements, and subsequent revisions, with an additional column 

identifying the effect of the current year’s uncorrected misstatements on the Closing Package 

line items. 

13.13 The management representations and related summary of unadjusted misstatements will 

be submitted to Treasury, GAO and OMB by the due dates listed in the A-136, Attachment B. 

 

Audit Report

13.14 An auditor’s report(s) on the special-purpose financial statements, internal control over 

the financial reporting process for the special-purpose financial statements, and compliance with 

TFM Chapter 4700 will be prepared at the completion of the audit in accordance with U.S. 

Government Auditing Standards and this Bulletin. The audit report(s) will state that the audit 

was conducted in accordance with U.S. Government Auditing Standards and the provisions of 

this Bulletin. The audit report(s) will be submitted to the agency head no later than the date 

specified in the A-136, Attachment B. The audit results will be discussed with management as 

soon as practicable but, in any case, prior to issuance of the audit report. 

13.15 The audit report will include an opinion as to whether the reporting entity's specialpurpose financial statements are fairly presented in all material respects in conformity with 

accounting principles generally accepted in the United States of America and the presentation 

pursuant to the requirements of the TFM Chapter 4700, or a disclaimer of opinion. (See AU § 

623.) 

13.16 If the special-purpose financial statements are materially affected by a departure from the 

presentation requirements of the TFM Chapter 4700, the auditor will issue a qualified or adverse 

opinion and include an explanatory paragraph that describes the departure(s) from those 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 28
standards and, if practical, the effects of any material departure(s) on assets, liabilities, and net 

position; net costs and changes in net position. If the effects of the departure(s) are disclosed in a 

note to the special-purpose financial statements, the explanatory paragraph may be shortened by 

referring to that note. 

13.17 If the auditor disclaims an opinion, the report will describe why the auditor was unable to 

conduct the audit in accordance with U.S. Government Auditing Standards and this Bulletin. If 

material weaknesses and other significant deficiencies prevented the conduct of the audit in 

accordance with U.S. Government Auditing Standards and this Bulletin, such conditions will be 

included in the section on internal control, along with recommendations for correcting the 

condition(s). The report will also include an explanatory paragraph that describes any material 

departure(s) from the presentation requirements of the TFM Chapter 4700 and, if practical, the 

effects of the departure(s) on assets, liabilities, and net position; net costs and changes in net 

position. If the effects of the departure(s) are disclosed in a note to the special-purpose financial 

statements, the explanatory paragraph may be shortened by referring to that note. 

13.18 With respect to reporting on other data, the auditor will follow AU § 551. 

Section on Internal Control

13.19 The auditor will state that, with respect to internal control over the financial reporting 

process for the special-purpose financial statements, the auditor obtained an understanding and 

performed tests of the reporting entity's internal controls. 

13.20 The auditor will describe significant deficiencies and material weaknesses identified 

during the audit of the special-purpose financial statements. 

13.21 The section will state that providing an opinion on internal control over the specialpurpose financial statements reporting was not an objective of the audit. 

13.22 The section will reference the report on internal control that was issued as part of the 

audit of the general-purpose financial statements. 

Section on Compliance with the TFM

13.23 The auditor will report noncompliance with the TFM Chapter 4700 disclosed by audit, 

except for those instances of noncompliance that, in the auditor's judgment, are clearly 

inconsequential. 

• Include all facts pertaining to the noncompliance, including the nature and extent 

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

relevant comments from reporting entity management or employees responsible 

for the noncompliance. 

• Provide recommended remedial actions. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 29
13.24 In the event the audit disclosed no reportable instances of noncompliance, the section will 

state that the audit disclosed no reportable instances of noncompliance with the TFM Chapter 

4700. 

13.25 The section will state that providing an opinion on compliance was not an objective of 

the audit. 

13.26 The section will reference the report on compliance with laws and regulations that was 

issued as part of the audit of the general-purpose financial statements. 

Status/Comments/Distribution

13.27 In preparing the audit report(s), the auditor will report the status of known but 

uncorrected findings and recommendations from prior audits that affect the current audit 

objectives. 

13.28 The reporting entity will provide comments on the auditors’ findings and 

recommendations included in the audit report, including corrective actions taken or planned and 

comments on the status of corrective actions taken on prior findings. To the extent practical, 

these comments will be included in the audit report, as applicable. If corrective actions are not 

necessary, an explanatory statement will be included in the applicable audit report. 

13.29 Specified documents are required to be submitted with the audit report. (Refer to the 

TFM Chapter 4700 for a complete listing.) 

 

13.30 Copies of the audit report(s) will be distributed to the head of the executive department or 

agency and simultaneously submitted to the FMS, OMB, and GAO, no later than the date 

specified in the A-136, Attachment B. 

Communicating Other Deficiencies

13.31 Other deficiencies in internal control, that are not required to be included in the audit 

report, but that the auditor considers necessary to communicate, may be communicated 

separately to the reporting entity’s management either orally or in writing via a management 

letter or separate report. (See Chapter 5 of U.S. Government Auditing Standards for further 

guidance.) If a separate document containing other deficiencies in internal control over the 

financial reporting process for the special-purpose financial statements is issued, the auditor 

must refer to that document in the auditors’ report. 

Intragovernmental Balances: Supplementary and Agreed-Upon Procedures (AUP)

13.32 Intragovernmental balances and transactions are a key component in the consolidation of 

the financial information submitted by Federal entities and in the overall compilation process of 

the FR. Intragovernmental balances include transactions between Federal entities such as 

services or goods sold, transfers of assets or budget authority, investments or borrowings with 

the Department of the Treasury, and benefit-related transactions with the Department of Labor 

and the Office of Personnel Management. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 30
13.33 Intragovernmental balances by trading partner are included within the scope of the 

special-purpose financial statements audit (Module 4 of the Governmentwide Financial Report 

System (GFRS) included as a note disclosure). As progress continues in mitigating and 

resolving the material weaknesses on the FR that are related to intragovernmental balances, 

supplementary procedures may be necessary at the component entity level. As a start, for the 

third quarter of fiscal year 2007, OMB will require that AUP be performed by agencies where 

there is evidence and a history of systemic or recurring problems in accounting, reporting, or 

reconciling intragovernmental balances. The AUP will be targeted to identify, analyze, and 

facilitate the correction of the underlying internal control or process weaknesses at those 

agencies (See illustrative example of Appendix H.). OMB will contact the applicable agencies, 

and their respective OIGs, that meet the above criteria no later than August 15, 2007. Those 

agencies, their OIGs, and FMS must meet to formulate AUP that are agreed to by the applicable 

parties and are in conformance with AICPA standards. The OIG/IPA will issue its AUP Report 

in accordance with AT Section 201, Agreed-Upon Procedures Engagements. Thereafter, the 

AUP Report on the 3rd Quarter Intragovernmental Activity and Balances must be delivered to the 

applicable parties no later than September 6, 2007. 

SECTION 14: SIGNIFICANT DUE DATES AND CONTACT INFORMATION FOR 

FINANCIAL STATEMENTS AND RELATED REPORTS 

For a complete list of year-end financial reports and their respective due dates, please refer to the 

A-136, Attachment B. In addition, contact information is provided in the A-136, Attachment C. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 31
TABLE OF APPENDICES 

Appendix A: Executive Departments and Agencies Subject to the CFO Act Required to 

Prepare Financial Statements 

Appendix B: Components of Executive Departments and Agencies Required to Prepare 

Financial Statements 

Appendix C: Executive Agencies Subject to the Accountability of Tax Dollars Act 

Required to Prepare Financial Statements 

Appendix D: Government Corporations Required to Prepare Financial Statements 

Appendix E: General Laws 

Appendix F: Illustrative Management Representation Letter for the Special-Purpose 

Financial Statements 

Appendix G: Illustrative Independent Auditors’ Report on the Special-Purpose 

Financial Statements 

Appendix H: Illustrative Agreed-Upon Procedures on Intragovernmental Material 

Differences 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 32
APPENDIX A 

EXECUTIVE DEPARTMENTS AND AGENCIES SUBJECT TO THE CHIEF 

FINANCIAL OFFICERS (CFO) ACT REQUIRED TO PREPARE FINANCIAL 

STATEMENTS

Department of Agriculture 

Department of Commerce 

Department of Defense 

Department of Education 

Department of Energy 

Department of Health and Human Services 

Department of Homeland Security 

Department of Housing and Urban Development 

Department of the Interior 

Department of Justice 

Department of Labor 

Department of State 

Department of Transportation 

Department of the Treasury 

Department of Veterans Affairs 

Agency for International Development 

Environmental Protection Agency 

General Services Administration 

National Aeronautics and Space Administration 

National Science Foundation 

Nuclear Regulatory Commission 

Office of Personnel Management 

Small Business Administration 

Social Security Administration 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 33
APPENDIX B 

COMPONENTS OF EXECUTIVE DEPARTMENTS AND AGENCIES REQUIRED TO 

PREPARE FINANCIAL STATEMENTS23

Department of Agriculture

Food and Nutrition Service 

Forest Service 

Rural Development Mission Area 

Department of Defense

Department of Army General Funds 

Department of Navy General Funds 

Department of Air Force General Funds 

Military Retirement Fund 

U.S. Army Corps of Engineers Civil Works Program 

Department of Army Working Capital Fund 

Department of Navy Working Capital Fund 

Department of Air Force Working Capital Fund 

Department of Health and Human Services

Centers for Medicare & Medicaid Services 

Department of Transportation

Federal Aviation Administration 

Department of the Treasury

Internal Revenue Service 

Office of Personnel Management

Civil Service Retirement and Disability Fund 

Federal Employees Health Benefits Program 

Federal Employees Life Insurance Program 

 

23 The requirement for components to prepare financial statements may be satisfied by presenting the components 

separately in consolidating agency-wide financial statements and conducting an audit, in accordance with this 

Bulletin, at the consolidating financial statement level. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 34
APPENDIX C 

 (Page 1 of 2) 

EXECUTIVE AGENCIES SUBJECT TO THE ACCOUNTABILITY OF TAX DOLLARS 

ACT REQUIRED TO PREPARE FINANCIAL STATEMENTS

Advisory Council on Historic Preservation 

African Development Fund 

Appalachian Regional Commission 

Architectural and Transportation Barriers Compliance Board 

Armed Forces Retirement Home 

Barry Goldwater Scholarship and Excellence in Education Fund 

Broadcasting Board of Governors 

Central Intelligence Agency 

Chemical Safety and Hazard Investigation Board 

Christopher Columbus Fellowship Foundation 

Commission on Civil Rights 

Commission of Fine Arts 

Commission for the Preservation of America’s Heritage Abroad 

Committee for Purchase from People Who Are Blind or Severely Disabled 

Commodities Futures Trading Commission 

Consumer Product Safety Commission 

Court Services and Offender Supervision Agency for DC 

Defense Nuclear Facilities Safety Board 

Delta Regional Authority 

Denali Commission 

Equal Employment Opportunity Commission 

Farm Credit Administration 

Farm Credit System Insurance Corporation 

Federal Communications Commission 

Federal Election Commission 

Federal Financial Institutions Examination Council Appraisal Subcommittee 

Federal Housing Finance Board 

Federal Labor Relations Authority 

Federal Mediation and Conciliation Service 

Federal Mine Safety and Health Review Commission 

Federal Retirement Thrift Investment Board 

Federal Trade Commission 

Harry S. Truman Scholarship Fund 

Institute of American Indian and Alaska Native Culture and Arts Development 

Institute of Museum and Library Services 

Inter-American Foundation 

James Madison Memorial Fellowship Foundation 

Japan-U.S. Friendship Commission 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 35
APPENDIX C 

(Page 2 of 2)

EXECUTIVE AGENCIES SUBJECT TO THE ACCOUNTABILITY OF TAX 

DOLLARS ACT REQUIRED TO PREPARE FINANCIAL STATEMENTS 

Marine Mammal Commission 

Merit Systems Protection Board 

Morris K. Udall Scholarship and Excellence in National Environmental 

Policy Foundation 

National Archives and Records Administration 

National Capital Planning Commission 

National Commission on Libraries and Information Science 

National Council on Disability 

National Credit Union Administration 

National Endowment for the Arts 

National Endowment for the Humanities 

National Labor Relations Board 

National Mediation Board 

 National Transportation Safety Board 

Nuclear Waste Technical Review Board 

Occupational Safety and Health Review Commission 

Office of Government Ethics 

Office of Navajo and Hopi Indian Relocation Commission 

Office of Special Counsel 

Peace Corps 

Presidio Trust 

Railroad Retirement Board 

Securities and Exchange Commission 

Selective Service System 

Smithsonian Institution (SI) 

SI/John F. Kennedy Center for the Performing Arts 

SI/National Gallery of Arts 

SI/Woodrow Wilson International Center for Scholars 

Trade and Development Agency 

U.S. Court of Appeals for Veterans Claims 

U.S. Holocaust Memorial Museum 

U.S. Interagency Council on Homelessness 

U.S. International Trade Commission 

Vietnam Education Foundation 

White House Commission on the National Moment of Remembrance 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 36
APPENDIX D 

GOVERNMENT CORPORATIONS REQUIRED TO PREPARE FINANCIAL 

STATEMENTS 

Commodity Credit Corporation 

Community Development Financial Institutions Fund 

Corporation for National and Community Service 

Export-Import Bank of the United States 

Federal Crop Insurance Corporation 

Federal Deposit Insurance Corporation 

Federal Home Loan Banks 

Federal Housing Administration Fund 

Federal Prison Industries, Incorporated 

Financing Corporation 

Government National Mortgage Association 

Millennium Challenge Corporation 

National Credit Union Administration Central Liquidity Facility 

Overseas Private Investment Corporation 

Pension Benefit Guaranty Corporation 

Rural Telephone Bank 

Resolution Funding Corporation 

Saint Lawrence Seaway Development Corporation 

Tennessee Valley Authority 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 37
APPENDIX E 

GENERAL LAWS24

• Anti-Deficiency Act (codified as amended in 31 U.S.C. §§ 1341, 1342, 1351, 1517) 

31 U.S.C. § 1341(a)(1)(A) and (C) 

31 U.S.C. § 1517 (a) 

• Federal Credit Reform Act of 1990, Pub. L. No. 101-508, 104 Stat. 1388-610 (codified 

in various sections of title 2, United States Code) 

2 U.S.C. § 661(b) and (e) 

 

• Pay and Allowance System for Civilian Employees as provided primarily in Chapters 51-

59 of title 5, United States Code 

5 U.S.C. §§ 5332 and 5343 

29 U.S.C. § 206 

• Prompt Payment Act (codified as amended in 31 U.S.C. §§ 3901-3907) 

31 U.S.C. § 3902(a), (b), and (f) 

31 U.S.C. § 3904 

• Provisions Governing Claims of the United States Government as provided primarily in 

sections 3711 through 3720E of title 31, United States Code (including provisions of the 

Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321-358, 

which also is codified in various sections of titles 5, 18, 26, 28, 31, and 42, United States 

Code) 

31 U.S.C. § 3711 

31 U.S.C. § 3717 (a), (b), (c), (e) and (f) 

31 U.S.C. § 3719 

 

24 The auditor is not expected to test all provisions of each law presented. However, the auditor is expected to test, 

at a minimum, the provisions cited above. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 38
APPENDIX F

ILLUSTRATIVE MANAGEMENT REPRESENTATION LETTER 

FOR THE SPECIAL-PURPOSE FINANCIAL STATEMENTS

[Entity Letterhead] 

[Date of auditor's report] 

[Name and title of head of audit organization] 

[Address of audit organization] 

Dear [name of head of audit organization]: 

This letter is in connection with your audits of the [name of Federal agency]’s special-purpose 

financial statements, including the reclassified balance sheets as of [end of years covered by 

special-purpose financial statements] and the related statements of net cost and changes in net 

position for the year then ended, and the statements of social insurance (if applicable) for the 

purpose of expressing an opinion as to whether the special-purpose financial statements are 

presented fairly, in all material respects, in conformity with accounting principles generally 

accepted in the United States of America and the presentation requirements set forth in the U.S. 

Department of the Treasury’s Financial Manual (TFM) Volume I, Part 2, Chapter 4700. 

We confirm, to the best of our knowledge and belief, the following representations made to you 

during your audits, which these representations are as of the date of your auditor’s report, and 

pertain to the periods covered by the special-purpose financial statements. 

1. We are responsible for the fair presentation of the special-purpose financial statements in 

conformity with the accounting principles generally accepted in the United States of 

America and the presentation requirements set forth in the TFM Chapter 4700. 

2. The special-purpose financial statements are fairly presented in conformity with the 

accounting principles generally accepted in the United States of America and the 

presentation requirements set forth in the TFM Chapter 4700. 

If there are instances of departures from generally accepted accounting principles or 

noncompliance with the requirements set forth in the TFM Chapter 4700, this statement 

should be modified to disclose all known instances of departure or noncompliance. 

3. We have made available to you, all financial records and related data relevant to 

 the reclassification of [name of Federal agency]’s audited, consolidated 

 department-level financial statements to the reclassified special-purpose financial 

 statements and accompanying notes as prescribed in the TFM Chapter 4700. 

4. There are no material transactions that have not been properly reclassified in the specialpurpose financial statements or disclosed in the notes to the financial statements. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 39
5. We are responsible for establishing and maintaining internal control over the specialpurpose financial statement reporting process and complying with the requirements set 

forth in the TFM Chapter 4700. 

6. Those controls in place on September 30, 20XX [or date of latest audited financial 

statements] provided reasonable assurance that the foregoing objectives are met. 

If there are material weaknesses in internal control over the special-purpose financial 

statement reporting process, the foregoing representation should be modified to read: 

“Those controls in place on September 30, 20XX, provided reasonable assurance that the 

foregoing objectives are met except for the effects of the material weaknesses discussed 

below (or in the attachment),” or a statement that “internal controls are not effective” or 

“do not meet the foregoing objectives.” 

[Signed by Agency Head] 

[Signed by Chief Financial Officer] 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 40
APPENDIX G 

ILLUSTRATIVE INDEPENDENT AUDITORS’ REPORT ON SPECIAL-PURPOSE 

FINANCIAL STATEMENTS 

We have audited the accompanying reclassified balance sheets as of September 30, [insert years] 

and the related reclassified statements of net cost and changes in net position for the year then 

ended, and the statements of social insurance (if applicable) (hereinafter referred to as the 

special-purpose financial statements) contained in the special-purpose closing package of [name 

of Federal Agency]. These special-purpose financial statements are the responsibility of [name 

of Federal Agency]’s management. Our responsibility is to express an opinion on these specialpurpose financial statements based on our audit. 

We conducted our audit in accordance with auditing standards generally accepted in the United 

States of America and the standards applicable to financial audits contained in U.S. Government 

Auditing Standards, issued by the Comptroller General of the United States; and, Office of 

Management and Budget (OMB) Bulletin No. 07-xx, Audit Requirements for Federal Financial 

Statements, as amended. Those standards require that we plan and perform the audit to obtain 

reasonable assurance about whether the special-purpose financial statements are free of material 

misstatement. An audit includes examining, on a test basis, evidence supporting the amounts 

and disclosures in the special-purpose financial statements. An audit also includes assessing the 

accounting principles used and significant estimates made by management, as well as evaluating 

the overall special-purpose financial statement presentation. We believe that our audit provides a 

reasonable basis for our opinion. 

The accompanying special-purpose financial statements and accompanying notes contained in 

the special-purpose closing package have been prepared for the purpose of complying with the 

requirements of the U.S. Department of the Treasury’s Financial Manual (TFM) Volume I, Part 

2, Chapter 4700, as described in note X, solely for the purpose of providing financial information 

to the U.S. Department of the Treasury and U.S. Government Accountability Office to use in 

preparing and auditing the Financial Report of the U.S. Government, and are not intended to be a 

complete presentation of [name of Federal Agency]’s financial statements. 

In our opinion, the special-purpose financial statements and accompanying notes referred to 

above present fairly, in all material respects, the financial position of [name of Federal Agency] 

as of September 30, [insert year(s)], and its net costs and changes in net position for the year 

then ended, and the statements of social insurance (if applicable) in conformity with accounting 

principles generally accepted in the United States of America and the presentation pursuant to 

the requirements of the TFM Chapter 4700. 

The information included in the Other Data is presented for the purpose of additional analysis 

and is not a required part of the special-purpose financial statements, but is supplementary 

information required by the TFM Chapter 4700. We have applied certain limited procedures, 

which consisted principally of inquiries of management regarding methodology and presentation 

of this information. We also reviewed such information for consistency with the related 

information presented in [name of federal agency]’s financial statements. However, we did not 

audit this information, and accordingly, we express no opinion on it. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 41
In accordance with U.S. Government Auditing Standards and OMB Bulletin No. 07-xx, we have 

also issued reports25 dated [insert date] on our consideration of [name of Federal Agency]’s 

internal control over financial reporting and its compliance with certain provisions of laws and 

regulations. Those reports are an integral part of an audit of general-purpose financial statement 

reporting performed in accordance with U.S. Government Auditing Standards and OMB Bulletin 

No. 07-xx, as amended, and should be read in conjunction with this report in considering the 

results of our audit. 

In planning and performing our audit of the special-purpose financial statements, we also 

considered [name of Federal Agency]’s internal control over the financial reporting process for 

the special-purpose financial statements and compliance with the TFM Chapter 4700. 

Management is responsible for establishing and maintaining internal control over financial 

reporting, including Other Data, and for complying with laws and regulations, including 

compliance with the TFM Chapter 4700 requirements. 

Our consideration of internal control over the financial reporting process for the special-purpose 

financial statements would not necessarily disclose all matters in the internal control over the 

financial reporting process that might be significant deficiencies. Under standards issued by the 

American Institute of Certified Public Accountants, significant deficiencies are deficiencies in 

internal control, or a combination of deficiencies, that adversely affects [name of Federal 

Agency]’s ability to initiate, authorize, record, process, or report financial data reliably and in 

accordance with accounting principles generally accepted in the United States of America such 

that there is more than a remote likelihood that a misstatement of the special-purpose financial 

statements being audited that is more than inconsequential will not be prevented or detected. 

Material weaknesses are significant deficiencies, or a combination of significant deficiencies, 

that result in a more than remote likelihood that material misstatements in relation to the specialpurpose financial statements being audited will not be prevented or detected. 

We found no material weaknesses in internal control over the financial reporting process for the 

special-purpose financial statements, and our tests of compliance with the TFM Chapter 4700 

requirements disclosed no instances of noncompliance that are required to be reported under U.S. 

Government Auditing Standards and OMB Bulletin No. 07-xx, as amended. However, providing 

opinions on internal control over the financial reporting process for the special-purpose financial 

statements or on compliance with the TFM Chapter 4700 requirements were not objectives of 

our audit of the special-purpose financial statements and, accordingly, we do not express such 

opinions. 

 

25 If an agency’s auditor issues a combined report that includes the audit report on the financial statements, the 

report on internal control over financial reporting and compliance with certain provisions of laws and regulations, 

the language in this section should be modified accordingly. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 42
This report is intended solely for the information and use of [name of Federal Agency], the U.S. 

Department of the Treasury, the Office of Management and Budget and the U.S. Government 

Accountability Office in connection with the preparation and audit of the Financial Report of the 

U.S. Government and is not intended to be and should not be used by anyone other than these 

specified parties. 

[Signature] 

[Date] 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 43
Notes to the Special-Purpose Financial Statements 

Note X - Special-Purpose Financial Statement Requirements 

The Budget and Accounting Procedures Act of 1950 allows the Secretary of the Treasury to 

stipulate the format and requirements of executive agencies to furnish financial and operational 

information to the President and the Congress to comply with the Government Management 

Reform Act of 1994 (GMRA) (Pub. L. No. 103-356), which requires the Secretary of the 

Treasury to prepare and submit annual audited financial statements of the executive branch. The 

Secretary of the Treasury developed guidance in the U.S. Department of the Treasury’s Financial 

Manual (TFM) Volume I, Part 2, Chapter 4700 to provide agencies with instructions to meet the 

requirements of GMRA. The TFM Chapter 4700 requires agencies to: 

1. Reclassify all items and amounts on the audited consolidated, department-level 

balance sheets, statements of net cost, changes in net position/income statement, 

social insurance and custodial activity, if applicable, to the special-purpose 

financial statements; 

2. Disclose special-purpose financial statement line item amounts identified as 

Federal by trading partner and amount (amounts should be net of intra-agency and 

intra-departmental eliminations); 

3. Disclose notes required by Balance Sheet line items and other notes required in 

the Financial Report of the U.S. Government (FR); and 

4. Disclose other data not contained in the primary FR financial statements and notes 

required to meet GAAP requirements. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 44
APPENDIX H 

ILLUSTRATIVE AGREED-UPON PROCEDURES ON INTRAGOVERNMENTAL 

MATERIAL DIFFERENCES 

For the third quarter of fiscal year 2007, the agency OIG/IPA will perform AUP on material 

differences identified by FMS. Those agencies, their OIGs, and FMS must meet to formulate AUP 

that are agreed to by the applicable parties and are in conformance with AICPA standards. 

Thereafter, the OIG/IPA will issue its AUP Report in accordance with AT Section 201, AgreedUpon Procedures Engagements. Below is an example of the AUP. 

1. Obtain a copy of the reconciliation schedule from the OCFO. 

2. Obtain the agency’s policies and procedures that describe the agency’s activities to record, 

process, summarize, reconcile, and report intragovernmental activity/balances by trading 

partner. 

3. Obtain a copy of the Intragovernmental Business Rules (TFM Bulletin No. 2007-03). 

4. Inspect and compare the recording of items identified in the OCFO-provided reconciliation 

schedule (provided in Procedure 1) to the agency’s policies and procedures, and determine 

whether the items were recorded in accordance with those policies and procedures. 

5. For those items identified in Procedure 1 which were not recorded in accordance with the 

agency policies and procedures, document which policy and/or procedure was not applied. 

Also, document if these items are contrary tothe Intragovernmental Business Rules (TFM 

Bulletin No. 2007-03). 

6. For all items identified in Procedure 1, inspect the OCFO-documented communications with 

its trading partner and the actions outlined/taken by the OCFO to resolve the difference, and 

determine whether the communications and actions taken were in accordance with the 

agency’s policies and procedures identified in Procedure 2. 

The AUP Report on the 3rd Quarter Intragovernmental Activity and Balances must be delivered to 

the applicable parties no later than September 6, 2007. 

OMB Bulletin No. 07-04, Audit Requirements for Federal Financial Statements 45