GAO-07-61R Commission on the National Moment of Remembrance 

United States Government Accountability Office

Washington, DC 20548 

October 26, 2006 

The Honorable Arlen Specter 

Chairman 

The Honorable Patrick J. Leahy 

Ranking Minority Member 

Committee on the Judiciary 

United States Senate 

The Honorable F. James Sensenbrenner, Jr. 

Chairman 

The Honorable John Conyers, Jr. 

Ranking Minority Member 

Committee on the Judiciary 

House of Representatives 

Subject: Financial Management: Review of the Financial Statement Audit of the 

White House Commission on the National Moment of Remembrance for 

Fiscal Year 2005 and Status of GAO Audit Recommendations 

The White House Commission on the National Moment of Remembrance 

(Commission) was created on December 28, 2000, by the National Moment of 

Remembrance Act.1

 The Commission’s purpose is to sustain the American spirit 

through acts of remembrance, not only on Memorial Day but also throughout the 

year, for those who died serving our country.

The National Moment of Remembrance Act requires us to annually audit the financial 

transactions of the Commission. However, as reflected in an Office of Management 

and Budget (OMB) memorandum,2

 the Commission is subject to the Accountability of 

Tax Dollars Act of 2002 which was enacted on November 7, 2002.3

 This act requires 

the Commission to annually prepare and submit audited financial statements to OMB 

 

1

Pub. L. No. 106-579, 114 Stat. 3078 (Dec. 28, 2000) (reprinted at 36 U.S.C. § 116 note). 

2

Office of Management and Budget, Memorandum for the Heads of Executive Departments and 

Agencies, Chief Financial Officers and Inspectors General: Amendments to OMB Bulletin No. 01-02, 

Audit Requirements for Federal Financial Statements, M-04-22, at 13 (Washington, D.C.: July 27, 

2004). 

3

Pub. L. No. 107-289, 116 Stat. 2049 (Nov. 7, 2002) (codified, as amended, at 31 U.S.C. § 3515). 
and Congress. This is the first year the Commission has prepared a complete set of 

financial statements and contracted with an independent public accountant (IPA) to 

conduct the financial statement audit. In lieu of performing an audit of the 

Commission’s fiscal year 2005 financial transactions, which would duplicate much of 

the work performed by the IPA, we performed a review of the IPA’s audit of the 

Commission’s financial statements. This report provides the results of our review of 

the Commission’s fiscal year 2005 financial statement audit and provides the status of 

the Commission’s implementation of recommendations made by us during prior 

years’ audits of the Commission’s financial transactions. Our work was performed in 

accordance with U.S. generally accepted government auditing standards. 

Results in Brief 

We found no instances in which the IPA did not perform sufficient work to support 

its opinion and no instances in which the IPA did not comply, in all material respects, 

with U.S. generally accepted government auditing standards. In its audit of the 

Commission’s fiscal year 2005 financial statements, the IPA found that (1) the 

financial statements were presented fairly, except for the Commission’s failure to 

provide a legal representation letter; (2) the Commission’s failure to provide a legal 

representation letter also resulted in a reportable condition;4

 and (3) there was no

reportable noncompliance with selected provisions of laws and regulations. 

In our report on our audit of the Commission’s fiscal year 2004 financial transactions,5

we made 10 recommendations to the Commission designed to improve its overall 

financial management and internal control. Subsequently, the Commission provided 

a written statement of actions it had taken or was planning to take to address the 

issues we reported that gave rise to our recommendations. We reviewed the actions 

taken by the Commission and found that the Commission had effectively 

implemented 9 of our 10 recommendations. 

We are not making any new recommendations in this report. The Commission agreed 

with the results presented in this report. 

Background 

The Commission’s purpose is to sustain the American spirit through acts of 

remembrance, not only on Memorial Day but also throughout the year, for those who 

died serving our country. Congress appropriated $1.25 million to the Commission to 

fund its operations for fiscal years 2002 through 2005.6

 In fiscal year 2005, the 

 4

Reportable conditions are matters coming to the auditor’s attention that in the auditor’s judgment

should be communicated because they represent significant deficiencies in the design or operation of

internal control, which could adversely affect the entity’s ability to meet the internal control objectives

described in the report. 

5

GAO, Financial Management: Audit of the White House Commission on the National Moment of 

Remembrance for Fiscal Year 2004, GAO-05-791R (Washington, D.C.: July 21, 2005). 

6

Congress appropriated $500,000 in fiscal year 2002 and $250,000 per year in fiscal years 2003 through 

2005. See, respectively, Pub. L. No. 107-117, 115 Stat. 2230, 2299 (Jan. 10, 2002); Pub. L. No. 108-7, div. 

J, title IV, 117 Stat. 11, 460 (Feb. 20, 2003); Pub. L. No. 108-199, div. F, title IV, 118 Stat. 3, 340 (Jan. 23, 

2004); and Pub. L. No.108-447, div. I, title III, 118 Stat. 2809, 3337 (Dec. 8, 2004). 

Page 2 GAO-07-61R Commission on the National Moment of Remembrance 
Commission received net appropriations of approximately $248,000, along with cash 

and in-kind7

 donations of approximately $103,000 from individuals and businesses. In 

addition, it had approximately $244,000 in unexpended appropriations from prior 

fiscal years. The Commission expended approximately $239,000 of appropriated 

funds and funded costs of approximately $103,000 with cash and in-kind donations 

received during the fiscal year. 

Processing of Commission Financial Transactions

The Commission utilizes the Department of Veterans Affairs (VA)—through an 

interagency agreement—for administrative support services, including payment of 

the Commission’s bills and personnel and payroll services. VA processes the 

Commission’s obligations, expenditures, and cash and in-kind donations recorded 

during the fiscal year. VA also prepares annual financial statements and monthly 

standard forms on budget execution for the Commission. During fiscal year 2005, the 

Commission employed the services of a part-time bookkeeper to help maintain its 

financial records. 

Financial Reporting and Audit Requirements

The Commission is required under the Accountability of Tax Dollars Act of 2002 to 

annually prepare and submit audited financial statements. OMB Circular No. A-136, 

Financial Reporting Requirements, as amended, identifies the basic financial 

statements to include the Balance Sheet, Statement of Net Cost, Statement of 

Changes in Net Position, Statement of Budgetary Resources, and Statement of 

Financing. The financial statements are to be prepared in accordance with U.S. 

generally accepted accounting principles, and their production is intended, in part, to 

provide for complete, reliable, timely, and consistent financial information for use by 

management and Congress in the financing, management, and evaluation of federal 

programs. 

Federal financial statements are to be audited in accordance with U.S. generally 

accepted government auditing standards.8

 OMB’s guidance in OMB Circular No. 

A-136 requires agencies to prepare and submit their performance and accountability 

reports, which include agencies’ audited financial statements, to OMB and Congress 

no later than November 15 for agencies with a September 30 fiscal year-end. OMB 

granted the Commission an exemption from the requirement to prepare audited 

financial statements for fiscal year 20049

 but did not exempt the Commission from 

 

7

In-kind donations are noncash assets and contributed services—such as Web site hosting and the use 

of facilities and staff. 

8

For financial statement audits, generally accepted government auditing standards incorporate the 

standards of the American Institute of Certified Public Accountants. 

9

Under the Accountability of Tax Dollars Act of 2002, the Director of OMB may, under certain 

conditions, exempt certain covered executive agencies from the financial statement requirements of

the Accountability of Tax Dollars Act of 2002 for a particular fiscal year. See Pub. L. No. 107-289, § 

2(a)(4), 116 Stat. 2049 (Nov. 7, 2002) (codified at 31 U.S.C. § 3515(e)). 

Page 3 GAO-07-61R Commission on the National Moment of Remembrance 
this requirement in fiscal year 2005. The Commission did not submit audited 

financial statements to OMB by November 15, 2005, as required by OMB guidance, 

and the Commission did not request an exemption from this requirement from OMB 

for fiscal year 2005. 

Financial statement audits of federal departments and agencies, performed in 

accordance with generally accepted government auditing standards, are intended to 

provide reasonable assurance about whether the financial statements for an audited 

entity present fairly, in all material respects, its financial position, net cost, changes in 

net position, budgetary status, and financing, in conformity with U.S. generally 

accepted accounting principles. OMB Bulletin No. 01-02, Audit Requirements for 

Federal Financial Statements, as amended, establishes the minimum requirements 

for audits of federal financial statements.10 OMB audit guidance requires auditors to 

(1) report whether agencies’ financial statements are fairly presented in all material

respects, in conformity with U.S. generally accepted accounting principles; (2) obtain 

an understanding of the components of internal controls and assess the level of 

control risk; and (3) test whether agencies comply with laws and regulations that 

have a direct and material effect on the financial statements. 

Objectives, Scope, and Methodology 

Our objectives were to determine (1) whether the IPA performed sufficient work to 

support its opinion on the fiscal year 2005 financial statements of the Commission; 

(2) whether the financial statement audit was performed in accordance with 

appropriate auditing standards; and (3) whether, and to what extent, the Commission 

effectively implemented recommendations made by us in our prior audits of the 

Commission’s financial transactions. 

To satisfy these objectives, we reviewed the IPA’s report and related audit 

documentation and, as necessary, met with IPA representatives and the 

Commission’s management. Our review, as differentiated from an audit in 

accordance with generally accepted government auditing standards, was not 

intended to enable us to express, and we do not express, opinions on the 

Commission’s financial statements and about the effectiveness of its internal control 

or conclude on its compliance with laws and regulations. We performed our review 

in accordance with Section 650 of the GAO/President’s Council on Integrity and 

Efficiency Financial Audit Manual. This guidance requires us to

• evaluate the IPA’s independence and objectivity, 

• evaluate the IPA’s qualifications, and 

• review and evaluate the IPA’s work. 

We evaluated the IPA’s independence, objectivity, and qualifications by reviewing the 

following: 

 10OMB requirements incorporate both generally accepted government auditing standards and AICPA 

auditing standards. OMB Bulletin No. 01-02 was superseded by OMB Bulletin No. 06-03, Audit 

Requirements for Federal Financial Statements, on August 23, 2006. 

Page 4 GAO-07-61R Commission on the National Moment of Remembrance 
• the most recent peer review11 report for the IPA (dated September 30, 2004) 

and the corresponding letter of response, 

• the informal request for proposal sent out by the Commission when 

seeking an audit firm to conduct the audit of its fiscal year 2005 financial 

statements,

• the engagement letter between the IPA and the Commission, and

• résumés for the IPA staff assigned to the Commission’s audit. 

To determine whether the IPA performed sufficient work to support its audit opinion 

and whether the auditor complied with U.S. generally accepted government auditing 

standards, we reviewed the IPA’s planning, testing, and reporting audit 

documentation and made inquiries of the IPA staff. 

To determine whether, and to what extent, the Commission effectively implemented 

recommendations we made during prior years’ audits of the Commission’s financial 

transactions, we reviewed the IPA’s audit documentation, made inquiries of 

Commission personnel, and obtained certain documentation from the Commission. 

 

Because we did not audit the Commission’s financial statements, we do not express 

an opinion on the statements. Our work was performed from April 2006 through 

October 2006 in accordance with U.S. generally accepted government auditing

standards. We provided a draft of our report to the Commission for review and

comment. 

IPA Is Independent, Objective, and Qualified 

We determined the IPA to be independent and objective with respect to the 

Commission. We evaluated the IPA’s qualifications by reviewing résumés for the IPA 

staff assigned to the Commission’s audit, and determined the IPA to be qualified to 

perform the audit of the Commission. 

The IPA’s most recent peer review report was unqualified; however, the report cited 

the need for the IPA to improve its quality control policies and procedures. The 

results of our review also indicated that the IPA’s quality control policies and 

procedures should be further enhanced. 

Sufficient Audit Work Was Performed, and Audit Was Performed in 

Accordance with Generally Accepted Government Auditing Standards 

During our preliminary review of the IPA’s audit documentation, we found areas in 

which further documentation was needed. In all instances, the IPA provided the 

 11U.S. generally accepted government auditing standards require audit organizations to have an 

external peer review conducted at least once every 3 years by reviewers independent of the

organization being reviewed. The external peer review should determine whether, during the period 

under review, the reviewed audit organization’s internal quality control system was adequate and 

whether quality control policies and procedures were being complied with to provide the audit

organization with reasonable assurance of conforming with applicable professional standards. 

Page 5 GAO-07-61R Commission on the National Moment of Remembrance 
additional documentation needed. Our final review of the audit of the Commission’s 

financial statements disclosed no instances in which insufficient audit work was 

performed by the IPA to support its audit opinion. Our review also disclosed no 

instances in which the IPA did not comply, in all material respects, with U.S. 

generally accepted government auditing standards. 

Commission Received a Qualified Audit Opinion 

The Commission received a qualified opinion on its fiscal year 2005 financial 

statements. The IPA found that the Commission’s financial statements were 

presented fairly, except for the Commission’s failure to obtain a legal representation 

letter.12 The Commission’s failure to obtain a legal representation letter also resulted 

in a reportable condition in the IPA’s report on internal control over financial 

reporting. The IPA found no instances of noncompliance with laws and regulations 

on the part of the Commission and noted no other matters to be communicated to the 

Commission. 

Commission Has Taken Action to Improve Internal Control

In our prior work, we found that the Commission’s internal control over financial 

transactions needed improvement.13 In particular, we found that (1) documentation 

for payroll, benefits, and payments to VA was not readily available; (2) reconciliations 

with VA’s records were not routinely performed; (3) financial transactions were not 

properly coded; (4) procurement regulations were not followed; (5) travel 

reimbursements exceeded allowable rates; (6) cash and in-kind donations were not 

always recorded; and (7) greater distinction between the Commission and another 

nonprofit organization called No Greater Love was needed. We made 10 

recommendations to the Commission for corrective actions to improve its overall 

financial management and internal control. 

Since our audit of the Commission’s fiscal year 2004 financial transactions, the 

Commission has taken a number of corrective actions to improve its internal control 

and overall accountability. Specifically, we found that the Commission has taken the 

following actions: 

• maintains appropriate documentation for financial transactions, including 

biweekly time sheets for the Commission’s employee; 

 12Generally accepted auditing standards require the auditor to send a letter of audit inquiry to the

entity's legal counsel. A response to this letter is the auditor's primary means of obtaining 

corroboration of the information furnished by management concerning litigation, claims, and 

assessments. Evidential matter obtained from legal counsel with whom the entity consulted during the 

period under audit may provide the auditor with the necessary corroboration. Legal counsel for the 

Commission did not respond to the auditor’s letter of audit inquiry because the Commission did not 

have a memorandum of understanding in place with VA, which provided legal counsel during fiscal 

year 2005. 

13GAO-05-791R.

Page 6 GAO-07-61R Commission on the National Moment of Remembrance 
• solicits offers from three commercial vendors before purchasing goods or 

services for an amount expected to exceed the $2,500 micropurchase 

threshold for federal procurements;14

• strengthened procedures for the preparation of travel vouchers to ensure that 

allowable rates established by federal regulation are not exceeded;15

• obtained and retained documentation for all cash and in-kind donations; and 

• discontinued the listing of No Greater Love’s e-mail address and fax number 

on the Commission’s business cards to assist in furthering the distinction 

between the Commission and No Greater Love. 

We have determined that through its actions, the Commission has effectively 

addressed most of the issues that gave rise to our recommendations. However, the 

Commission has not implemented adequate procedures to timely reconcile the 

Commission’s financial data to the financial records maintained by its accounting 

services provider. The enclosure provides a list of all financial management-related 

recommendations we made to the Commission in our prior audits of its financial 

transactions, the actions taken by the Commission in response to our 

recommendations, and the status of those recommendations based on our review. 

Agency Comments 

We provided a draft of our report to the Commission for review and comment. The 

Commission agreed with the results presented in the report. 

– – – – 

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

of the Senate Committee on Appropriations and the House Committee on 

Appropriations; the Chairman of the White House Commission on the National 

Moment of Remembrance; the Secretary of Veterans Affairs; the Director, Office of 

Management and Budget; and other interested parties. This report is also available at 

no charge on the GAO Web site at http://www.gao.gov. 

 14See the Federal Acquisition Regulation on simplified acquisition procedures, codified, in part, at 48

C.F.R. § 13.104(b)(2004). 

15The Federal Travel Regulation implements statutory requirements and executive branch policies for 

travel by federal civilian employees. It is promulgated by the General Services Administration and 

codified at 41 C.F.R., chapters 300-304.

Page 7 GAO-07-61R Commission on the National Moment of Remembrance 
If you or your staff have any questions, please contact me at (202) 512-3406 or by email at sebastians@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

Contributors to this report were Julie T. Phillips, Assistant Director, and Peggy J. 

Smith. 

Steven J. Sebastian 

Director 

Financial Management and Assurance 

Enclosure 

Page 8 GAO-07-61R Commission on the National Moment of Remembrance 
Enclosure I

Status of GAO Recommendations from Prior Audits

Count

Recommendations from 

GAO-05-791R

Status per Commission on the National Moment of 

Remembrance (Commission) Status per GAO

1 Prepare biweekly time sheets and 

regularly submit them to the 

Department of Veterans Affairs (VA) 

for approval and processing as 

evidence of actual hours worked.

As of May 2, 2005, the Commission's employee has 

been submitting biweekly time sheets to the financial 

services provider.

Closed. We verified that the 

Commission's employee 

submitted biweekly time sheets to 

the financial services provider.

2 Strengthen the procedures to ensure 

that appropriate documentation for all 

financial transactions--including 

payroll, payroll-related, and 

intragovernmental transactions--is 

maintained and readily available for 

review.

For fiscal year 2005, the Commission made sure to 

maintain and have available in its office all appropriate 

documentation related to its financial transactions. In 

addition, the Commission requested from its financial 

services provider submission by fax on a monthly basis 

of all documents supporting payroll, payroll-related, and 

intragovernmental transactions.

Closed. The Commission 

appropriately documented 

financial transactions, including 

payroll, payroll-related, and 

intragovernmental transactions.

3 Assess the cost of VA's services to 

determine if comparable services may 

be available from other sources at a 

lower cost.

To ensure the Commission was not overpaying for 

financial services, it looked into comparable services 

vendors. In the meantime, and after review of GAO's 

fiscal year 2004 report on the Commission, VA Financial 

Services offered the Commission a contract for fiscal 

year 2006 with a $10,000 reduction in the annual service 

fee.

Closed. The Commission 

negotiated with VA Financial 

Services for a significant reduction 

in its annual service fee.

4 Establish procedures to (1) timely 

reconcile, on a monthly basis, the 

Commission's financial data to the 

financial records maintained by its 

accounting services provider, VA, and 

(2) communicate all differences to VA 

as the provider so that the two entities' 

records can be appropriately 

reconciled.

The Commission and VA Financial Services have now 

established new procedures to reconcile records 

appropriately and on a monthly basis. For fiscal year 

2005, the Commission communicated all differences to 

its financial services provider. In addition, all past 

transactions were reconciled as noted in GAO-05-791R 

(p. 2): "In May 2005, the Commission and VA reconciled 

their records and made accounting adjustments for the 

differences." 

Open. The Commission's yearend trial balance did not reconcile 

to the financial statements 

prepared by its accounting 

services provider (VA).

5 While continuing to use VA's services, 

code all invoices in accordance with 

VA guidelines to indicate the type of 

expenditure prior to submitting them to 

VA for processing.

For fiscal year 2005, the Commission has been coding 

all invoices in accordance with the financial service 

provider's guidelines.

Closed. We verified that the 

Commission is now coding all 

invoices in accordance with VA's 

guidelines.

6 Solicit offers or quotes from at least 

three commercial vendors when 

goods or services are expected to 

exceed the $2,500 micropurchase 

threshold for federal procurements 

and when otherwise required by the 

Federal Acquisition Regulation (FAR).

For fiscal year 2005, the Commission solicited offers 

from three commercial vendors before purchasing goods 

or services for an amount expected to exceed the $2,500 

micropurchase threshold for federal procurements and 

when otherwise required by the FAR.

Closed. We verified that the 

Commission is now soliciting 

offers from three commercial 

vendors before purchasing goods 

or services for an amount 

expected to exceed the $2,500 

micropurchase threshold for 

federal procurements and when 

otherwise required by the FAR.

7 Strengthen procedures over preparing 

travel vouchers by (1) adhering to 

allowable rates in accordance with 

federal regulations and (2) ensuring 

that travel-related overcharges and 

traveler reimbursements are timely 

collected or offset against amounts 

due.

During fiscal year 2005, the Commission worked with VA 

Financial Services to strengthen its procedures for 

preparing travel vouchers. Both entities now make sure 

the Commission adheres to allowable rates in 

accordance with federal regulations while it ensures that 

all travel-related overcharges and traveler 

reimbursements are timely collected or offset against 

amounts due.

Closed. The Commission's 

employee took one business trip 

during fiscal year 2005. We 

reviewed the documentation for 

that trip and concluded that the 

Commission adhered to allowable 

rates per federal travel 

regulations.

8 Strengthen procedures over cash 

donations by immediately obtaining 

and retaining documentation that 

evidences the purpose and intent of 

the donation.

For fiscal year 2005, all cash and in-kind donations are 

supported. All documents concerning cash and in-kind 

donations are now immediately requested and filed with 

other donations made to the Commission.

Closed. We verified that the 

Commission is retaining 

documentation that evidences the 

purpose and intent of donations.

GAO-07-61R Commission on the National Moment of Remembrance
Enclosure I

Status of GAO Recommendations from Prior Audits

Count

Recommendations from 

GAO-05-791R

Status per Commission on the National Moment of 

Remembrance (Commission) Status per GAO

9 Develop procedures to obtain and 

retain supporting documentation for 

the estimated value of in-kind 

donations and require that the 

financial information be recorded.

The Commission now asks for all companies donating inkind to provide documentation to support their donations. 

This documentation is maintained in the Commission's 

office and recorded in the Commission's electronic log.

Closed. The Commission 

obtained the proper 

documentation for all in-kind 

donations received during fiscal 

year 2005.

10 Discontinue listing No Greater Love's 

e-mail address and fax number on the 

Commission's business cards to 

assist in furthering the distinction of 

the Commission's and No Greater 

Love's management and activities.

The Commission received new business cards. The 

Commission would also like to reiterate what was stated 

in the 2004 GAO report: "No Greater Love still donates 

the time of one of its employees to the Commission; as 

of the end of June 2004, both entities have separate 

facilities, and separate phones and fax numbers. The 

White House Commission on the National Moment of 

Remembrance and No Greater Love are two different 

entities and their purposes are different. None of No 

Greater Love's programs were supported by the 

Commission."

Closed. The Commission's 

business cards no longer include 

the e-mail address and fax 

number for No Greater Love.

Source: GAO.

(196110)

GAO-07-61R Commission on the National Moment of Remembrance
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