Page 1 GAO-06-70R GSA Fiscal Year 2003 Restatement 

United States Government Accountability Office

Washington, DC 20548 

December 6, 2005 

Ms. Kathleen M. Turco 

Chief Financial Officer 

General Services Administration 

The Honorable Brian D. Miller

Inspector General 

General Services Administration 

Subject: Financial Audit: Restatement to the General Services 

Administration’s Fiscal Year 2003 Financial Statements

As you know, the Secretary of the Treasury, in coordination with the Director of the 

Office of Management and Budget (OMB), is required to annually prepare and submit 

audited financial statements of the U.S. government to the President and Congress. 

We are required to audit these consolidated financial statements (CFS) and report on 

the results of our work.1

 An issue meriting concern and close scrutiny that emerged 

during our fiscal year 2004 CFS audit was the growing number of Chief Financial 

Officers (CFO) Act agencies that restated2

 certain of their financial statements for 

fiscal year 2003 to correct errors.3

 Errors in financial statements can result from 

mathematical mistakes, mistakes in the application of accounting principles, or 

oversight or misuse of facts that existed at the time the financial statements were 

prepared. Frequent restatements to correct errors can undermine public trust and 

confidence in both the entity and all responsible parties. Further, when restatements 

do occur, it is important that financial statements clearly communicate, and readers 

of the restated financial statements understand, that the financial statements 

originally issued by management in the previous year and the opinion thereon should 

 

1

The Government Management Reform Act of 1994 has required such reporting, covering the executive 

branch of government, beginning with financial statements prepared for fiscal year 1997. 31 U.S.C. § 

331 (e). The federal government has elected to include certain financial information on the legislative 

and judicial branches in the CFS as well. 

2

A financial statement restatement occurs when an entity either voluntarily or prompted by its auditors 

or regulators revises public financial information that has previously been reported. 

3

According to Federal Accounting Standards Advisory Board, Statement of Federal Financial 

Accounting Standards (SFFAS) No. 21, Reporting Corrections of Errors and Changes in Accounting 

Principles, prior period financial statements presented should be restated only to correct errors that 

caused such statements to be materially misstated. 
Page 2 GAO-06-70R GSA Fiscal Year 2003 Restatement 

 

no longer be relied on and instead the restated financial statements and related 

auditor’s opinion should be used. 

Eleven of the 23 CFO Act agencies4

 restated certain of their financial statements for 

fiscal year 2003. Five CFO Act agencies had restatements in fiscal year 2003 covering 

their fiscal year 2002 financial statements. Three CFO Act agencies had restatements 

covering both years. We noted that the extent of the restatements to CFO Act 

agencies’ fiscal year 2003 financial statements varied from agency to agency, ranging 

from correcting two line items on one agency’s balance sheet to correcting numerous 

line items on several of another agency’s financial statements. In some cases, the net 

operating results of the agency were affected by the restatement. The amounts of the 

agencies’ restatements ranged from several million dollars to more than $91 billion. 

Nine of the 11 agencies that had restatements for fiscal year 2003 received unqualified 

opinions on their originally issued fiscal year 2003 financial statements. The auditors 

for 6 of these 9 agencies issued unqualified opinions on the restated financial 

statements, replacing the previous unqualified opinions on the respective agencies’ 

original fiscal year 2003 financial statements. The auditors for 2 of these 9 withdrew 

their unqualified opinions on the fiscal year 2003 financial statements and issued 

other than unqualified opinions on the respective agencies’ restated fiscal year 2003 

financial statements because they could not determine whether there were any 

additional misstatements and the effect of any such misstatements on the restated 

fiscal year 2003 financial statements. For the remaining agency, the principal auditor 

of the agency’s fiscal year 2004 financial statements was not the principal auditor of 

the agency’s fiscal year 2003 financial statements, and an audit opinion on the 

agency’s restated fiscal year 2003 financial statements was not issued. 

Our review focused on the 9 agencies with restatements for fiscal year 2003 that 

received unqualified opinions on their originally issued fiscal year 2003 financial 

statements.5

 These were the Department of Agriculture, Department of State, 

Department of Justice, Department of Transportation, Department of Health and 

Human Services, General Services Administration (GSA), National Science 

Foundation, Nuclear Regulatory Commission, and Office of Personnel Management. 

Because of the varying nature and circumstances surrounding the restatements, we 

are issuing a number of separate reports on the matter. This report communicates 

our observations regarding GSA’s fiscal year 2003 restatement. Going forward, we 

hope that the lessons learned from the fiscal year 2003 restatement, together with our 

4

The Federal Emergency Management Agency (FEMA) was transferred to the Department of 

Homeland Security (DHS) effective March 1, 2003. With this transfer, FEMA was no longer required to 

prepare and have audited stand-alone financial statements under the CFO Act, leaving 23 CFO Act 

agencies for the remainder of fiscal year 2003 and for fiscal year 2004. The DHS Financial 

Accountability Act, Pub. L. No. 108-330, 118 Stat. 1275 (Oct. 16, 2004), added DHS to the list of CFO Act 

agencies, increasing the number of CFO Act agencies again to 24 beginning in fiscal year 2005. 

5

The 2 agencies that had restatements for fiscal year 2003 but did not receive unqualified opinions on 

their originally issued fiscal year 2003 financial statements were the Department of Defense and the 

Small Business Administration. 
Page 3 GAO-06-70R GSA Fiscal Year 2003 Restatement 

 

recommendations, will help GSA and its auditor avoid the need for restatements to 

GSA’s future financial statements. 

We reviewed four key areas with respect to the restatement of GSA’s fiscal year 2003 

financial statements: (1) the nature and cause of the errors that necessitated the 

restatement, including planned corrective actions by the agency and its auditors; (2) 

the timing of communicating the material misstatement to users of the financial 

statements; (3) the extent of transparency6

 exhibited in disclosing the nature and 

impact of the material misstatement in the financial statements and the reissued 

auditor’s report; and (4) audit issues that contributed to the failure to detect the 

errors that necessitated the restatement during the audit of the agency’s fiscal year 

2003 financial statements. 

Results in Brief

Improperly transferring costs related to one major construction project out of the 

Construction in Process (CIP)7

 account and into the Buildings account led to the 

material misstatement that necessitated the restatement of two separate and distinct 

line items on GSA’s originally issued fiscal year 2003 Balance Sheet. Specifically, at 

fiscal year 2003 year end, GSA recorded an adjusting journal entry to transfer about 

$952 million of construction costs from the CIP account to the Buildings account. 

This amount was derived based on a statistical sample of construction projects 

included in GSA’s unadjusted year-end balance for the CIP account. The largest 

project included in GSA’s statistical sample was a multiphase project totaling about 

$68.6 million, which was incorrectly classified as substantially complete8

 at that time. 

This incorrect classification, when projected to the population of CIP projects, was 

the basis for about $921 million of the $952 million, or over 96 percent, of the 

estimated costs transferred at year end. 

GSA’s auditor did not detect the error because its fiscal year 2003 audit tests were not 

adequately designed to test the validity of GSA’s transfers of construction costs 

between the two accounts. Although the journal entry used to record the transfer 

between the accounts involved a material amount and GSA’s contracted independent 

public accountant (IPA) had reported a reportable condition relating to CIP transfers 

in its previous two years audit reports, in our view, the IPA did not adequately 

understand the significant components underlying this journal entry. As a result, the 

IPA randomly selected 10 projects from GSA’s statistical sample of 99 projects and 

6

Transparency is the full, accurate, and timely disclosure of information. 

7

The United States General Ledger uses the term Construction in Progress, but GSA presents this 

account as Construction in Process in the fiscal year 2003 financial statements. We will use the term 

Construction in Process (CIP) to refer to the account. 

8

According to the IPA’s Property Cycle memorandum, GSA defines substantial completion as the date 

when GSA can use the constructed item for its intended use. Substantial completion is not equivalent 

to the completion date for the contract. Substantial completion is also the date for the transfer of the 

project from the work in process account to the Buildings account. 
Page 4 GAO-06-70R GSA Fiscal Year 2003 Restatement 

 

did not review the above noted project that GSA had incorrectly classified. Further, in 

our view, the title of GSA’s note disclosure of the restatement could be 

misinterpreted. 

We are recommending that GSA’s CFO ensures that GSA fully and effectively 

implements control procedures to properly transfer costs from the CIP account to the 

Buildings account. We are also making a recommendation to GSA’s Inspector General 

to work with the IPA so that audit procedures to sufficiently test for any similar 

errors in the transfer of amounts from the CIP account to the Buildings account in the 

future are implemented. 

GSA, along with its Inspector General concurred with our recommendations for 

ensuring reliable balances in the CIP and Buildings accounts. In separate responses 

on a draft of this report, they described the accounting and auditing procedures 

planned to avoid similar restatements of this nature in the future. 

Background

In conducting the fiscal year 2004 audit of the CFS, we reviewed the 23 CFO Act 

agencies’ performance and accountability reports for possible restatements and 

identified 11 agencies that had restated certain of their audited fiscal year 2003 

financial statements. 

The primary intended users of federal agencies’ financial reports are citizens, 

Congress, federal executives, and federal program managers.9

 Each of these groups 

may use federal agencies’ financial statements to satisfy their specific needs. Citizens 

are interested in many aspects of the federal government, particularly federal 

programs that affect their financial well-being. Congress is interested in monitoring 

and assessing the efficiency and effectiveness of federal programs. Federal 

executives, such as central agency officials at OMB and the Department of the 

Treasury (Treasury), are interested in federal financial statements to assist the 

President of the United States. OMB assists the President in overseeing the 

preparation of the federal budget by formulating the President’s spending plans, 

evaluating the effectiveness of agency programs, assessing competing funding 

demands among agencies, and setting funding priorities. Treasury assists the 

President in managing the finances of the federal government and prepares the CFS, 

which is based on audited financial statements prepared by federal agencies. GAO 

audits the CFS and reports on the results of its audit. Finally, federal program 

managers use agency financial statements as tools for managing their operations 

within the limits of the spending authority granted by Congress. 

The primary accounting and auditing standards that apply to restatement disclosures 

by federal entities are the Federal Accounting Standards Advisory Board’s Statement 

of Federal Financial Accounting Standards (SFFAS) No. 21, Reporting Corrections of 

9

Federal Accounting Standards Advisory Board, Statement of Federal Financial Accounting Concepts 

No. 1, Objectives of Federal Financial Reporting. 
Page 5 GAO-06-70R GSA Fiscal Year 2003 Restatement 

 

Errors and Changes in Accounting Principles, and the American Institute of 

Certified Public Accountants (AICPA) Codification of Auditing Standards, AU section 

561, Subsequent Discovery of Facts Existing at the Date of the Auditor’s Report.

10

Objective, Scope, and Methodology 

The objective of our review of the restatement of GSA’s fiscal year 2003 financial 

statements was to determine the nature and cause of the errors, the transparency and 

timing of communicating the material misstatements, any audit issues relating to 

such misstatements, and any actions being taken to help preclude similar errors from 

occurring in the future. 

We reviewed the nature and causes of the restatement, and we also examined 

corrective action plans to be implemented by GSA to help preclude similar errors 

from occurring in the future. We interviewed the preparers and auditors of GSA’s 

fiscal year 2003 financial statements, including staff from the agency’s Office of 

Inspector General (OIG), and we obtained and reviewed relevant audit 

documentation. Our work was not designed to and we did not test the accuracy or 

appropriateness of the restatement.

In our review, we considered certain accounting and auditing standards, including 

SFFAS No. 21; the Financial Accounting Standards Board’s Statement of Financial 

Accounting Standards No. 16, Prior Period Adjustments; and the AICPA Codification 

of Auditing Standards, AU section 420, Consistency of Application of Generally 

Accepted Accounting Principles, AU section 508, Reports on Audited Financial 

Statements, and AU section 561. 

We performed our review of the restatement of GSA’s fiscal year 2003 financial 

statements from December 2004 to October 2005 in accordance with U.S. generally 

accepted government auditing standards. 

We requested comments on the draft of this report from GSA’s CFO and Inspector 

General or their designees. Written comments from GSA’s Acting Administrator and 

Inspector General are reprinted in enclosures I and II, respectively, and are also 

discussed in the Agency Comments section. 

Issues Related to Restatement of GSA’s Fiscal Year 2003 Balance Sheet 

With respect to the restatement of GSA’s fiscal year 2003 Balance Sheet, we identified 

the following three areas that need improvement: (1) identification of substantially 

complete CIP transfers, (2) design of audit procedures relating to adjusting journal 

10Generally accepted government auditing standards incorporate AICPA reporting standards and 

Statements on Auditing Standards unless the Comptroller General of the United States excludes them 

by formal announcement. 
Page 6 GAO-06-70R GSA Fiscal Year 2003 Restatement 

entries used to transfer amounts from the CIP account, and (3) the title of the note 

disclosure of the restatement. These issues are discussed in detail below. 

Adjustment to CIP and Buildings Accounts Were Erroneous

GSA’s Balance Sheet for fiscal year 2003 was restated because of an error in the 

adjusting journal entry that was used to transfer approximately $952 million of 

estimated costs from the CIP account to the Buildings account. The error caused the 

Buildings line item on the Balance Sheet to be materially overstated by approximately 

$921 million and the CIP line item on the Balance Sheet to be materially understated 

by this same amount. 

The CIP general ledger account includes construction of, and major improvements 

and renovation projects to, buildings that GSA owns and leases to other federal 

entities. Upon substantial completion, certain costs are to be transferred to the 

appropriate Property and Equipment (P&E) asset account. The transfer from the CIP 

account to the appropriate P&E account is necessary for proper classification of 

assets in the Balance Sheet as well as accurate and complete reporting of 

depreciation expenses. Depreciation is not calculated and recorded until the asset is 

transferred from CIP to the appropriate asset account. 

When a new CIP project is established, regional personnel are expected to enter all 

necessary information, including the expected date of completion into the Inventory 

Reporting Information System (IRIS) that GSA management uses to monitor the 

status of construction projects. Construction costs are accumulated in the CIP 

account. Once a project is substantially complete, the project manager is supposed to 

enter the date of substantial completion into IRIS so that the CIP account project 

costs will be automatically transferred into the Real Property Accounting 

Depreciation System (RPADS). Also, building projects that meet certain capitalization 

criteria and are determined to have been substantially completed during the reporting 

period should be transferred to the Buildings account from the CIP account. 

Transfers of the costs of substantially completed projects from the CIP to the 

appropriate P&E account are necessary for proper classification of the related assets 

in the Balance Sheet. For fiscal year 2003, GSA’s net Buildings account and CIP 

account totaled about 52 percent of its total assets. However, according to the IPA’s 

fiscal year 2004 Report on Internal Control, since fiscal year 2001, GSA has 

experienced problems related to cost transfers from CIP to the appropriate P&E 

account. Specifically, the IPA’s report noted that GSA’s Public Buildings Service 

(PBS) controls over transferring substantially complete CIP projects continue to need 

improvement. 

GSA has been aware that weaknesses in these processes can lead to the failure to 

recognize the completion of construction projects on a timely basis. Among the 

causes of the underlying weaknesses previously reported by GSA’s auditor are 

regional personnel not entering completion dates in IRIS, and manual procedures 

performed by central staff not addressing all CIP issues. In order to mitigate these 

control weaknesses, each quarter GSA’s PBS uses a random statistical sample to 
Page 7 GAO-06-70R GSA Fiscal Year 2003 Restatement 

assess the accuracy of data in its RPADS and makes an adjusting journal entry to 

correct for any errors for reporting purposes.

Based on PBS’s review of a statistical sample of projects still classified in IRIS as CIP 

at the end of fiscal year 2003, GSA recorded an adjusting journal entry to transfer 

about $952 million of estimated costs from the CIP account to the Buildings account. 

In September 2004, during GSA’s OIG review of GSA’s quarterly financial statements, 

the OIG discovered an error in the agency’s classification of the largest project 

included in GSA’s end of fiscal year 2003 statistical sample. Specifically, the OIG 

found that PBS incorrectly classified a $68.6 million multiphase project from the 

fiscal year 2003 CIP sample as substantially complete when it should have remained 

in CIP. PBS identified the multiphase project as substantially complete without 

obtaining written documentation from the region responsible for the project to 

support such a determination. This incorrect classification, when projected to the 

population of CIP projects, was the basis for about $921 million of the approximately 

$952 million of the estimated costs that were transferred. As a result, GSA’s adjusting 

journal entry to transfer approximately $952 million in estimated costs from the CIP 

account to the Buildings account was overstated by about $921 million. GSA’s OIG 

communicated the error to GSA management and to the IPA in September 2004, 

which was appropriate. After researching the issue, GSA management concurred that 

the error warranted an adjustment to restate the CIP and Buildings line items on the 

fiscal year 2003 Balance Sheet. 

To reduce the risk of similar errors in the future, GSA officials told us that GSA has 

refined its methodology for determining the CIP transfer amounts. Starting with fiscal 

year 2005, GSA will semi-annually review all of the CIP projects over $7 million and 

statistically sample the remaining lower cost CIP projects to develop an adjusting 

journal entry, if necessary. In addition, according to GSA’s Corrective Action Plan, 

GSA intends to improve its controls over transferring substantially complete CIP 

projects by enforcing its control procedures at the project level to ensure that all 

substantially complete and only substantially complete CIP projects are transferred 

out of the CIP account. GSA’s plan calls for GSA regions to make entries into a 

weekly nationwide CIP Progress Report to certain GSA officials regarding the 

number of projects: (1) with no substantial completion date, (2) with substantial 

completion dates in the past, and (3) marked to be completed in the current month. 

In addition, according to GSA’s Plan, PBS intends to work with regions to develop 

regional action plans that enforce entering timely substantial completion dates at the 

project level. 

Auditor’s Procedures Were Not Adequately Designed to Detect Error in the Transfer 

of CIP Costs

The above-noted error was not discovered during the audit of GSA’s fiscal year 2003 

financial statements because the fiscal year 2003 audit procedures performed by 

GSA’s IPA were not adequately designed to detect the error. The journal entry used to 

record the transfer between the accounts involved a material amount and GSA’s IPA 

had reported a reportable condition relating to CIP transfers in its previous two years 

audit reports. In addition, as noted above, over 96 percent of the estimated costs that 

were transferred resulted from the incorrectly classified multiphase project. 
Page 8 GAO-06-70R GSA Fiscal Year 2003 Restatement 

Nevertheless, the IPA randomly selected 10 projects from GSA’s statistical sample of 

99 projects and did not review the largest cost project in the sample, which is the 

above noted project that GSA had incorrectly classified. 

The Financial Audit Manual (FAM)11 states that during the audit planning process, 

the auditor should identify conditions that significantly increase inherent, fraud, and 

control risk. Among other things, the auditor should perform procedures to identify 

account balances and transactions that might signal inherent risk. According to FAM 

260.40, the auditor should obtain an understanding of the financial reporting process 

and the controls over journal entries and other adjustments; identify and select 

journal entries and other adjustments for testing; determine the nature, timing, and 

extent of the testing; and inquire of individuals involved in the financial reporting 

process about inappropriate or unusual activity related to the processing of journal 

entries and adjustments. In our view, if the IPA had had a better understanding of the 

significant components of the calculations used to determine the material adjusting 

journal entry that transferred construction costs from the CIP account to the 

Buildings account and had then designed and performed sufficient audit procedures 

over such components, the error that necessitated the restatement might have been 

detected. 

According to GSA’s IPA, future audits will include testing more projects from GSA’s 

sample. Specifically, the IPA intends to increase the sample size from 10 to about 45. 

Given the known risks in this area, it will be important for the IPA to perform 

adequate audit procedures over any significant adjusting journal entries made by GSA 

to transfer CIP costs. 

The Title of GSA’s Note Disclosure of the Restatement Could Be Misinterpreted

The notes to GSA’s comparative fiscal years 2004 and 2003 financial statements 

included a note disclosure titled “Prior Period Reclassification.” In our view, this title 

could be misinterpreted, since the note disclosure discussed the adjustment to 

correct the $921 million material misstatement and the adjustment represented a 

restatement as defined by SFFAS No. 21 rather than a prior period reclassification. 

Conclusions 

The restatement was caused by an error that GSA’s OIG identified. GSA corrected the 

error and issued restated financial statements. Going forward, the key will be for GSA 

to ensure that the planned corrective actions established to help prevent future errors 

in the transfer of CIP costs are fully and effectively implemented. In addition, it will 

be important that GSA’s OIG work with GSA’s IPA so that audit procedures to detect 

any similar errors in the future are fully and effectively implemented. 

 

11GAO/President’s Council on Integrity and Efficiency, Financial Audit Manual, GAO-01-765G 

(Washington, D.C.: July 2001), updated by GAO-04-1015G and GAO-04-924G (July 2004). 
Page 9 GAO-06-70R GSA Fiscal Year 2003 Restatement 

Recommendations for Executive Action 

We recommend that GSA’s Chief Financial Officer ensure that GSA fully and 

effectively implements control procedures to properly transfer costs from the CIP 

account to the Buildings account. 

We recommend that GSA’s Inspector General, work with GSA’s IPA so that audit 

procedures to sufficiently test adjusting journal entries related to the transfer of 

amounts from the CIP account to the Buildings account are fully and effectively 

implemented. 

Agency Comments 

In commenting on a draft of this report, GSA’s Acting Administrator stated that GSA 

concurs with our recommendation to implement control procedures to properly 

transfer costs from the CIP account to the Buildings account and has made changes 

in the statistical sample process as we acknowledged in our report. He also stated 

that GSA developed a weekly report that is sent to the regional offices to highlight the 

CIP projects where the estimated substantial completion date is overdue, missing, or 

scheduled to occur within 30 days to assist in ensuring the CIP projects are 

accurately capitalized and depreciated in a timely fashion. GSA’s Inspector General 

concurred with our recommendation and stated that his office will continue to work 

with the IPA regarding auditing the transfer of CIP to the Buildings account and that 

since fiscal year 2003, the IPA’s testing in this area has expanded to reduce the 

likelihood that a similar error would occur in the future. He also stated that his office 

will continue to monitor the IPA’s efforts to plan and perform its tests of the adjusting 

journal entries related to the transfer of amounts from the CIP account to the 

Buildings account. 

- - - - - 

Within 60 days of the date of this report, we would appreciate receiving a written 

statement on actions taken to address these recommendations. 

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

of the Senate Committee on Homeland Security and Governmental Affairs; the 

Subcommittee on Federal Financial Management, Government Information, and 

International Security, Senate Committee on Homeland Security and Governmental 

Affairs; the House Committee on Government Reform; and the Subcommittee on 

Government Management, Finance and Accountability, House Committee on 

Government Reform. In addition, we are sending copies to the Fiscal Assistant 

Secretary of the Treasury and the Controller of OMB. This report is also available at 

no charge on GAO’s Web site at www.gao.gov. 
Page 10 GAO-06-70R GSA Fiscal Year 2003 Restatement 

We appreciate the courtesy and cooperation extended to us by your staff throughout 

our work. We look forward to continuing to work with your offices to help improve 

financial management in the federal government. If you have any questions about the 

contents of this report, please contact me at (202) 512-3406 or engelg@gao.gov. 

Gary T. Engel 

Director 

Financial Management and Assurance 
Page 11 GAO-06-70R GSA Fiscal Year 2003 Restatement 

Enclosure I: Comments from the Acting Administrator, General Services Administration 
Page 12 GAO-06-70R GSA Fiscal Year 2003 Restatement 

Enclosure I 
Page 13 GAO-06-70R GSA Fiscal Year 2003 Restatement 

Enclosure II: Comments from the Inspector General, General Services Administration

(198396)
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