Heritage Assets and Stewardship Land 

Federal Accounting Standards Advisory Board 

 Statement of Federal Financial Accounting Standards 29 

July 7, 2005 

____________________________________________________________________ 
THE FEDERAL ACCOUNTING STANDARDS ADVISORY BOARD 

The Federal Accounting Standards Advisory Board (FASAB or "the Board") was established 

by the Secretary of the Treasury, the Director of the Office of Management and Budget 

(OMB), and the Comptroller General in October 1990. It is responsible for promulgating 

accounting standards for the United States Government. These standards are recognized as 

generally accepted accounting principles (GAAP) for the Federal Government. 

An accounting standard is typically formulated initially as a proposal after considering the 

financial and budgetary information needs of citizens (including the news media, state and 

local legislators, analysts from private firms, academe, and elsewhere), Congress, Federal 

executives, Federal program managers, and other users of Federal financial information. The 

proposed standard is published in an Exposure Draft for public comment. In some cases, a 

discussion memorandum, invitation for comment, or preliminary views document may be 

published before an exposure draft is published on a specific topic. A public hearing is 

sometimes held to receive oral comments in addition to written comments. The Board 

considers comments and decides whether to adopt the proposed standard, with or without 

modification. After review by the three officials who sponsor FASAB, the Board publishes 

adopted standards in a Statement of Federal Financial Accounting Standards. The Board 

follows a similar process for Interpretations and also for Statements of Federal Financial 

Accounting Concepts, which guide the Board in developing accounting standards and 

formulating the framework for Federal accounting and reporting. 

Additional background information is available from the FASAB or its website: 

 • “Memorandum of Understanding among the General Accounting Office, the 

Department of the Treasury, and the Office of Management and Budget, on Federal 

Government Accounting Standards and a Federal Accounting Standards Advisory 

Board” 

 • “Mission Statement: Federal Accounting Standards Advisory Board” 

Exposure drafts, Statements of Federal Accounting Standards and Concepts, Interpretations, 

FASAB newsletters, and other items of interest are posted on FASAB’s website, at 

www.fasab.gov. 

Federal Accounting Standards Advisory Board 

441 G Street, NW, Suite 6814 

Mailstop 6K17V 

Washington, DC 20548 

Telephone (202) 512-7350 

Fax (202) 512-7366 

www.fasab.gov
Summary 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

Summary 

This standard changes the classification of information reported for heritage assets and 

stewardship land provided by Statement of Federal Financial Accounting Standards 8. This 

standard reclassifies all heritage assets and stewardship land information as basic except for 

condition information, which is reclassified as required supplementary information (RSI). This 

standard requires that entities reference a note on the balance sheet that discloses information 

about heritage assets and stewardship land, but no asset dollar amount should be shown. 

Instead, the note disclosure provides minimum reporting requirements consistent with the 

previous standards for heritage assets and stewardship land. These requirements include a 

description of major categories, physical unit information for the end of the reporting period, 

physical units added and withdrawn during the year, a description of the methods of acquisition 

and withdrawal, and condition information. 

This standard also requires two new disclosures for heritage assets and stewardship land. 

Specifically, this standard requires additional reporting disclosures about entity stewardship 

policies and an explanation of how heritage assets and stewardship land relate to the mission of 

the entity. 

This standard also includes the requirements for the U.S. Government-wide Financial 

Statement. It provides for a general discussion and directs users to the applicable entities’ 

financial statements for more detailed information on heritage assets and stewardship land. 

This standard amends several existing standards. The amendments rescind certain standards 

or parts of certain standards due to the classification change, as well as serve as a means to 

incorporate all standards specific to heritage assets and stewardship land into one document. 
Table of Contents 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

Heritage Assets and Stewardship Land 

Table of Contents 

Introduction ................................................................................................................................. 1

Standards of Federal Financial Accounting....................................................................... 3

Heritage Assets (including Multi-use Heritage Assets).......................................... 3

Amendments to Existing Standards.......................................................................... 3

Definitions ................................................................................................................ 3

Recognition and Measurement ................................................................................. 4

Disclosures and Required Supplementary Information ............................................. 5

U.S. Government-wide Financial Statement Disclosures........................................... 7

Stewardship Land...................................................................................................... 8

Amendments to Existing Standards.......................................................................... 8

Definitions ................................................................................................................ 8

Recognition and Measurement ................................................................................. 9

Disclosures and Required Supplementary Information ............................................. 9

U.S. Government-wide Financial Statement Disclosures......................................... 11

Effective Date........................................................................................................... 12

Appendix A: Basis for Conclusions.................................................................................... 13

Introduction.............................................................................................................. 13

Amendments to Standards ..................................................................................... 14

Basic vs. RSI ............................................................................................................ 15

U.S. Government-wide Financial Statement.......................................................... 16

Exposure Draft......................................................................................................... 16

Responses to the ED............................................................................................... 17

Board Consideration of Comments ....................................................................... 18

Importance to Mission............................................................................................. 18

Limiting Information Presented.............................................................................. 19

Categorization and Unitization ............................................................................... 19

Supporting Documentation .................................................................................... 21

Additional Guidance................................................................................................ 21

Effective Date/Phased-In Implementation ............................................................. 22

Materiality................................................................................................................. 23

Board Approval........................................................................................................ 24

Appendix B: List of Abbreviations...................................................................................... 25
Introduction 1 

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Statement of Federal Financial Accounting Standards 

Heritage Assets and Stewardship Land

 

 

Introduction 

1. The required supplementary stewardship information (RSSI) category, as 

described in Statement of Federal Financial Accounting Standards (SFFAS) 8, 

was a response to the unique aspects of the Federal accounting and reporting 

environment, and to the broad objectives of Federal financial reporting. It was 

intended to permit flexibility on the part of preparers and auditors that would 

facilitate reporting relevant, reliable information, including nonfinancial and 

nonhistorical information.1

2. Although some stewardship information may not link directly with the basic 

financial statements because the data to be reported may be other than in dollar 

terms, the Federal Accounting Standards Advisory Board (the Board or FASAB) 

intended that RSSI information would augment the basic financial statements 

and would receive commensurate audit scrutiny. 

3. The Board found, however, that in many cases the word “supplementary” in the 

RSSI title caused certain readers to assume that the information was of 

secondary importance. Since this was contrary to its intentions, the Board 

decided to eliminate the RSSI category and re-categorize the stewardship 

elements within the reporting categories that are well defined in existing 

professional literature and familiar to report users. Additionally, this standard 

clarifies the Board’s expectation that information essential to fair presentation will 

be subject to audit. 

4. The main focus of this standard is the reclassification of heritage assets and 

stewardship land information. This standard reclassifies heritage assets and 

stewardship land information as basic information with the exception of condition 

reporting, which is considered RSI2

. Specifically, this standard requires that 

entities reference a note on the balance sheet that discloses information about 

heritage assets and stewardship land, but no asset dollar amount should be 

 

1 See the Implementation Guide to Statement of Federal Financial Accounting Standards 7: Accounting 

for Revenue and Other Financing Sources, par. 22-24, the diagram on page 15, and minutes of 

associated Board discussions. See also SFFAS 8, Supplementary Stewardship Reporting, par. 21, 34, 

111-115, and minutes of associated Board discussions. 

2 RSI was added to the accounting literature by Statement of Financial Accounting Standards (SFAS) 25, 

Suspension of Certain Accounting Requirements for Oil and Gas Producing Companies, published by the 

Financial Accounting Standards Board (FASB) in 1979. That Statement has been amended, but the RSI 

category continues to be used in a variety of standards published by the FASB, Governmental Accounting 

Standards Board (GASB), and FASAB. The auditor’s responsibility for RSI is discussed in section AU 

558 of the codification of professional auditing standards published by the American Institute of Certified 

Public Accountants (AICPA).
Introduction 2 

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shown. The note disclosure provides minimum reporting requirements 

consistent with the previous standards for heritage assets and stewardship land, 

which includes a description of major categories, physical unit information for the 

end of the reporting period, physical units added and withdrawn during the year, 

a description of the methods of acquisition and withdrawal, and condition 

information. 

5. Although the most significant change within this standard is this reclassification, it 

also introduces certain changes to the disclosure requirements for heritage 

assets and stewardship land. Specifically, the standard requires additional 

reporting disclosures about entity stewardship policies and an explanation of how 

heritage assets and stewardship land relate to the mission of the entity. 

6. This standard also includes disclosure requirements applicable to the U.S. 

Government-wide Financial Statement. This financial statement must provide a 

general discussion of heritage assets and stewardship land and direct users to 

the applicable entities’ financial statements for more detailed information on 

these assets. 

7. This standard also amends several existing standards. The amendments rescind 

certain standards or parts of certain standards due to the classification change, 

as well as serve as a means to incorporate all standards specific to heritage 

assets and stewardship land into one document. 

8. The Board believes by fully incorporating into this standard all requirements for 

heritage assets (including multi-use heritage assets) and stewardship land, 

readers will better understand all reporting requirements. However, the main 

issues deliberated by the Board were the reclassification and presentation of 

heritage assets and stewardship land information. The Board has not 

reconsidered the definition, recognition and measurement provisions of the 

existing standards. These provisions have been brought forward from those 

standards that were based on prior Boards’ conclusions. 

9. The Board developed this standard for heritage assets and stewardship land 

based on the importance of the data in meeting the stewardship reporting 

objective as described in Statement of Federal Financial Accounting Concepts 

(SFFAC) 1, Objectives of Federal Financial Reporting. Further information on 

the Board’s considerations regarding this reclassification is included in the Basis 

for Conclusions. 

 
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Standards of Federal Financial Accounting 

Heritage Assets (including Multi-use Heritage Assets) 

Amendments to Existing Standards

10. SFFAS 6 par. 21 is amended as follows: 

The following paragraphs provide recognition and measurement principles, and 

disclosure requirements for general PP&E. For standards relating to heritage assets, 

multi-use heritage-assets and stewardship land, see SFFAS 29, Heritage Assets and 

Stewardship Land. each category of PP&E. The categories identified are:

• general PP&E (including land acquired for or in connection with other 

general PP&E),

• National Defense PP&E,

• heritage assets, and

• stewardship land (i.e., land not included in general PP&E).

11. SFFAS 6 par. 57 through 65 are rescinded. 

12. SFFAS 8 Chapter 2 (Heritage Assets) is rescinded in its entirety. 

13. SFFAS 14 par. 10 and 11 are rescinded. 

14. SFFAS 16 is rescinded in its entirety. 

Definitions

15. Heritage assets are property, plant and equipment (PP&E) that are unique for 

one or more of the following reasons: 

• historical or natural significance, 

• cultural, educational, or artistic (e.g., aesthetic) importance; or 

• significant architectural characteristics. 

Heritage assets consist of (1) collection type heritage assets, such as objects 

gathered and maintained for exhibition, for example, museum collections, art 

collections, and library collections; and (2) non-collection-type heritage assets, 

such as parks, memorials, monuments, and buildings. 

16. Heritage assets are generally expected to be preserved indefinitely. One 

example of evidence that a particular asset is heritage in nature is that it is listed 

on the National Register of Historic Places. 
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17. Some investments in heritage assets (e.g., national parks) will meet the 

definitions and be considered and reported as both heritage assets and 

stewardship land (see Stewardship Land below). Such reporting would not be 

considered duplication, as the type of information reported for the physical unit 

would be different for each category of stewardship asset. 

18. Heritage assets may in some cases be used to serve two purposes—a heritage 

function and general government operations. In cases where a heritage asset 

serves two purposes, the heritage asset should be considered a multi-use 

heritage asset if the predominant use of the asset is in general government 

operations (e.g., the main Treasury building used as an office building). Heritage 

assets having an incidental use in government operations are not multi-use 

heritage assets; they are simply heritage assets. 

Recognition and Measurement

Heritage Assets 

19. With the exception of multi-use heritage assets (addressed in par. 22) the cost of 

acquisition, improvement, reconstruction, or renovation of heritage assets should 

be recognized on the statement of net cost for the period in which the cost is 

incurred. The cost3

 should include all costs incurred during the period to bring the 

item to its current condition (See par. 26 of SFFAS 6 for examples of the costs to 

be considered). 

20. With the exception of multi-use heritage assets (addressed in par.23) no 

amounts for heritage assets acquired through donation or devise4

 should be 

recognized in the cost of heritage assets.5

 

21. With the exception of multi-use heritage assets (addressed in par.24) transfers of 

heritage assets from one Federal entity to another do not affect the net cost of 

operations or net position of either entity. However, in some cases, assets 

included in general PP&E may be transferred to an entity for use as heritage 

assets. In this instance, the transferring entity should recognize a transfer-out of 

capitalized assets.6

 

 

3 For a full discussion of cost, including full cost, direct cost and indirect cost, see SFFAS 4, Managerial 

Cost Accounting Concepts and Standards for the Federal Government. Also, see par. 94-95, SFFAC 2, 

Entity and Display. 

4 A will or clause of a will disposing of property. 

5 SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 258-259 explains that 

stewardship PP&E is “expensed if purchased, but no amount is recognized if it is received as a donation.” 

6

 SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 74 and par. 345-346. 
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Multi-use Heritage Assets 

22. The cost of acquisition, improvement, reconstruction, or renovation of multi-use 

heritage assets should be capitalized as general PP&E and depreciated over its 

estimated useful life. 

23. Multi-use heritage assets acquired through donation or devise should be 

recognized as general PP&E at the assets' fair value at the time received, and 

the amount should also be recognized as "nonexchange revenues" as defined in 

SFFAS 7, Accounting for Revenue and Other Financing Sources. 

24. Transfers of multi-use heritage assets from one Federal entity to another are 

transfers of capitalized assets. The receiving entity should recognize a transferin as an additional financing source and the transferring entity should recognize a 

transfer-out. The value recorded should be the transferring entity’s book value of 

the multi-use heritage asset. If the receiving entity is not provided the book 

value, the multi-use heritage asset should be recorded at its estimated fair 

value.7

Disclosures and Required Supplementary Information

25. Entities with heritage assets should reference a note8 on the balance sheet that 

discloses information about heritage assets, but no asset dollar amount should 

be shown.9

 The note disclosure related to heritage assets should provide the 

following: 

a. A concise statement explaining how they relate to the mission of the entity. 

b. A brief description of the entity’s stewardship policies for heritage assets. 

Stewardship policies for heritage assets are the goals and principles the entity 

established to guide its acquisition, maintenance, use, and disposal of heritage 

assets consistent with statutory requirements, prohibitions, and limitations 

governing the entity and the heritage assets. 

c. A concise description of each major category of heritage asset. The 

appropriate level of categorization of heritage assets should be meaningful and 

 

7 See SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 74 for a discussion of 

transfers of assets. 

8 This standard does not prescribe a specific reference or line item entitled “Heritage Assets” as it may be 

included with other items for which no dollar amounts are recognized (such as stewardship land and other 

items that in the future may require similar non-financial disclosure) for presentation. Instead, the 

standard allows entities flexibility in determining the best presentation. 

9 No asset dollar amount is shown, except for multi-use heritage assets, which are capitalized and 

reported as part of general PP&E. See par. 22 through 24 and par. 27 for additional explanation. 
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determined by the preparer based on the entity’s mission, types of heritage 

assets, and how it manages the assets. 

d. Heritage assets should be quantified in terms of physical units. The 

appropriate level of aggregation and physical units10 of measure for each major 

category should be meaningful and determined by the preparer based on the 

entity’s mission, types of heritage assets, and how it manages the assets. For 

each major category of heritage asset (identified in c. above) the following should 

be reported: 

1. The number of physical units by major category; major categories 

should be classified by collection or non-collection type heritage assets 

for which the entity is the steward as of the end of the reporting period; 

2. The number of physical units by major category that were acquired and 

the number of physical units by major category that were withdrawn 

during the reporting period; and 

3. A description of the major methods of acquisition and withdrawal of 

heritage assets during the reporting period. This should include 

disclosure of the number of physical units (by major category) of transfers 

of heritage assets between Federal entities and the number of physical 

units (by major category) of heritage assets acquired through donation or 

devise, if material. In addition, the fair value of heritage assets acquired 

through donation or devise during the reporting period should be 

disclosed, if known and material. 

26. Entities should report the condition11 of the heritage assets (which may be 

reported with the deferred maintenance information12) as required supplementary 

information. Entities should include a reference to the condition and deferred 

 

10 Defining physical units as individual items to be counted is neither required nor prohibited. Particularly 

for collection-type heritage assets, it may be more appropriate to define the physical unit as a collection, 

or a group of assets located at one facility, and then count the number of collections or facilities. 

11 Condition is the physical state of an asset. The condition of an asset is based on an evaluation of the 

physical status/state of an asset, its ability to perform as planned, and its continued usefulness. 

Evaluating an asset’s condition requires knowledge of the asset, its performance capacity and its actual 

ability to perform, and expectations for its continued performance. The condition of a long-lived asset is 

affected by its durability, the quality of its design and construction, its use, the adequacy of maintenance 

that has been performed, and many other factors, including: accidents (an unforeseen and unplanned or 

unexpected event or circumstance), catastrophes (a tragic event), disasters (a sudden calamitous event 

bringing great damage, loss, or destruction), and obsolescence. Examples of condition information 

include, among others, (1) averages of standardized condition rating codes; (2) percentage of assets 

above, at, or below acceptable condition; or (3) narrative information. 

12 See SFFAS 6, Chapter 3, Deferred Maintenance (par. 77-84) for information regarding definition, 

measurement and disclosures specific to deferred maintenance. 
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maintenance information13 if reported elsewhere in the report containing the 

basic financial statements. 

27. Entities should disclose that multi-use heritage assets are recognized and 

presented with general PP&E in the basic financial statements and that additional 

information for the multi-use heritage assets is included with the heritage assets 

information. 

U.S. Government-wide Financial Statement Disclosures14

28. The U.S. Government-wide financial statement should reference a note on the 

balance sheet that discloses information about heritage assets, but no asset 

dollar amount should be shown. The note disclosure related to heritage assets 

should provide the following: 

a. A concise statement explaining how they relate to the mission of the Federal 

Government. 

b. A description of the broad categories of heritage assets of the Federal 

Government. 

c. A general reference to agency reports for additional information about heritage 

assets, such as agency stewardship policies for heritage assets, physical units 

by major categories of heritage assets, and the condition of the heritage assets. 

29. The U.S. Government-wide financial statement should disclose that multi-use 

heritage assets are recognized and presented with general PP&E in the basic 

financial statements and that additional information for the multi-use heritage 

assets is included with the heritage assets information. 

 

13 SFFAS 14, Amendments to Deferred Maintenance Reporting Amending SFFAS 6, Accounting for 

Property, Plant and Equipment and SFFAS 8, Supplementary Stewardship Reporting, defined deferred 

maintenance as RSI. The Board believed that a period of experimentation was necessary for deferred 

maintenance information and that classifying it as RSI would be more appropriate during the 

experimentation period. The Board may revise this standard based on experience gained during this time 

and the development of additional criteria. 

14 SFFAS 24, Selected Standards for the Consolidated Financial Report of the United States Government, 

clarified that all existing and future standards apply to all Federal entities, including the U.S. Governmentwide Financial Statement, unless a standard specifically provides otherwise. 
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Stewardship Land 

Amendments to Existing Standards

30. SFFAS 6 par. 66 through 76 are rescinded. 

31. SFFAS 8 Chapter 4 (Stewardship Land) is rescinded in its entirety. 

32. SFFAS 14 par. 10 and 11 are rescinded. 

Definitions

33. Stewardship Land is land and land rights15 owned by the Federal Government 

but not acquired for or in connection with16 items of general PP&E. Examples of 

stewardship land include land used as forests and parks, and land used for 

wildlife and grazing. 

34. “Land” is defined as the solid part of the surface of the earth. Excluded from the 

definition are the natural resources (that is, depletable resources, such as 

mineral deposits and petroleum; renewable resources, such as timber; and the 

outer-continental shelf resources) related to land. 17

35. Land and land rights owned by the Federal Government and acquired for or in 

connection with items of general PP&E should be accounted for and reported as 

general PP&E. 

36. Land and land rights owned by the Federal Government and not acquired for or 

in connection with items of general PP&E should be reported as stewardship 

land. 

 

15 Land rights are interests and privileges held by the entity in land owned by others, such as leaseholds, 

easements, water and water power rights, diversion rights, submersion rights, rights-of-way, mineral 

rights, and other like interests in land.

16 “Acquired for or in connection with" is defined as including land acquired with the intent to construct 

general PP&E and land acquired in combination with general PP&E, including not only land used as the 

foundation, but also adjacent land considered to be the general PP&E's common grounds. 

17 The Board presently has an active project to address standards for natural resources, for which the 

Board is considering developing individual standards for each type of natural resource separately. To 

begin the project, the Board will be addressing oil and gas resources. The framework for the oil and gas 

resource phase of the project will be used as a model when addressing the other types or logical sets of 

natural resources (e.g., timber, grazing land, solid leasable minerals) in subsequent phases of the project. 
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Recognition and Measurement

37. The cost of acquisition of stewardship land should be recognized on the 

statement of net cost for the period in which the cost is incurred. The cost should 

include all costs to prepare stewardship land for its intended use (e.g., razing a 

building). In some cases, land may be acquired along with existing structures. 

The following treatments should apply: 

a. if the structure would be deemed a heritage asset and is significant in and of 

itself, the entity should use its judgment as to whether the acquisition cost should 

be treated as the cost of stewardship land, heritage asset, or both; 

b. if the structure is to be used in operations (for example, as general PP&E) but 

1) the value of the structure is insignificant, or 2) its acquisition is merely a 

byproduct of the acquisition of the land, the cost in its entirety should be treated 

as an acquisition of stewardship land; or 

c. significant structures that have an operating use (e.g., a constructed hotel or 

employee housing block) should be treated as general PP&E by identifying the 

cost attributable to general PP&E and segregating it from the cost of the 

stewardship land acquired. 

38. No amounts for stewardship land acquired through donation or devise18 should 

be recognized in the cost of stewardship land.19 

39. Transfers of stewardship land from one Federal entity to another, does not affect 

the net cost of operations or net position of either entity. However, in some 

cases, land included in general PP&E may be transferred to an entity for use as 

stewardship land. In this instance, the transferring entity should recognize a 

transfer-out of capitalized assets.20 

Disclosures and Required Supplementary Information

40. Entities with stewardship land should reference a note21 on the balance sheet 

that discloses information about stewardship land, but no asset dollar amount 

 

18 A will or clause of a will disposing of property. 19 SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 258-259 explains that 

stewardship PP&E is “expensed if purchased, but no amount is recognized if it is received as a donation.” 

20 SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 74 and par. 345-346. 21 This standard does not prescribe a specific reference or line item entitled “Stewardship Land” as it may 

be included with other items for which no dollar amounts are recognized (such as heritage assets and 

other items that in the future may require similar non-financial disclosure) for presentation. Instead, the 

standard allows entities flexibility in determining the best presentation. 
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should be shown. The note disclosure related to stewardship land should provide 

the following: 

a. A concise statement explaining how it relates to the mission of the entity. 

b. A brief description of the entity’s stewardship policies for stewardship land. 

Stewardship policies for stewardship land are the goals and principles the entity 

established to guide its acquisition, maintenance, use, and disposal of 

stewardship land consistent with statutory requirements, prohibitions, and 

limitations governing the entity and the stewardship land. 

c. A concise description of each major category of stewardship land use. Where 

parcels of land have more than one use, the predominant use of the land should 

be considered the major use. In cases where land has multiple uses, none of 

which is predominant, a description of the multiple uses should be presented. 

The appropriate level of categorization of stewardship land use should be 

meaningful and determined by the preparer based on the entity’s mission, types 

of stewardship land use, and how it manages the assets. 

d. Stewardship land should be quantified in terms of physical units. The 

appropriate level of aggregation and physical units of measure for each major 

category of stewardship land use should be meaningful and determined by the 

preparer based on the entity’s mission, types of stewardship land use, and how it 

manages the assets. For each major category of stewardship land use the 

following should be reported: 

1. The number of physical units by major category of stewardship land use 

for which the entity is the steward as of the end of the reporting period; 

2. The number of physical units by major category of stewardship land use 

that were acquired and the number of physical units by major category of 

stewardship land use that were withdrawn during the reporting period; and 

3. A description of the major methods of acquisition and withdrawal of 

stewardship land during the reporting period. This should include disclosure 

of physical units (by major category of stewardship land use) of transfers of 

stewardship land between Federal entities and the number of physical units 

(by major category of stewardship land use) of stewardship land acquired 

through donation or devise, if material. In addition, the fair value of 

stewardship land acquired through donation or devise during the reporting 

period should be disclosed, if known and material. 
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41. Entities should report the condition22 of the stewardship land (which may be 

reported with the deferred maintenance information23) as required supplementary 

information. Entities should include a reference to the condition and deferred 

maintenance information24 if reported elsewhere in the report containing the 

basic financial statements. 

U.S. Government-wide Financial Statement Disclosures25

42. The U.S. Government-wide financial statement should reference a note on the 

balance sheet that discloses information about stewardship land, but no asset 

dollar amount should be shown. The note disclosure related to stewardship land 

should provide the following: 

a. A concise statement explaining how it relates to the mission of the Federal 

Government. 

b. A description of the predominant uses of the stewardship land of the Federal 

Government. 

c. A general reference to agency reports for additional information about 

stewardship land, such as agency stewardship policies for stewardship land, 

physical units by major categories of stewardship land use, and the condition of 

the stewardship land. 

 

22 Condition is the physical state of an asset. The condition of an asset is based on an evaluation of the 

physical status/state of an asset, its ability to perform as planned, and its continued usefulness. 

Evaluating an asset’s condition requires knowledge of the asset, its performance capacity and its actual 

ability to perform, and expectations for its continued performance. The condition of a long-lived asset is 

affected by its durability, the quality of its design and construction, its use, the adequacy of maintenance 

that has been performed, and many other factors, including: accidents (an unforeseen and unplanned or 

unexpected event or circumstance), catastrophes (a tragic event), disasters (a sudden calamitous event 

bringing great damage, loss, or destruction), and obsolescence. Examples of condition information 

include, among others, (1) averages of standardized condition rating codes; (2) percentage of assets 

above, at, or below acceptable condition; or (3) narrative information. 

23 See SFFAS 6, Chapter 3, Deferred Maintenance (par. 77-84) for information regarding definition, 

measurement and disclosures specific to deferred maintenance. 

24 SFFAS 14, Amendments to Deferred Maintenance Reporting Amending SFFAS 6, Accounting for 

Property, Plant and Equipment and SFFAS 8, Supplementary Stewardship Reporting, defined deferred 

maintenance as RSI. The Board believed that a period of experimentation was necessary for deferred 

maintenance information and that classifying it as RSI would be more appropriate during the 

experimentation period. The Board may revise this standard based on experience gained during this time 

and the development of additional criteria. 

25 SFFAS 24, Selected Standards for the Consolidated Financial Report of the United States Government, 

clarified that all existing and future standards apply to all Federal entities, including the U.S. Governmentwide Financial Statement, unless a standard specifically provides otherwise. 
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Effective Date 

43. These standards are effective for reporting periods beginning after September 

30, 2005 with the exception of the specific paragraphs listed below. These 

exceptions provide for a phase-in of disclosure requirements being reported as 

basic information such that these standards will be fully implemented for 

reporting periods beginning after September 30, 2008. 

a. Section c and section d1 in par. 25 and 40 are effective for reporting periods 

beginning after September 30, 2007; 

 

b. Section d2 and section d3 in par. 25 and 40 are effective for reporting periods 

beginning after September 30, 2008; and 

c. Information that is provided an exception (described in par. a. and b. above) 

to being reported as basic information during the phase-in period is still required, 

but should be reported as RSI until the exceptions expire. 

44. Full implementation of the standards is effective for reporting periods beginning 

after September 30, 2008. Earlier implementation is encouraged. 

The provisions of this Statement need not be applied to immaterial 

items. 
Appendix A: Basis for Conclusions 13 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

 Appendix A: Basis for Conclusions 

This appendix discusses factors considered significant by Board members in 

reaching the conclusions in this Statement. It includes the reasons for accepting 

certain approaches and rejecting others. Individual members gave greater weight to 

some factors than to others. The standards enunciated in this statement---not the 

material in this appendix---should govern the accounting for specific transactions, 

events or conditions. 

Introduction 

45. In SFFAS 8, Supplementary Stewardship Reporting, the Board described 

stewardship information and required the reporting of that information. When the 

Board established the RSSI category, it believed that the new category was 

needed to highlight the unique nature of the reported items, to accommodate 

non-financial data, and to allow for reporting experimental information, such as 

condition. The Board believed that as agencies gained experience in reporting 

stewardship information that the reporting would evolve to a level where there 

was consistency within categories and at the government-wide consolidated 

reporting level. The Board has found that this evolution is, in fact, happening. 

46. Consequently, the Board also has considered entities’ improved accounting and 

reporting methods in deciding how to categorize the stewardship elements. The 

Board has found that, in many cases, entities have adopted the stewardship 

standards with a sense of responsible creativity. There are many instances 

where entities have developed imaginative, informative, and meaningful displays 

of stewardship information. The Board commends the efforts of these entities 

and supports their continued efforts to report on the Nation’s stewardship 

resources and responsibilities in a responsible and informative manner. 

47. The Board believes that avoiding the use of the RSSI category will eliminate 

some potential confusion and ambiguity. In particular, it should clarify the 

Board’s expectation that significant information essential to fair presentation will 

be subject to audit. 

48. The Board eliminated the use of RSSI to report information about weapons 

systems when it issued SFFAS 23, Eliminating the Category “National Defense 

Property, Plant, and Equipment.” Additionally, SFFAS 25, Reclassification of 

Stewardship Responsibilities and Eliminating the Current Services Assessment, 

eliminated the use of RSSI for reporting stewardship responsibilities. 

Classification of other items of information currently designated RSSI 

(stewardship investments) may be dealt with in one or more future standards. 
Appendix A: Basis for Conclusions 14 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

49. This standard eliminates the use of RSSI for reporting Stewardship PP&E. 

Stewardship PP&E consists of items whose physical properties resemble those 

of general PP&E traditionally capitalized in basic financial statements. However, 

the nature of Federal physical assets classified as stewardship PP&E (e.g., 

museum collections, monuments, assets acquired in the formation of the nation, 

etc.) differ from general PP&E. Stewardship PP&E includes heritage assets (e.g., 

Federal monuments and memorials and historically or culturally significant 

property) and stewardship land (i.e., land not acquired for or in connection with 

general property, plant, and equipment).26

Amendments to Standards 

50. This standard amends several existing standards. The amendments rescind 

certain standards or parts of certain standards due to the classification change, 

as well as serves as a means to incorporate all standards specific to heritage 

assets and stewardship land into one standard. 

51. This standard amends SFFAS 8 by rescinding chapters 2 and 4 of that standard. 

This change eliminates the use of the RSSI category to report information about 

heritage assets and stewardship land. This standard also incorporates the 

revised multi-use heritage asset standards of SFFAS 16, Amendments to 

Accounting for Property, Plant, and Equipment: Measurement and Reporting for 

Multi-use Heritage Assets.27 Accordingly, SFFAS 16 is rescinded in its entirety. 

Additionally, par. 57 through 76 of SFFAS 6, Accounting for Property, Plant and 

Equipment also is rescinded because they relate to heritage assets and 

stewardship land. 

52. SFFAS 14, Amendments to Deferred Maintenance Reporting, also amended 

certain paragraphs within Chapters 2 and 4 of SFFAS 8 that related to deferred 

maintenance and condition reporting. This standard also incorporates those 

revisions. Accordingly, the portion of SFFAS 14 entitled ‘Amendments to SFFAS 

8’ (SFFAS 14 par. 10 and 11) is rescinded.28 

53. As a result, this standard incorporates all standards for heritage assets and 

stewardship land into one document. The Board believes by fully incorporating 

all requirements for heritage assets (including multi-use heritage assets) and 

stewardship land, readers will better understand all existing reporting 

 

26 SFFAS 8, par. 11 27 SFFAS 16 has been incorporated into the current standard for ease in understanding because SFFAS 

16 amended Chapter 2 Heritage Assets of SFFAS 8 and portions of SFFAS 6. 

28 SFFAS 14 did amend the status of deferred maintenance by classifying it as RSI, however, SFFAS 6, 

Accounting for Property, Plant and Equipment, provides for the information to be reported. See SFFAS 6, 

Chapter 3, Deferred Maintenance (par. 77-84) for information regarding definition, measurement and 

disclosures specific to deferred maintenance. 
Appendix A: Basis for Conclusions 15 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

requirements. However, the main issues deliberated by the Board were the 

reclassification and presentation of heritage assets and stewardship land 

information. The Board has not reconsidered the definition, recognition and 

measurement provisions of the current standards at this time. These provisions 

have been brought forward from previous standards that were based on prior 

Boards’ conclusions. In the future, the Board may reconsider the recognition and 

measurement issues for heritage assets and stewardship land. 

Basic vs. RSI 

54. The Board believes that information on heritage assets and stewardship land 

(except for condition) should be basic information for the following reasons: 

a. Information on these assets is essential to fair presentation and may be 

crucial to understanding the entirety of an entity’s financial condition. 

b. Accountability for heritage assets and stewardship land requires more audit 

scrutiny than would be afforded if they were considered RSI.29

c. This classification is consistent with existing standards issued by the 

Governmental Accounting Standards Board (GASB) that is specific to 

reporting on art and historical treasures; and the Financial Accounting 

Standards Board (FASB) that is specific to collections, and other works of art 

and historical treasures. There is also existing audit guidance available in 

this area.30

55. It should be noted that during Board discussions and deliberations related to 

SFFAS 25, Reclassification of Stewardship Responsibilities and Eliminating the 

Current Services Assessment, and the reclassification of the stewardship 

responsibilities, the Board developed a detailed list of practical and conceptual 

factors for consideration in determining RSI versus basic information 

classification. This structure was also considered in the decisions relating to the 

appropriate classification of heritage assets and stewardship land information 

and will be invoked in any future classification decisions by the Board.31 

 

29 See SFFAS 8, par. 114 which details the fact the Board believed “that certain stewardship information, 

should receive more audit scrutiny than it would if it were RSI...” 

30 For additional information on these existing standards and guidance see Statement of Financial 

Accounting Standards 116, Accounting for Contributions Received and Contributions Made, GASB 34 

par. 27-29 (Reporting Works of Art and Historical Treasures), and AICPA Audit and Accounting Guide, 

Not-for-Profit Organizations. 31 See SFFAS 25, Appendix A paragraphs 34-50 for detail on the factors. To help readers understand the 

Board’s deliberations, those paragraphs provide more details about some practical and conceptual 

factors that affected the Board’s decision whether to designate an item as RSI or as an integral part of the 

basic financial statements. 
Appendix A: Basis for Conclusions 16 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

56. Specifically, the Board agreed that heritage assets and stewardship land 

information was essential and relevant to fair presentation. Additionally, the 

Board believed that it was important that this be clearly communicated to the 

readers of the financial statements and auditor reports. The Board also noted 

the importance and relevance of the information in light of the Objectives of 

Federal Financial Reporting.

32

57. Condition reporting for heritage assets and stewardship land should be reported 

as required supplementary information because this information is experimental 

in nature and there is inconsistency in the manner of assessing and reporting this 

information. 

U.S. Government-wide Financial Statement 

58. In determining the required disclosures for the U.S. Government-wide Financial 

Statement, the Board considered SFFAC 4, Intended Audience and Qualitative 

Characteristics for the Consolidated Financial Report of the United States 

Government, which designated the intended or primary audience of the U.S. 

Government-wide Financial Statement and qualitative characteristics for the U.S. 

Government-wide Financial Statement that would be most useful for that 

audience.33 

59. Par. 6 of SFFAC 4 explains that the U.S. Government-wide Financial Statement 

“is a general purpose report that is aggregated from agency reports and tells 

users where to find information in other formats, both aggregated and 

disaggregated, such as individual agency reports, agency websites, and the 

President’s Budget.” 

60. The Board considered the nature and the variety of the data that would be 

aggregated from the various entities in preparing the heritage assets and 

stewardship land disclosures for the U.S. Government-wide Financial Statement. 

The Board determined that the standards for the U.S. Government-wide 

Financial Statement should provide for a general discussion and direct users to 

the applicable entities’ financial statements for more detailed information on 

heritage assets and stewardship land. 

Exposure Draft 

61. FASAB published the exposure draft (ED) Heritage Assets and Stewardship 

Land: Reclassification from Required Supplementary Stewardship Information on 

 

32 See Stewardship (Objective 3) as described in SFFAC 1, Objectives of Federal Financial Reporting. 33 See SFFAC 4, Intended Audience and Qualitative Characteristics for the Consolidated Financial Report 

of the United States Government par. 5 
Appendix A: Basis for Conclusions 17 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

August 20, 2003. Upon release of the ED, notices and/or press releases were 

provided to: the Federal Register; the FASAB News, the Journal of 

Accountancy, AGA Today, the CPA Journal, Government Executive, the CPA 

Letter, Government Accounting and Auditing Update, and JFMIP News; the CFO 

Council, the Presidents Council on Integrity and Efficiency, the Financial 

Statement Audit Network, the Federal Financial Managers Council; and 

committees of professional associations generally commenting on exposure 

drafts in the past. 

62. Twelve letters were received from the following sources: 

 FEDERAL 

(internal) 

NONFEDERAL 

(external) 

Users, academics, others 1 3 

Auditors 1 1 

Preparers and financial 

managers 

6 

63. A public hearing was held on March 4, 2004. Individuals from the Library of 

Congress, U.S. Department of Agriculture, Department of Interior (including 

representatives from the CFO, OIG and IPA currently performing the DOI audit), 

and a representative from the Institute for Truth in Accounting testified at the 

public hearing. The participants reiterated issues included in the comment letters 

to the ED. 

Responses to the ED 

64. A majority of the respondents did not agree with heritage assets and stewardship 

land information being reported as basic. Key issues raised by respondents 

included the following: 

a. A need for more specific guidance on categorization and unitization for 

reporting heritage assets and stewardship land information; 

b. The audit implications of the standard, including the additional audit costs by 

classifying the information as basic; and 

c. Less useful information being presented by agencies with the reclassification. 

65. Most respondents that did not agree with heritage assets and stewardship land 

information being reported as basic, recommended that it be classified as RSI (or 

remain as RSSI). 

66. Most respondents agreed with the Board’s new disclosure requirements and did 

not foresee any problems with the new disclosure requirements 
Appendix A: Basis for Conclusions 18 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

67. Most respondents did not agree with the proposed effective date for periods 

beginning after September 30, 2004 in the ED. Key reasons cited for the delay 

of the effective date included the need for additional time to address 

implementation issues and time for including funding in their budgets to cover the 

additional costs for implementation and audit. 

Board Consideration of Comments 

68. Considering that the majority of respondents did not agree with the ED, the 

Board directed staff to research various issues that would assist the Board in 

addressing the comments raised by respondents. For example, the Board 

considered the current FASB and GASB standards in this area. The Board also 

considered results of a review of private museum reporting practices. 

69. The Board also considered several recent government-wide initiatives that 

promote accountability and stewardship over real property assets and heritage 

assets such as the Federal Real Property Asset Management Initiative, 

Executive Order 13327 Federal Real Property Asset Management, and 

Executive Order 13287 Preserve America. The Board believes these initiatives 

provide further support for the decision to classify the heritage assets and 

stewardship land as basic information and the importance of accountability for 

these types of assets. 

70. The Board also considered the issue of unitization and categorization further by 

reviewing draft guidance prepared by the Heritage Assets Categorization Project 

Team and the Accounting and Auditing Policy Committee (AAPC) Stewardship 

Guidance Workgroup. The Board believes that the draft products from these 

workgroups are excellent starting points for developing comprehensive guidance 

on many of the issues raised by respondents. 

71. In response to the audit concerns, FASAB held a roundtable meeting with 

representatives from the Office of Inspector General (OIG) and CPA firms 

responsible for financial statement audits to solicit their views on specific issues 

raised by respondents as well as potential audit costs involved with implementing 

the standard. 

72. As a result of the comments received and testimony provided at the public 

hearing, as well as the above actions, the Board did make certain revisions, 

which are detailed in the following paragraphs. Additionally, reasons for not 

making revisions on specific issues are detailed below. 

Importance to Mission 

73. The ED contained the new disclosure that required a statement explaining how 

heritage assets and stewardship land are “important to the overall mission of the 
Appendix A: Basis for Conclusions 19 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

entity.” A respondent explained that agencies may have significant stewardship 

assets as a result of their compliance with cultural resource protection laws and 

regulations or because Congress has determined that certain classes of assets 

to be nationally significant, regardless of the agency mission. The respondent 

believed that showing the link between the agency mission and the assets may 

result in less disclosure by agencies that lack a direct link to their mission. 

74. The Board understands that some agencies may have heritage assets because 

of the facts described by the respondent and it is possible that the assets may 

not be important to the overall mission of the agency. However, the Board 

considered the new requirement to be explanatory in nature by offering more 

information about the assets. The Board did not envision the importance to the 

mission to be considered in determining which heritage assets and stewardship 

land should be included. 

75. The Board revised the language of the new requirement to read “A concise 

statement explaining how they relate to the mission of the entity.” The Board 

believes with this language, the requirement is flexible enough that if the assets 

are not related to the mission of the entity, the entity may state that and provide 

additional explanation, if they so choose. 

Limiting Information Presented 

76. Several respondents commented that agencies would present less information in 

their annual reports because the heritage assets information and stewardship 

land information would be subject to audit since it is classified as basic 

information. The classification of heritage assets and stewardship land 

information as basic should not limit the information entities choose to present or 

prevent the continuation of informative and meaningful displays of information. 

77. This standard does not eliminate any information that was previously required for 

heritage assets and stewardship land. In drafting the standard, the Board 

envisioned the required disclosures to be presented in a concise format similar to 

the format that most entities present for general property, plant and equipment. 

78. The Board notes that preparers continue to have the option of voluntarily 

presenting information beyond the minimum reporting requirements as other 

accompanying information. 

Categorization and Unitization 

79. The standard does not define asset categories or physical units for reporting. The 

Board recognizes that there may be difficulties for agencies in determining the 

appropriate level of aggregation for reporting categories of heritage assets. 

However, the Board believes that the agencies are in the best position to 
Appendix A: Basis for Conclusions 20 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

determine the most meaningful level of presentation. The Board believes that 

ultimately the presentation depends upon the specifics of the entity—its mission, 

the types of heritage assets, how it manages, and materiality considerations. It 

would be difficult for the standard to define such specific reporting requirements, 

as they may be unique to each entity. 

80. The Board also has avoided detailed illustrations and limited specific examples in 

the standard because preparers and auditors may attempt to strictly adhere to 

the illustrations. 

81. The standard emphasizes reporting on asset categories, rather than individual 

assets. Based on comments to the ED, it appeared that this may not have been 

clear to the readers. Therefore, additional language was added to the final 

standard to clarify that the appropriate level of categorization of stewardship 

assets and the associated physical units should be determined by the preparer 

based on the entity’s mission, types of use, and how it manages the assets. 

82. Entities should designate asset reporting categories that allow inclusion and 

aggregation of their heritage assets and stewardship land. Entities should 

determine the appropriate level of detail for their categorization. It is helpful if 

entities designate asset categories that are meaningful and reflect how the entity 

views the assets for management purposes. It would also be helpful for entities 

to document the reasoning for the categorization. 

83. The Board recognizes that the information that is appropriate for reporting 

heritage assets and stewardship land can vary from one entity to another. The 

amount and level of detail of the information presented depends, in part, on the 

mission of the entity and the materiality of the assets in question. For example, 

categories reported by an agency that has a stewardship mission, might be more 

disaggregated than is appropriate for one that does not. 

84. Defining physical units as individual items to be counted is neither required nor 

prohibited. Particularly for collection-type heritage assets, it may be more 

appropriate to define the physical unit as a collection, or a group of assets 

located at one facility, and then count the number of collections or facilities. The 

level of detail may differ by entity. 

85. It is the intent of the Board to provide entities with considerable latitude and 

flexibility in designating categories, determining a meaningful level of aggregation 

for reporting, and selecting physical units aligned with those categories. For 

example, should a library report that it has a collection of papers or that it has 

10,000 pieces of paper in that collection? Further, should a museum report that 

is has 10 dinosaur skeletons or 10,000 dinosaur bones, or a single collection of 

skeletons in one facility? Ultimately, the answer is influenced by how the entity 

manages as well as materiality considerations. Agencies may be required to 

count the number of individual items for control purposes. But due to materiality 

considerations, entities may choose to report a higher level of aggregation such 

as the number of collections or facilities in which individual items are located. 
Appendix A: Basis for Conclusions 21 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

Although individual item counts may not be necessary to support the reporting 

requirements in the standard, this does not mean that item counts for 

management control and safeguarding purposes are not necessary to fulfill 

mandates required by other public laws and regulations. 

Supporting Documentation 

86. The Board has recognized in previous standards that historical records for items 

acquired long ago may not have been retained.34 Based on responses to the 

ED, testimony provided at the public hearing, and discussions with the auditors at 

the roundtable meeting, the Board believes this may be an issue in implementing 

this standard. 

87. The Board understands that with the heritage assets and stewardship land 

information being classified as basic, auditors may require certain supporting 

documentation to fulfill audit assertions. There may be instances where the 

historical documents are not available for items acquired many years ago, prior 

to the effective date of this standard, in an environment in which the historical 

records were not required to be retained and may therefore be inadequate. 

88. Therefore, the Board encourages preparers, program offices, and auditors to 

develop other reasonable approaches and methods for satisfying the specific 

audit assertions that would rely on historical documents as evidence and support. 

In addition, the Board plans to suggest that this issue be addressed further in the 

forthcoming AAPC Guidance (discussed below). 

Additional Guidance 

89. The Board notes that there has been work by certain government-wide task 

forces (such as the AAPC Stewardship Guidance Work Group and the Heritage 

Assets Categorization Team) to address issues identified such as standardized 

categories, definitions of units of measurements, and other areas where 

prescriptive guidance has been requested. The task forces contained 

representatives from pertinent agencies and experts in the field, which most likely 

provided for a comprehensive assessment. 

90. Considering the extensive research performed by the task forces, their draft 

proposals or guides which address areas such as categories and subcategories 

and related physical units should be a good starting point for additional guidance 

that could be included in a Technical Release from the AAPC. 

 

34 SFFAS 23 Eliminating the Category National Defense PP&E, par. 11 provided implementation 

guidance as follows: “This standard recognizes that determining initial historical cost may not be practical 

for items acquired many years prior to the effective date of this standard in an environment in which the 

historical records were not required to be retained and may therefore be inadequate.” 
Appendix A: Basis for Conclusions 22 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

91. The Board will request that the AAPC revitalize the efforts of the Stewardship 

Guidance Work Group and work towards finalization of their draft guidance, 

which may ultimately be published as a Technical Release. The guidance will be 

expanded where necessary to cover the issues identified by respondents in the 

comment letters. For example, the Board will suggest that the AAPC review 

case studies where supporting documentation may not be available and 

determine other reasonable approaches, methods, and best practices for 

satisfying specific assertions that would rely on historical documents as evidence 

and support. 

92. The Board will suggest that the AAPC also consider the work done by the 

Heritage Assets Categorization Team. FASAB staff will work closely with the 

task force with the goal of finalizing the guide within one year of the issuance of 

this standard. 

Effective Date/Phased-In Implementation 

93. Most respondents to the ED and participants at the public hearing did not agree 

with the proposed effective date in the ED for periods beginning after September 

30, 2004. Key reasons cited for the delay of the effective date were the need for 

additional time to address issues noted in their arguments against classifying the 

information as basic and time for including funding in their budgets for the 

additional work and audit costs to be incurred. 

94. The Board believed the reasons provided for the delay of the effective date were 

valid and justified some delay. Therefore, the Board believed a phased 

implementation would provide time for entities to address some of the issues 

identified and for consideration of the strained resources facing most agencies. 

95. The Board also believed that the effective date for certain disclosures to be 

classified as basic should be delayed to allow time for the issuance of the 

additional guidance by the AAPC. Therefore, the standard was revised to allow 

for a phase-in of required reporting disclosures as basic. 

96. The standards are effective for reporting periods beginning after September 30, 

2005, with the exception of the section c (category descriptions) and section d1 

(physical units by major category for the end of the reporting period) in par. 25 

and 40 that are effective for reporting periods beginning after September 30, 

2007; and section d2 (physical units by major category that were acquired and 

withdrawn during the reporting period) and section d3 (major methods of 

acquisition and withdrawal during the reporting period) in par. 25 and 40 that are 

effective for reporting periods beginning after September 30, 2008. 

97. These exceptions provide for a phase-in of disclosure requirements being 

reported as basic information such that the standard will be fully implemented for 
Appendix A: Basis for Conclusions 23 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

reporting periods beginning after September 30, 2008. Information that is 

provided an exception (see par. above) to being reported as basic information 

during the phase-in period is still required, but should be reported as RSI until the 

exceptions expire. It may be appropriate for entities to include a reference to the 

information reported as RSI during the phase-in period. 

98. The phased-in implementation offers additional time for agencies to determine 

the proper level of aggregation for major categories, as well as determining the 

appropriate physical unit of measure and documenting their reasoning for such. 

This additional time will also allow for the AAPC to issue its guidance in time for 

consideration before implementation. It is anticipated that the AAPC will finalize 

the guide prior to the implementation of the required reporting by major 

categories. 

Materiality 

99. In the ED, the disclosure requirements language read “Entities with significant 

heritage assets/stewardship land should reference a note...” The Board used 

the term “significant” to emphasize that some entities may not be subject to the 

disclosure requirements due to certain entities having only immaterial amounts 

of heritage assets and stewardship land covered by this standard. 

100. Although most respondents to the ED agreed that the preparer should have 

flexibility in determining appropriate categories for aggregation and that the 

preparer should be allowed to exercise professional judgment in determining 

which assets are significant, there was some concern raised by respondents 

that these judgments may be difficult to make. Certain respondents noted that 

“significant” is difficult to apply in the case of heritage assets and stewardship 

land because there are no financial dollar amounts required to be reported. 

101. The term “significant” was removed from the language establishing disclosure 

requirements in the final standard because the Board has stated within this 

standard “The provisions of this Statement need not be applied to immaterial 

items.” Therefore, entities may omit heritage asset and stewardship land 

information if they are immaterial. 

102. In SFFAS 3, Accounting for Inventory and Related Property, the introduction 

included a discussion on "materiality".35 It explained that materiality has not 

been strictly defined in the accounting community; rather, it has been a matter 

of judgment on the part of preparers of financial statements and the auditors 

who attest to them. It further explained that the determination of whether an 

item is immaterial requires the exercise of considerable judgment, based on 

consideration of specific facts and circumstances. 

 

35 See SFFAS 3, Accounting for Inventory and Related Property, par. 7-15. 
Appendix A: Basis for Conclusions 24 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

103. In its discussion in SFFAS 3, the Board relied on the FASB’s concept as 

modified by certain concepts expressed in governmental auditing standards36. 

Par. 9 of SFFAS 3 discussed FASB's Statement of Financial Accounting 

Concepts No. 2, "Qualitative Characteristics of Accounting Information," that 

provides for materiality as the magnitude of an omission or misstatement of 

accounting information that, in the light of surrounding circumstances, makes it 

probable that the judgment of a reasonable person relying on the information 

would have been changed or influenced by the omission or misstatement. 

104. Par. 9 of SFFAS 3 also explains that this concept includes both qualitative and 

quantitative considerations. An item that is not considered material from a 

quantitative standpoint may be considered qualitatively material if it would 

influence or change the judgment of the financial statement user. The Board 

believes that preparers should consider both quantitative and qualitative 

characteristics when applying materiality to this standard. 

Board Approval 

105. This statement was approved for issuance by all members of the Board. 

 

36 Par. 12 of SFFAS 3 explains that the Government Auditing Standards provide "In government audits 

the materiality level and/or threshold of acceptable risk may be lower than in similar-type audits in the 

private-sector because of the public accountability of the entity, the various legal and regulatory 

requirements, and the visibility and sensitivity of government programs, activities, and functions." 
Appendix B: List of Abbreviations 25 

Federal Accounting Standards Advisory Board 

Heritage Assets and Stewardship Land 

July 7, 2005

Appendix B: List of Abbreviations 

AAPC Accounting and Auditing Policy Committee 

AICPA American Institute of Certified Public Accountants 

ED Exposure Draft 

FASAB Federal Accounting Standards Advisory Board 

FASB Financial Accounting Standards Board 

GAO Government Accountability Office 

GASB Governmental Accounting Standards Board 

OMB Office of Management and Budget 

PP&E Property, Plant and Equipment 

RSI Required Supplementary Information 

RSSI Required Supplementary Stewardship Information 

SFFAC Statement of Federal Financial Accounting Concepts 

SFFAS Statement of Federal Financial Accounting Standards 

U.S. United States 
FASAB Board Members 

David Mosso, Chairman 

Joseph V. Anania, Sr. 

Philip T. Calder (through July 31, 2004) 

Claire Gorham Cohen 

Robert F. Dacey (from August 1, 2004) 

John A. Farrell 

Joseph L. Kull (through August 31, 2003) 

James M. Patton 

Robert N. Reid 

Elizabeth Robinson 

Alan H. Schumacher 

David M. Zavada (from December 1, 2003)

FASAB Staff 

Wendy M. Comes, Executive Director 

Melissa Loughan 

Federal Accounting Standards Advisory Board 

441 G Street NW 

Suite 6814 

Mailstop 6K17V 

Washington, DC 20548 

Telephone (202) 512-7350 

FAX (202) 512-7366 

www.fasab.gov