Date: September 15, 1997

To: Wendy Comes

Executive Director

Federal Accounting Standards Advisory Board

From: Judy Yuran

Chairperson

SGL Issue Resolution Committee

Subject: SGL Issue Resolution Committee Responses on 

Governmentwide Supplementary Stewardship Reporting 

Standards ED

The following are comments from IRC members related to the

FASAB Governmentwide Supplementary Stewardship Reporting

Standards Exposure Draft. We appreciate the opportunity to

comment on this exposure draft. Please call me on (202) 874-6308,

if you have any questions. 

GENERAL COMMENTS

IRC comments on this exposure draft are limited since the primary

impact of governmentwide consolidation would fall outside the

scope of agency responsibility. 

Stewardship Investments

 Outlays versus Expenses 

Page 13, Para 28 and 29. Substituting outlay data for

expense data for previous 4 years of stewardship

investment, including Human Capital.

 

IRC Comment: Since outlay data submitted by many agencies(SF

133), does not identify human capital outlays, the

requirements of these paragraphs may be difficult if not 

impossible to implement. In addition, if the consolidated 

statements present outlay data to show trends, there should

be a caveat about the lack of comparability between outlays

and expenses. As an example, a large portion of outlays in

the Direct Student Loan Program are from borrowings from

Treasury, which are required to be repaid by borrowers, and

do not represent an expense to the taxpayer. If outlay data

is substituted for expense data, the consolidated statements

must clearly explain the differences between outlays and

expenses, so that the information will not be misleading to
the general public.

COMMENTS TO SPECIFIC QUESTIONS FOR RESPONDENTS

The following are responses to specific questions in the

Governmentwide Supplementary Stewardship Reporting Standards. 

1. Are the proposed standards clearly written? 

Yes, the IRC feels that the standards are generally clearly 

written.

2. Are there any aspects of or terms in the proposed standards 

that need further explanation? 

No. The IRC does not believe that any aspects or terms of

the exposure draft, as related to agencies, need any further 

explanation. 

 

3. Do you believe that the proposed governmentwide

supplementary stewardship standards will produce an

effective "roll up" or consolidation of the entity level

information required by SRAS No. 8?

Yes. The IRC feels that the proposed standards will produce 

an effective "roll up" or consolidation of the entity level

information required by SRAS No. 8.

4. Have you any specific suggestions for modifying or improving

the sample displays of governmentwide supplementary 

stewardship information (see Appendix B) to aid in its 

understanding and use by readers?

No. The IRC believes that the sample displays of

governmentwide supplementary stewardship information in

appendix B seem adequate for understanding and use by

readers.

5. Do you agree that the implementation date of the

governmentwide supplementary stewardship standards should be

one fiscal year later than that of the entity level

supplementary stewardship standards to allow the preparers

of the governmentwide reports one cycle to examine the

nature of data that would have to be accumulated for the
governmentwide reports?

Yes. The IRC agrees with the delay of the implementation

date of the governmentwide supplementary stewardship

standards for one year later than the entity level. This

should give the preparers some additional time to decide

what type and level of agency data to roll-up in the

governmentwide statements.