This is the accessible text file for GAO report number GAO-07-61R 
entitled 'Financial Management: Review of the Financial Statement Audit 
of the White House Commission on the National Moment of Remembrance for 
Fiscal Year 2005 and Status of GAO Audit Recommendations' which was 
released on October 26, 2006. 

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October 26, 2006: 

The Honorable Arlen Specter:
Chairman:
The Honorable Patrick J. Leahy:
Ranking Minority Member:
Committee on the Judiciary:
United States Senate: 

The Honorable F. James Sensenbrenner, Jr. Chairman:
The Honorable John Conyers, Jr.
Ranking Minority Member:
Committee on the Judiciary:
House of Representatives: 

Subject: Financial Management: Review of the Financial Statement Audit 
of the White House Commission on the National Moment of Remembrance for 
Fiscal Year 2005 and Status of GAO Audit Recommendations: 

The White House Commission on the National Moment of Remembrance 
(Commission) was created on December 28, 2000, by the National Moment 
of Remembrance Act.[Footnote 1] The Commission's purpose is to sustain 
the American spirit through acts of remembrance, not only on Memorial 
Day but also throughout the year, for those who died serving our 
country. 

The National Moment of Remembrance Act requires us to annually audit 
the financial transactions of the Commission. However, as reflected in 
an Office of Management and Budget (OMB) memorandum,[Footnote 2] the 
Commission is subject to the Accountability of Tax Dollars Act of 2002 
which was enacted on November 7, 2002.[Footnote 3] This act requires 
the Commission to annually prepare and submit audited financial 
statements to OMB and Congress. This is the first year the Commission 
has prepared a complete set of financial statements and contracted with 
an independent public accountant (IPA) to conduct the financial 
statement audit. In lieu of performing an audit of the Commission's 
fiscal year 2005 financial transactions, which would duplicate much of 
the work performed by the IPA, we performed a review of the IPA's audit 
of the Commission's financial statements. This report provides the 
results of our review of the Commission's fiscal year 2005 financial 
statement audit and provides the status of the Commission's 
implementation of recommendations made by us during prior years' audits 
of the Commission's financial transactions. Our work was performed in 
accordance with U.S. generally accepted government auditing standards. 

Results in Brief: 

We found no instances in which the IPA did not perform sufficient work 
to support its opinion and no instances in which the IPA did not 
comply, in all material respects, with U.S. generally accepted 
government auditing standards. In its audit of the Commission's fiscal 
year 2005 financial statements, the IPA found that (1) the financial 
statements were presented fairly, except for the Commission's failure 
to provide a legal representation letter; (2) the Commission's failure 
to provide a legal representation letter also resulted in a reportable 
condition;[Footnote 4] and (3) there was no reportable noncompliance 
with selected provisions of laws and regulations. 

In our report on our audit of the Commission's fiscal year 2004 
financial transactions,[Footnote 5] we made 10 recommendations to the 
Commission designed to improve its overall financial management and 
internal control. Subsequently, the Commission provided a written 
statement of actions it had taken or was planning to take to address 
the issues we reported that gave rise to our recommendations. We 
reviewed the actions taken by the Commission and found that the 
Commission had effectively implemented 9 of our 10 recommendations. 

We are not making any new recommendations in this report. The 
Commission agreed with the results presented in this report. 

Background: 

The Commission's purpose is to sustain the American spirit through acts 
of remembrance, not only on Memorial Day but also throughout the year, 
for those who died serving our country. Congress appropriated $1.25 
million to the Commission to fund its operations for fiscal years 2002 
through 2005.[Footnote 6] In fiscal year 2005, the Commission received 
net appropriations of approximately $248,000, along with cash and in- 
kind[Footnote 7] donations of approximately $103,000 from individuals 
and businesses. In addition, it had approximately $244,000 in 
unexpended appropriations from prior fiscal years. The Commission 
expended approximately $239,000 of appropriated funds and funded costs 
of approximately $103,000 with cash and in-kind donations received 
during the fiscal year. 

Processing of Commission Financial Transactions: 

The Commission utilizes the Department of Veterans Affairs (VA)-- 
through an interagency agreement--for administrative support services, 
including payment of the Commission's bills and personnel and payroll 
services. VA processes the Commission's obligations, expenditures, and 
cash and in-kind donations recorded during the fiscal year. VA also 
prepares annual financial statements and monthly standard forms on 
budget execution for the Commission. During fiscal year 2005, the 
Commission employed the services of a part-time bookkeeper to help 
maintain its financial records. 

Financial Reporting and Audit Requirements: 

The Commission is required under the Accountability of Tax Dollars Act 
of 2002 to annually prepare and submit audited financial statements. 
OMB Circular No. A-136, Financial Reporting Requirements, as amended, 
identifies the basic financial statements to include the Balance Sheet, 
Statement of Net Cost, Statement of Changes in Net Position, Statement 
of Budgetary Resources, and Statement of Financing. The financial 
statements are to be prepared in accordance with U.S. generally 
accepted accounting principles, and their production is intended, in 
part, to provide for complete, reliable, timely, and consistent 
financial information for use by management and Congress in the 
financing, management, and evaluation of federal programs. 

Federal financial statements are to be audited in accordance with U.S. 
generally accepted government auditing standards.[Footnote 8] OMB's 
guidance in OMB Circular No. A-136 requires agencies to prepare and 
submit their performance and accountability reports, which include 
agencies' audited financial statements, to OMB and Congress no later 
than November 15 for agencies with a September 30 fiscal year-end. OMB 
granted the Commission an exemption from the requirement to prepare 
audited financial statements for fiscal year 2004[Footnote 9] but did 
not exempt the Commission from this requirement in fiscal year 2005. 
The Commission did not submit audited financial statements to OMB by 
November 15, 2005, as required by OMB guidance, and the Commission did 
not request an exemption from this requirement from OMB for fiscal year 
2005. 

Financial statement audits of federal departments and agencies, 
performed in accordance with generally accepted government auditing 
standards, are intended to provide reasonable assurance about whether 
the financial statements for an audited entity present fairly, in all 
material respects, its financial position, net cost, changes in net 
position, budgetary status, and financing, in conformity with U.S. 
generally accepted accounting principles. OMB Bulletin No. 01-02, Audit 
Requirements for Federal Financial Statements, as amended, establishes 
the minimum requirements for audits of federal financial 
statements.[Footnote 10] OMB audit guidance requires auditors to (1) 
report whether agencies' financial statements are fairly presented in 
all material respects, in conformity with U.S. generally accepted 
accounting principles; (2) obtain an understanding of the components of 
internal controls and assess the level of control risk; and (3) test 
whether agencies comply with laws and regulations that have a direct 
and material effect on the financial statements. 

Objectives, Scope, and Methodology: 

Our objectives were to determine (1) whether the IPA performed 
sufficient work to support its opinion on the fiscal year 2005 
financial statements of the Commission; (2) whether the financial 
statement audit was performed in accordance with appropriate auditing 
standards; and (3) whether, and to what extent, the Commission 
effectively implemented recommendations made by us in our prior audits 
of the Commission's financial transactions. 

To satisfy these objectives, we reviewed the IPA's report and related 
audit documentation and, as necessary, met with IPA representatives and 
the Commission's management. Our review, as differentiated from an 
audit in accordance with generally accepted government auditing 
standards, was not intended to enable us to express, and we do not 
express, opinions on the Commission's financial statements and about 
the effectiveness of its internal control or conclude on its compliance 
with laws and regulations. We performed our review in accordance with 
Section 650 of the GAO/President's Council on Integrity and Efficiency 
Financial Audit Manual. This guidance requires us to: 

˛ evaluate the IPA's independence and objectivity, 

˛ evaluate the IPA's qualifications, and: 

˛ review and evaluate the IPA's work. 

We evaluated the IPA's independence, objectivity, and qualifications by 
reviewing the following: 

˛ the most recent peer review[Footnote 11] report for the IPA (dated 
September 30, 2004) and the corresponding letter of response, 

˛ the informal request for proposal sent out by the Commission when 
seeking an audit firm to conduct the audit of its fiscal year 2005 
financial statements, 

˛ the engagement letter between the IPA and the Commission, and: 

˛ résumés for the IPA staff assigned to the Commission's audit. 

To determine whether the IPA performed sufficient work to support its 
audit opinion and whether the auditor complied with U.S. generally 
accepted government auditing standards, we reviewed the IPA's planning, 
testing, and reporting audit documentation and made inquiries of the 
IPA staff. 

To determine whether, and to what extent, the Commission effectively 
implemented recommendations we made during prior years' audits of the 
Commission's financial transactions, we reviewed the IPA's audit 
documentation, made inquiries of Commission personnel, and obtained 
certain documentation from the Commission. 

Because we did not audit the Commission's financial statements, we do 
not express an opinion on the statements. Our work was performed from 
April 2006 through October 2006 in accordance with U.S. generally 
accepted government auditing standards. We provided a draft of our 
report to the Commission for review and comment. 

IPA Is Independent, Objective, and Qualified: 

We determined the IPA to be independent and objective with respect to 
the Commission. We evaluated the IPA's qualifications by reviewing 
résumés for the IPA staff assigned to the Commission's audit, and 
determined the IPA to be qualified to perform the audit of the 
Commission. 

The IPA's most recent peer review report was unqualified; however, the 
report cited the need for the IPA to improve its quality control 
policies and procedures. The results of our review also indicated that 
the IPA's quality control policies and procedures should be further 
enhanced. 

Sufficient Audit Work Was Performed, and Audit Was Performed in 
Accordance with Generally Accepted Government Auditing Standards: 

During our preliminary review of the IPA's audit documentation, we 
found areas in which further documentation was needed. In all 
instances, the IPA provided the additional documentation needed. Our 
final review of the audit of the Commission's financial statements 
disclosed no instances in which insufficient audit work was performed 
by the IPA to support its audit opinion. Our review also disclosed no 
instances in which the IPA did not comply, in all material respects, 
with U.S. generally accepted government auditing standards. 

Commission Received a Qualified Audit Opinion: 

The Commission received a qualified opinion on its fiscal year 2005 
financial statements. The IPA found that the Commission's financial 
statements were presented fairly, except for the Commission's failure 
to obtain a legal representation letter.[Footnote 12] The Commission's 
failure to obtain a legal representation letter also resulted in a 
reportable condition in the IPA's report on internal control over 
financial reporting. The IPA found no instances of noncompliance with 
laws and regulations on the part of the Commission and noted no other 
matters to be communicated to the Commission. 

Commission Has Taken Action to Improve Internal Control: 

In our prior work, we found that the Commission's internal control over 
financial transactions needed improvement.[Footnote 13] In particular, 
we found that (1) documentation for payroll, benefits, and payments to 
VA was not readily available; (2) reconciliations with VA's records 
were not routinely performed; (3) financial transactions were not 
properly coded; (4) procurement regulations were not followed; (5) 
travel reimbursements exceeded allowable rates; (6) cash and in-kind 
donations were not always recorded; and (7) greater distinction between 
the Commission and another nonprofit organization called No Greater 
Love was needed. We made 10 recommendations to the Commission for 
corrective actions to improve its overall financial management and 
internal control. 

Since our audit of the Commission's fiscal year 2004 financial 
transactions, the Commission has taken a number of corrective actions 
to improve its internal control and overall accountability. 
Specifically, we found that the Commission has taken the following 
actions: 

˛ maintains appropriate documentation for financial transactions, 
including biweekly time sheets for the Commission's employee; 

˛ solicits offers from three commercial vendors before purchasing goods 
or services for an amount expected to exceed the $2,500 micropurchase 
threshold for federal procurements;[Footnote 14] 

˛ strengthened procedures for the preparation of travel vouchers to 
ensure that allowable rates established by federal regulation are not 
exceeded;[Footnote 15] 

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

˛ discontinued the listing of No Greater Love's e-mail address and fax 
number on the Commission's business cards to assist in furthering the 
distinction between the Commission and No Greater Love. 

We have determined that through its actions, the Commission has 
effectively addressed most of the issues that gave rise to our 
recommendations. However, the Commission has not implemented adequate 
procedures to timely reconcile the Commission's financial data to the 
financial records maintained by its accounting services provider. The 
enclosure provides a list of all financial management-related 
recommendations we made to the Commission in our prior audits of its 
financial transactions, the actions taken by the Commission in response 
to our recommendations, and the status of those recommendations based 
on our review. 

Agency Comments: 

We provided a draft of our report to the Commission for review and 
comment. The Commission agreed with the results presented in the 
report. 

We are sending copies of this report to the Chairmen and Ranking 
Minority Members of the Senate Committee on Appropriations and the 
House Committee on Appropriations; the Chairman of the White House 
Commission on the National Moment of Remembrance; the Secretary of 
Veterans Affairs; the Director, Office of Management and Budget; and 
other interested parties. This report is also available at no charge on 
the GAO Web site at [Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions, please contact me at (202) 512-
3406 or by e-mail at sebastians@gao.gov. Contact points for our Offices 
of Congressional Relations and Public Affairs may be found on the last 
page of this report. Contributors to this report were Julie T. 
Phillips, Assistant Director, and Peggy J. Smith. 

Signed by: 

Steven J. Sebastian: 
Director: 
Financial Management and Assurance: 

Enclosure: 

Enclosure I: Status of GAO Recommendations from Prior Audits: 

Count: 1; 
Recommendations from GAO-05-791R: Prepare biweekly timesheets and 
regularly submit them to the Department of Veterans Affairs (VA) for 
approval and processing as evidence of actual hours worked; 
Status per Commission on the National Moment of Remembrance 
(Commission): As of May 2, 2005, the Commission's employees has been 
submitting biweekly time sheets to the financial services provider; 
Status per GAO: Closed. We verified that the Commission's employees 
submitted biweekly time sheets to the financial service providers. 

Count: 2; 
Recommendations from GAO-05-791R: Strengthen the procedures to ensure 
that appropriate documentation for all financial transactions--
including payroll, payroll-related, and intragovernmental transactions--
is maintained and readily available for review; 
Status per Commission on the National Moment of Remembrance 
(Commission): For fiscal year 2005, the Commission made sure to 
maintain and have available in its office all appropriate documentation 
related to its financial transactions. In addition, the Commission 
requested from its financial services provider submission by fax on a 
monthly basis of all documents supporting payroll, payroll-related, and 
intragovernmental transactions; 
Status per GAO: Closed. The Commission appropriately documented 
financial transactions including payroll, payroll-related, and 
intragovernmental transactions. 

Count: 3; 
Recommendations from GAO-05-791R: Assess the cost of VA's services to 
determine if comparable services may be available from other sources at 
a lower cost; 
Status per Commission on the National Moment of Remembrance 
(Commission): To ensure that the Commission was not overpaying for 
services, it looked into comparable services vendors. In the meantime, 
and after review of GAO's fiscal year 2004 report on the Commission, VA 
Financial Services offered the Commission a contract for fiscal year 
2006 with a $10,000 reduction in the annual service fee; 
Status per GAO: Closed. The Commission negotiated with VA Financial 
Services for a significant reduction in its annual services fee. 

Count: 4; 
Recommendations from GAO-05-791R: Establish procedures to (1) timely 
reconcile, on a monthly basis, the Commission's financial data to the 
financial records maintained by its accounting services provider, VA, 
and (2)communicate all differences to VA as the provider so that the 
two entities' records can be appropriately reconciled; 
Status per Commission on the National Moment of Remembrance 
(Commission): The Commission and VA Financial Services have now 
established new procedures to reconcile records appropriately and on a 
monthly basis. For fiscal year 2005, the Commission communicated all 
differences to its financial services provider. In addition, all past 
transactions were reconciled as noted in GAO-07-791R (p.2): "In May 
2005, the Commission and VA reconciled their records and made 
accounting adjustments for the differences"; 
Status per GAO: Open. The Commission's year-end trial balance did not 
reconcile to the financial statements prepared by its accounting 
services provider (VA).

Count: 5; 
Recommendations from GAO-05-791R: While continuing to use VA's 
services, code all invoices in accordance with VA guidelines to 
indicate the type of expenditure prior to submitting them to VA for 
processing; 
Status per Commission on the National Moment of Remembrance 
(Commission): For fiscal year 2005, the Commission has been coding all 
invoices in accordance with the financial service provider's 
guidelines; 
Status per GAO: Closed. We verified that the Commission is now coding 
all invoices in accordance with VA's guidelines. 

Count: 6; 
Recommendations from GAO-05-791R: Solicit offers or quotes from at 
least three commercial vendors when goods or services are expected to 
exceed the $2,500 micropurchase threshold for federal procurements and 
when otherwise required by the Federal Acquisition Regulations (FAR); 
Status per Commission on the National Moment of Remembrance 
(Commission): For fiscal year 2005, the Commission solicited offers 
from three commercial vendors before purchasing goods or services for 
an amount expected to exceed the $2,500 micropurchase threshold for 
federal procurements and when otherwise required by FAR; 
Status per GAO: Closed. We verified that the Commission is now 
soliciting offers from three commercial vendors before purchasing goods 
or services for an amount expected to exceed the $2,500 micropurchase 
threshold for federal procurements and when otherwise required by FAR. 

Count: 7; 
Recommendations from GAO-05-791R: Strengthen procedures over preparing 
travel vouchers by (10 adhering to allowable rates in accordance with 
federal regulations and (2) ensuring that travel-related overcharges 
and traveler reimbursements are timely collected or offset against 
amounts due; 
Status per Commission on the National Moment of Remembrance 
(Commission): During fiscal year 2005, the Commission worked with VA 
Financial Services to strengthen its procedures for preparing travel 
vouchers. Both entities now make sure the Commission adheres to 
allowable rates in accordance with federal regulations while it ensures 
that all travel-related overcharges and traveler reimbursements are 
timely collected or offset against amounts due; 
Status per GAO: Closed. The Commission's employee took one business 
trip during fiscal year 2005. We reviewed the documentation for that 
trip and concluded that the Commission adhered to allowable rates per 
federal regulations. 

Count: 8; 
Recommendations from GAO-05-791R: Strengthen procedures over cash 
donations by immediately obtaining and retaining documentation that 
evidences the purpose and intent of the donation; 
Status per Commission on the National Moment of Remembrance 
(Commission): For fiscal year 2005, all cash and in-kind donations are 
supported. All documents concerning cash and in-kind donations are now 
immediately requested and filed with other donations made to the 
Commission; 
Status per GAO: Closed. We verified that the Commission is retaining 
documentation that evidences the purpose and intent of donations. 

Count: 9; 
Recommendations from GAO-05-791R: Develop procedures to obtain and 
retain supporting documentation for the estimated value of in-kind 
donations and require that the financial information be recorded; 
Status per Commission on the National Moment of Remembrance 
(Commission): The Commission now asks for all companies donating in-
kind to provide documentation to support their donations. This 
documentation is maintained in the Commission's office and recorded in 
the Commission's electronic log; 
Status per GAO: Closed. The Commission obtained the proper 
documentation for all in-kind donations received during fiscal year 
2005. 

Count: 10; 
Recommendations from GAO-05-791R: Discontinue listing No Greater Love's 
e-mail address and fax number on the Commission's business cards to 
assist in furthering the distinction of the Commission's and No Greater 
Love's management and activities; 
Status per Commission on the National Moment of Remembrance 
(Commission): The Commission received new business cards. The 
Commission would also like to reiterate what was stated in the 2004 GAO 
report: "No Greater Love still donates the time of one of its employees 
to the Commission; as of the end of June 2004, both entities have 
separate facilities, and separate phones and fax numbers. The White 
House Commission on the National Moment of Remembrance and No Greater 
Love are two different entities and their purposes are different. None 
of No Greater Love's programs were supported by the Commission";
Status per GAO: Closed. The Commission's business cards no longer 
include the e-mail address and fax number for No Greater Love. 

Source: GAO. 

[End of Table] 

[End of Section]

FOOTNOTES 

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

[2] Office of Management and Budget, Memorandum for the Heads of 
Executive Departments and Agencies, Chief Financial Officers and 
Inspectors General: Amendments to OMB Bulletin No. 01-02, Audit 
Requirements for Federal Financial Statements, M-04-22, at 13 
(Washington, D.C.: July 27, 2004). 

[3] Pub. L. No. 107-289, 116 Stat. 2049 (Nov. 7, 2002) (codified, as 
amended, at 31 U.S.C. § 3515). 

[4] Reportable conditions are matters coming to the auditor's attention 
that in the auditor's judgment should be communicated because they 
represent significant deficiencies in the design or operation of 
internal control, which could adversely affect the entity's ability to 
meet the internal control objectives described in the report. 

[5] GAO, Financial Management: Audit of the White House Commission on 
the National Moment of Remembrance for Fiscal Year 2004, GAO-05-791R 
(Washington, D.C.: July 21, 2005). 

[6] Congress appropriated $500,000 in fiscal year 2002 and $250,000 per 
year in fiscal years 2003 through 2005. See, respectively, Pub. L. No. 
107-117, 115 Stat. 2230, 2299 (Jan. 10, 2002); Pub. L. No. 108-7, div. 
J, title IV, 117 Stat. 11, 460 (Feb. 20, 2003); Pub. L. No. 108-199, 
div. F, title IV, 118 Stat. 3, 340 (Jan. 23, 2004); and Pub. L. No.108- 
447, div. I, title III, 118 Stat. 2809, 3337 (Dec. 8, 2004). 

[7] In-kind donations are noncash assets and contributed services--such 
as Web site hosting and the use of facilities and staff. 

[8] For financial statement audits, generally accepted government 
auditing standards incorporate the standards of the American Institute 
of Certified Public Accountants. 

[9] Under the Accountability of Tax Dollars Act of 2002, the Director 
of OMB may, under certain conditions, exempt certain covered executive 
agencies from the financial statement requirements of the 
Accountability of Tax Dollars Act of 2002 for a particular fiscal year. 
See Pub. L. No. 107-289, § 2(a)(4), 116 Stat. 2049 (Nov. 7, 2002) 
(codified at 31 U.S.C. § 3515(e)). 

[10] OMB requirements incorporate both generally accepted government 
auditing standards and AICPA auditing standards. OMB Bulletin No. 01-02 
was superseded by OMB Bulletin No. 06-03, Audit Requirements for 
Federal Financial Statements, on August 23, 2006. 

[11] U.S. generally accepted government auditing standards require 
audit organizations to have an external peer review conducted at least 
once every 3 years by reviewers independent of the organization being 
reviewed. The external peer review should determine whether, during the 
period under review, the reviewed audit organization's internal quality 
control system was adequate and whether quality control policies and 
procedures were being complied with to provide the audit organization 
with reasonable assurance of conforming with applicable professional 
standards. 

[12] Generally accepted auditing standards require the auditor to send 
a letter of audit inquiry to the entity's legal counsel. A response to 
this letter is the auditor's primary means of obtaining corroboration 
of the information furnished by management concerning litigation, 
claims, and assessments. Evidential matter obtained from legal counsel 
with whom the entity consulted during the period under audit may 
provide the auditor with the necessary corroboration. Legal counsel for 
the Commission did not respond to the auditor's letter of audit inquiry 
because the Commission did not have a memorandum of understanding in 
place with VA, which provided legal counsel during fiscal year 2005. 

[13] GAO-05-791R. 

[14] See the Federal Acquisition Regulation on simplified acquisition 
procedures, codified, in part, at 48 C.F.R. § 13.104(b)(2004). 

[15] The Federal Travel Regulation implements statutory requirements 
and executive branch policies for travel by federal civilian employees. 
It is promulgated by the General Services Administration and codified 
at 41 C.F.R., chapters 300-304. 

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