DOD Financial Management:

Significant Efforts Still Needed for Remediating Audit Readiness Deficiencies

GAO-17-85: Published: Feb 9, 2017. Publicly Released: Feb 9, 2017.

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khana@gao.gov

 

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What GAO Found

The Schedules of Budgetary Activity (Budgetary Schedules) for the Army, Navy, and Air Force for fiscal year 2015 reflected current year budget activity as an interim step toward producing an auditable Statement of Budgetary Resources that will reflect multiyear budget activity. All three of the independent public accountants (IPA) contracted to audit these fiscal year 2015 Budgetary Schedules issued disclaimers, meaning that the IPAs were unable to express an opinion because of a lack of sufficient evidence to support the amounts presented. The IPAs for all three military services also identified material weaknesses in internal control and collectively issued a total of over 700 findings and recommendations. These weaknesses included, among other things, the military services' inability to reasonably assure that the Budgetary Schedules reflected all of the relevant financial transactions that occurred and that documentation was available to support such transactions. Army, Navy, and Air Force management generally concurred with these findings and stated that they would develop and implement corrective actions to address the IPAs' recommendations.

Office of Management and Budget (OMB) guidance and the Department of Defense's (DOD) Financial Improvement and Audit Readiness (FIAR) Guidance include the following steps for addressing these and other financial management-related findings and recommendations reported by external auditors: (1) identify and track them, (2) prioritize them, (3) develop corrective action plans (CAP) to remediate them, and (4) monitor the implementation status of the CAPs. GAO found that the remediation processes designed by each military service had deficiencies in one or more of these areas. For example, each military service's policies and procedures lacked sufficient controls to reasonably assure that they identified and tracked the complete universe of open findings and recommendations related to financial management. Without identifying and tracking the complete universe of unresolved deficiencies, the military services cannot provide reasonable assurance that the deficiencies will be addressed in a timely manner, which can ultimately affect the reliability of financial information and the auditability of their financial statements.

The DOD Comptroller has established several elements of a department-wide audit readiness remediation process, but it does not have comprehensive information on the status of CAPs throughout the department needed to fully monitor and report on the progress being made to resolve financial management-related deficiencies. Specifically, (1) the DOD Comptroller does not obtain complete, detailed information on all CAPs from the military services related to the department's critical capabilities to be able to fully assess progress and (2) reports to external stakeholders such as the Congress on the status of audit readiness do not provide comprehensive information. A lack of comprehensive information on the CAPs limits the ability of DOD and Congress to evaluate DOD's progress toward achieving audit readiness, especially given the short amount of time remaining before the statutory deadline to submit to Congress the results of an audit of the department-wide financial statements for fiscal year 2018.

Why GAO Did This Study

DOD remains on GAO's High-Risk List because of its long-standing financial management deficiencies. These deficiencies negatively affect DOD's audit readiness and its ability to make sound mission and operational decisions. The Army, Navy, and Air Force underwent their first Budgetary Schedule audits for fiscal year 2015.

This report, developed in connection with fulfilling GAO's mandate to audit the U.S. government's consolidated financial statements, examines (1) the results of the audits of the fiscal year 2015 Budgetary Schedules for the Army, Navy, and Air Force; (2) the extent to which each military service designed a process to address financial management-related audit findings and recommendations; and (3) the extent to which DOD has designed a department-wide process to monitor and report on audit readiness remediation efforts. GAO reviewed IPA reports and documentation from the military services and DOD Comptroller and interviewed cognizant officials.

What GAO Recommends

GAO is making a total of eight recommendations to the Army, the Navy, the Air Force, and DOD to improve processes for tracking and monitoring financial management-related audit findings and recommendations. The military services concurred with the five recommendations to them, while DOD concurred with one and partially concurred with two of the recommendations directed to it. GAO continues to believe that the recommendations are valid, as discussed in the report.

For more information, contact Asif A. Khan at (202) 512-9869 or khana@gao.gov.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Priority recommendation

    Comments: The Army concurred with this recommendation. The Army stated that the Internal Review Directorate has completed updating its written standard operating procedures to include monitoring financial management-related external audit findings and recommendations. The Army stated that this new guidance includes an explanation of how recommendations will be tracked; how findings and recommendations will be prioritized; how status and progress of corrective action plans (CAPs) will be developed; and how the status and progress of CAPs will be monitored. We received documentation from the Army in January 2018 and, after assessing the provided information, we determined that the actions taken were sufficient to close this recommendation.

    Recommendation: The Secretary of the Army should direct the Internal Review Directorate under the Assistant Secretary of the Army, Financial Management and Comptroller, to develop written policies and procedures for all financial management-related audit findings and recommendations under its purview that include the following: (1) how the status of the recommendations will be tracked; (2) the process and criteria to be followed for prioritizing the findings and recommendations; (3) the process for developing CAPs to remediate the findings and recommendations, including the detailed CAP elements recommended by the Implementation Guide for OMB Circular A-123; and (4) the process for monitoring the status and progress of the CAPs, including the documentation to be maintained for monitoring CAP status and any actions to be taken if a lack of progress is found.

    Agency Affected: Department of Defense: Department of the Army

  2. Status: Open

    Priority recommendation

    Comments: The Army concurred with this recommendation. The Army stated that the Accountability and Audit Readiness Directorate has completed actions to enhance its current standard operating procedures to include (1) updating its corrective action plan (CAP) database and reporting tool, (2) documenting its reporting procedures, and (3) updating its CAP template to include additional elements recommended by the Implementation Guide for OMB Circular A-123. In addition, the Army stated that its policies and procedures include steps to incorporate external financial management-related audit findings assigned to the Accountability and Audit Readiness Directorate by the Internal Review Directorate and that the existing process the Army uses to prioritize findings and the related CAPs and to monitor the progress and status of CAPs has been documented. We reviewed Army's documentation that was provided in January 2020. Army's documentation did not show that it has a process for ensuring that all financial management related findings and recommendations are identified and tracked. To implement this recommendations Army needs to enhance their policies and procedures related to tracking and monitoring the status of these audit findings.

    Recommendation: The Secretary of the Army should direct the Accountability and Audit Readiness Directorate under the Assistant Secretary of the Army, Financial Management and Comptroller, to enhance the directorate's policies and procedures for (1) tracking and prioritizing all financial management-related audit findings and recommendations under its purview and (2) developing and monitoring CAPs for all such recommendations so that they include sufficient details, such as the criteria used to prioritize the CAPs, the recommended CAP elements, and the process for monitoring and documenting the progress and status of CAPs.

    Agency Affected: Department of Defense: Department of the Army

  3. Status: Closed - Implemented

    Priority recommendation

    Comments: The Navy concurred with this recommendation. The Navy stated that it is (1) recording new findings and recommendations on a weekly basis in its deficiency database, (2) reviewing historical audits to ensure that previous findings and recommendations are recorded, and (3) collaborating with audit agencies to establish a process to reconcile the status of recommendations to ensure that its deficiency database accurately reports open and closed recommendations. In response to our recommendations, the Navy restructured its deficiency database to allow for the monthly reporting of current open findings and recommendations by source and status. The Navy also completed its development of more detailed SOPs that established specific steps and procedures for maintaining and validating its database of audit deficiencies on a continuous basis. The Navy's restructured database and revised SOPs should improve the Navy's ability to accurately identify and track the status of auditor findings and recommendations from external sources.

    Recommendation: The Secretary of the Navy should, when finalizing the Navy's policies and procedures for identifying and tracking its CAPs to remediate financial management-related audit findings and recommendations, enhance this guidance so it includes detailed steps and specific procedures for confirming and validating the completeness and accuracy of the status of these audit findings and recommendations.

    Agency Affected: Department of Defense: Department of the Navy

  4. Status: Open

    Priority recommendation

    Comments: The Air Force concurred with this recommendation. In January 2018, the Air Force stated that it continues to develop a process for identifying and tracking financial management-related findings and recommendations from all audit sources by updating its process guidance. In August 2019, we received draft guidance that Air Force is developing as guidance and procedures for a universe of financial management-related findings and recommendations. In January 2020, we also received a list of the Air Force deficiencies being tracked in the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) database. After assessing the provided documentation, we found that the draft does not include procedures for identifying GAO, DODOIG, and Air Force Audit Agency (AFAA) findings and the database did not include deficiencies identified by those external auditors. As a result of our review of the documentation provided, we determined that the actions taken were not sufficient to close the recommendation.

    Recommendation: The Secretary of the Air Force should design and document a comprehensive process to ensure that the complete universe of all financial management-related findings and recommendations from all audit sources is identified and tracked.

    Agency Affected: Department of Defense: Department of the Air Force

  5. Status: Open

    Priority recommendation

    Comments: The Air Force concurred with this recommendation. In January 2018, the Air Force stated that its Air Force Deficiency Remediation Tracking processes and guides were being refined. In December 2019, Air Force provided a document titled "NFR Prioritization Process." We found that this document included Air Force's priority categories. However, the document does not include information on determining the priority level or applying the priority levels when addressing the deficiencies. We also received a copy of Air Force's guide for the Corrective Action Plan (CAP) process dated July 2019. We found that this guide does not fully incorporate CAP development for deficiencies from all sources. Additionally, the guide does not provide information on the process for (1) determining resources and other requirements for remediating the deficiency, (2) conducting a cost benefit analysis, and (3) developing criteria for validating that the deficiency has been remediated. The guide also includes a template for conducting a root cause analysis. However, the instructions for conducting a root cause analysis are somewhat limited for determining the initial cause or underlying reason for the deficiency. Per the guide, the Air Force uses the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) database to monitor and report on Air Force's deficiencies and remediation CAP status. We obtained a listing of the NFRs and related CAPS in the database as of December 2019. We found that deficiencies from all audit sources were not included in the listing, only the independent public accountant's NFRs. The results of our review of a limited number of CAPs indicate that Air Force staff does not always comply with the Air Force's CAP requirements. As a result of our assessment of the Air Force documentation, we determined that the actions taken were not sufficient to close the recommendation.

    Recommendation: The Secretary of the Air Force should update the Air Force's written policies and procedures for prioritizing financial management-related audit findings and recommendations from all audit sources and for developing and monitoring CAPs so that they include sufficient details. These procedures should include the following details: (1) The process to be followed for prioritizing the financial management-related findings and recommendations from audit sources. (2) The guidance for developing CAPs for all financial management-related audit findings and recommendations from all audit sources to include complete details, including the elements recommended by the Implementation Guide for OMB Circular A-123. (3) The process for monitoring the status of the CAPs for all financial management-related audit findings and recommendations from all audit sources, including the documentation to support any corrective actions taken, as recommended by the Implementation Guide for OMB Circular A-123.

    Agency Affected: Department of Defense: Department of the Air Force

  6. Status: Open

    Priority recommendation

    Comments: DOD concurred with this recommendation. DOD stated that it solicits input on a bi-monthly basis, on critical capability corrective action plans (CAPs) at a summary level. This information is provided routinely at regularly scheduled FIAR Governance Board meetings. DOD also stated that an updated notice of finding and recommendation (NFR) form template is being developed and will be provided to the military services to use for reporting this information so that it will include the recommended standard data elements outlined in OMB Circular A-123 to provide greater transparency into the nature of remediation plans. DOD also stated that FIAR Guidance will be updated to explicitly state that military services should include the OMB recommended standard data elements in CAPs. To implement this recommendation, DOD needs to provide documentation that shows that the military services are able to provide a summary of key information in the corrective action plans that at a minimum contains data elements recommended by the Implementation Guide for OMB Circular A-123. .

    Recommendation: To improve DOD management's process for monitoring the military services' audit remediation efforts and to provide timely and useful information to stakeholders as needed, the Secretary of Defense should direct the Secretary of the Army, the Secretary of the Navy, and the Secretary of the Air Force to prepare and submit to the Under Secretary of Defense (Comptroller), on at least a bimonthly basis for availability at the FIAR Governance Board meetings, a summary of key information included in the CAPs that at a minimum contains the data elements recommended by the Implementation Guide for OMB Circular A-123 for each CAP related to critical capabilities for achieving audit readiness.

    Agency Affected: Department of Defense

  7. Status: Open

    Priority recommendation

    Comments: DOD partially concurred with this recommendation. According to DOD, the military services already provide summary-level updates on their critical capability corrective action plans (CAPs) at FIAR Governance Board meetings. It also stated that the template that is used to present CAPs to the FIAR Governance Board meetings at the summary level has been updated to align CAPs to critical capabilities. DOD still needs to address how all of the data elements from the Implementation Guide for OMB Circular A-123 will be summarized or otherwise reported for all CAPs pertaining to critical capabilities across the Department. In addition, DOD stated that because the Under Secretary of Defense (Comptroller) takes responsibility for maintaining, monitoring, and reporting on the status of CAPs for the service providers and other defense organizations and of DOD-wide issues, the Comptroller will also summarize this information. However, DOD has not clarified what information from the military services will be summarized. To implement this recommendation, DOD needs to provide documentation that shows the Comptroller has prepared a consolidated CAP management summary on a bimonthly basis.

    Recommendation: To reasonably assure that DOD management and external stakeholders have a comprehensive picture of the status of corrective actions needed for audit readiness throughout the department, the Secretary of Defense should direct the Under Secretary of Defense (Comptroller) to prepare a consolidated CAP management summary on a bimonthly basis that includes the data elements referred to above on the status of all CAPs related to critical capabilities for the military services and for the service providers and other defense organizations.

    Agency Affected: Department of Defense

  8. Status: Closed - Implemented

    Priority recommendation

    Comments: DOD partially concurred with this recommendation. DOD has established an NFR database to monitor the status of NFRs and CAPs. As part of our engagement on the Status of the DOD Audit Remediation, we reviewed how DOD uses this database and determined that it fully addresses this recommendation.

    Recommendation: To facilitate the development of a consolidated CAP management summary and the ability to efficiently respond to stakeholder requests, the Under Secretary of Defense (Comptroller) should develop and implement a centralized monitoring and reporting process that at a minimum (1) captures department-wide information on the military services' and other defense organizations' CAPs related to critical capabilities, including the standard data elements recommended in the Implementation Guide for OMB Circular A-123, and (2) maintains up-to-date information on the status of these CAPs.

    Agency Affected: Department of Defense: Under Secretary of Defense (Comptroller)

 

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