Recommendation: ODCFO should update the CAP template provided in its guidance to assist components in developing CAPs to include the year deficiencies are first identified data element defined in the Implementation Guide for OMB Circular A-123. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should update the NFR Database with a field to record the year deficiencies are first identified. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should incorporate appropriate steps to improve its CAP review process, including ensuring that (1) data elements not included in CAPs are appropriately identified and communicated to components and resolved, (2) NFRs are appropriately linked to the correct CAPs to address them, and (3) components document their rationale for accepting the risk associated with certain deficiencies and appropriately identify such instances in the NFR Database. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should update DOD guidance to instruct DOD and components to document root-cause analysis when needed to address deficiencies auditors identified. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should include appropriate steps in its monthly NFR Database review process to evaluate and follow-up on previously identified exceptions to ensure that they are resolved timely. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary of Defense (Comptroller) should, in collaboration with the Under Secretary of Defense (Acquisition and Sustainment), develop and implement a DOD-wide strategy to remediate real property asset control issues. (Recommendation 1).

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it was committed to placing increased leadership emphasis on real property asset controls to ensure mission readiness, audit readiness, testing for existence and completeness, and maintaining internal controls.

Recommendation: The Under Secretary of Defense (Comptroller) should, in collaboration with the Under Secretary of Defense (Acquisition and Sustainment), develop department-wide instructions for performing the E&C verifications. (Recommendation 2).

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it was committed to placing increased leadership emphasis on real property asset policies and instructions to ensure consistent and repeatable existence and completeness verifications.

Recommendation: We recommend that the Secretary of the Treasury ensure that the Fiscal Assistant Secretary enhances Treasury's procedures for the aggregate analysis to consider the impact of all amounts not obtained from significant entity audited financial statements on the reliability of the CFS and use the results to determine if audit coverage is needed for any information. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: In commenting on our draft report, Treasury stated that it has already taken steps to address this recommendation by updating guidance to federal entities for the preparation of the fiscal year 2020 Agency Financial Reports or Performance and Accountability Reports. In addition, Treasury stated that it has drafted a memo to the Federal Accounting Standards Advisory Board to seek clarification of existing guidance related to reporting differences for federal entities that prepare financial reports according to FASB standards.

Recommendation: We recommend that the Secretary of the Treasury ensure that the Fiscal Assistant Secretary enhances Treasury's process for revising accounting and reporting policies to reasonably assure that financial information—including the SOCNP, Funds from Dedicated Collections note, and Other Liabilities note—is prepared in accordance with U.S. GAAP and sufficiently documented to allow effective management review. (Recommendation 2)

Agency: Department of the Treasury
Status: Open

Comments: In commenting on our draft report, Treasury stated that it has already taken steps to address this recommendation by updating guidance to federal entities for the preparation of the fiscal year 2020 Agency Financial Reports or Performance and Accountability Reports.

Recommendation: We recommend that the Secretary of the Treasury ensure that the Fiscal Assistant Secretary enhances existing procedures to reasonably assure that disclosures for financial information incorporated using accounting standards issued by FASB are prepared in accordance with U.S. GAAP, such as improving (1) the quantitative analysis to consider all FASB information included in the CFS, (2) the FASB questionnaire to consider all relevant disclosures and obtain responses from all significant component entities, and (3) procedures for sufficiently documenting analyses and conclusions related to FASB information in the CFS. (Recommendation 3)

Agency: Department of the Treasury
Status: Open

Comments: In commenting on our draft report, Treasury stated that it drafted a memo to the Federal Accounting Standards Advisory Board to seek clarification of existing guidance related to reporting differences for federal entities that prepare financial reports according to FASB standards.

Recommendation: Congress should consider legislation to require each CFO at a CFO Act agency to oversee and provide leadership for all of the responsibilities necessary to effectively carry out federal financial management activities, including the formulation and financial execution of the budget, planning and performance, risk management, internal control, financial systems, and accounting. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language to clarify the duties and responsibilities of the CFO, including the formulation and financial execution of the budget, planning and performance, risk management, internal control, financial systems, and accounting. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require deputy CFOs in CFO Act agencies to have defined responsibilities consistent with the breadth of those of the agency CFOs. (Matter for Consideration 2)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language to specify that the deputy CFO shall assist the agency CFO in the performance of each of the duties of the agency CFO. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the Director of OMB to prepare and submit to the appropriate committees of Congress a government-wide 4-year financial management plan (with timing to match the GPRA reporting requirements) and an annual financial management status report.

a. The plan should include actions for improving financial management systems, strengthening the federal financial management workforce, and better linking performance and cost information for decision-making.

b. The plan should be developed in consultation with the CFO Council, the Chief Information Officers Council, the Chief Data Officer Council, the Chief Acquisition Officers Council, CIGIE, GAO, and other appropriate financial management experts. (Matter for Consideration 3)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for a government-wide 4-year financial management plan and an annual financial management status report. The plan is to address actions for improving financial management systems, strengthening the federal financial management workforce, and better linking performance and cost information for decision-making. The plan is to be developed in consultation with the CFO Council, the Chief Information Officers Council, the Chief Data Officer Council, the Chief Acquisition Officers Council, CIGIE, GAO, and other appropriate financial management experts. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require each CFO at a CFO Act agency, in consultation with financial management and other appropriate experts, to prepare an agency plan to implement the 4-year government-wide financial management plan prepared by OMB. (Matter for Consideration 4)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the CFO of each CFO Act agency to prepare, in consultation with financial management and other appropriate experts, an agency plan to implement the 4-year financial management plan prepared by the Director of the Office of Management and Budget and to achieve and sustain effective financial management in the agency. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the Director of OMB to prepare comprehensive financial management performance-based metrics and use these metrics to evaluate the financial management performance of executive agencies. The metrics should be included in the government-wide and agency-level financial management plans, and agencies' performance against the metrics should be reported in the annual financial management status reports. (Matter for Consideration 5)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the Director of OMB to prepare comprehensive financial management performance-based metrics, which are to be used to evaluate the financial management performance of executive agencies. These metrics are to be included in the government-wide and agency-level financial management plans, and agencies' performance against the metrics are to be reported in annual financial management status reports. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the head of each executive agency to identify, and if necessary develop, the key financial management information, in addition to financial statements, needed for effective financial management and decision-making. (Matter for Consideration 6)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the head of each CFO Act agency to identify key financial management information needed for effective financial management decision-making. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the head of each executive agency to annually assess and separately report their conclusion on the effectiveness of internal controls of the agency over financial reporting and other key financial management information. (Matter for Consideration 7)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the head of each CFO Act agency to annually assess and separately report on the effectiveness of internal controls of the agency over financial reporting and other key financial management information. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require auditors, as part of each financial statement audit of an executive agency, to test and report on internal control over financial reporting and other key financial management information. (Matter for Consideration 8)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the financial statement auditors of each CFO Act agency to report on their evaluation of internal control over financial reporting and other key financial management information. We will continue to monitor the status of this bill.

Recommendation: The Director of DFAS should, in accordance with the FMR, implement procedures to help ensure that FBWT reconciliations are consistently performed and that all DFAS sites review and document research conducted on the causes of any differences arising from these reconciliations. (Recommendation 1)

Agency: Department of Defense: Defense Finance and Accounting Service
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. They stated that the Defense Finance and Accounting Service (DFAS) will update the Financial Management Regulation (FMR) and implement procedures to help ensure Fund Balance with Treasury (FBWT) reconciliations are performed consistently and appropriate research on the causes of any difference arising from these reconciliations is reviewed and documented by all DFAS sites. Further, DFAS will update internal documentation/policy to outline DFAS roles and processes for FBWT reconciliations as well as include guidance on the execution of DOD's FMR FBWT reconciliation requirements. The estimated completion date for the implementation of this recommendation is December 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should update the FMR to clearly define the required supporting documentation for system-generated accounting adjustments, including the required documentation of business rules driving the recording of these adjustments, such as documentation of the programming logic. (Recommendation 2)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. They stated that the Department is developing a checklist of required supporting documents for incorporation into the DOD Financial Management Regulations (FMR). They will update the DOD FMR Volume, 6A, Chapter 2 to define the required supporting documentation for system generated accounting adjustments. Additionally, the Defense Finance and Accounting Service (DFAS) will update internal documentation to include narratives outlining the business rules for system generated accounting adjustments with the required supporting documentation. The estimated completion date for the implementation of this recommendation is December 2020. We will continue to follow up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should perform and document a comprehensive review of the FMR accounting adjustment category codes to determine their ongoing applicability or the need for additional codes to reflect the current financial reporting environment. (Recommendation 3)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department intends to collaborate with the financial community to update the category codes within the DOD Financial Management Regulations (FMR). Specifically, the Office of the Under Secretary of Defense will perform a comprehensive review of Journal Voucher Category Codes listed in DOD FMR, Volume 6A, Chapter 2 and update regulations based on feedback. The Defense Finance and Accounting Service will update internal documentation and procedures to reflect any code changes identified in the revised DOD FMR. The estimated completion date for this recommendation is July 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should establish procedures to help ensure the consistent implementation of the requirements of DFAS Form 9339. (Recommendation 4)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department plans to update the Defense Finance and Accounting Service (DFAS) Form 9339 and develop and conduct refresher training to all users of the Form 9339. The estimated completion date for this recommendation is September 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should update policies and procedures to identify the causes of out-of-balance accounting adjustments and resolve the causes in a timely manner. (Recommendation 5)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department is collaborating on utilizing existing data to identify and resolve out-of-balances and update DOD Financial Management Regulation, Volume 6A, Chapter 2 to include a section conveying out-of-balance accounting adjustments are not authorized. Root cause analysis efforts will be performed in conjunction with corrective action plans (CAPs) for recommendations 6--8. The estimated completion date for this recommendation is December 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller), in conjunction with the Director of DFAS, should develop and implement policies and procedures to help ensure that root cause analyses for accounting adjustments are consistently performed and documented across DOD. (Recommendation 6)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department, in conjunction with the Director of Defense Finance and Accounting Service (DFAS), intends to utilize existing advanced analytics tools to research and document root cause analyses. The estimated completion date for the implementation of this recommendation is December 2020. We will continue to follow-up on this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller), in conjunction with the Director of DFAS, should develop and implement policies and procedures to help ensure consistent development, implementation, monitoring, and documentation of action plans across DOD that address accounting adjustment causes that staff identified internally. (Recommendation 7)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department intends to collaborate with the financial community, including the Director of the Defense Financial and Accounting Service (DFAS), and utilize existing tools for documenting and implementing consistent procedures for action plans of accounting adjustments. The analytical tool, Advana will be used to analyze the action plan code for consistent analysis to be performed across the DOD. The estimated completion date for the implementation of this recommendation is February 2021. We will continue to follow-up on this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller), in conjunction with the Director of DFAS, should develop and implement procedures across DOD that include clearly defined outcomes focused on reducing accounting adjustments (supported and unsupported) with specific actionable steps and procedures for achieving stated goals. (Recommendation 8)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department, in conjunction with the Director of the Defense Finance and Accounting Service, plans to utilize existing tools to define and measure the outcomes of accounting adjustments. The estimated completion date for the implementation of this recommendation is April 2021. We will continue to follow-up on this recommendation.

Recommendation: The Secretary of the Treasury should ensure that the Fiscal Assistant Secretary enhances existing procedures for Treasury management to perform additional reviews for restatements, reclassifications, and adjustments to beginning net position to reasonably assure that they are properly supported and accurately reported. (Recommendation 2)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), we determined that this recommendation remains open. Treasury enhanced its procedures to include additional management reviews, particularly the Financial Reports and Advisory Division Director, for restatements, reclassifications, and adjustments to beginning net position. Although FRAD took steps to enhance its review procedures, the additional review did not prevent FRAD from including descriptions in the draft CFS that were not supported by entity financial statements or from excluding some information from the CFS notes. Further steps are needed to define procedures to ensure consistent and accurate treatment of restatements, reclassifications, and adjustments to beginning net position in the CFS. We will follow-up on progress made by Treasury as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should ensure that the Fiscal Assistant Secretary, working in coordination with the Controller of OMB, establishes effective processes and procedures to reasonably assure that appropriate information regarding legal contingency losses is reported in the CFS. (Recommendation 4)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), we determined that this recommendation remains open. Treasury and OMB (1) increased guidance to federal entities in the Treasury Financial Manual section 2-4700; (2) included an illustrative Contingent Loss Table in OMB Circular No. A-136 for agencies to use as guidance when reporting probable and reasonably possible losses; (3) provided guidance to agencies through monthly Central Reporting Team (CRT) meetings with the agencies' financial reporting staff and at the Government Financial Management Conference; (4) communicated regularly with Department of Justice officials regarding the preparation of the government-wide legal representation letter; and (5) increased the number of Treasury staff performing the legal letter analysis. However, we noted inconsistencies among the significant component entities' financial statement note disclosures, management schedules, and legal representation letters, and the legal contingency loss information reported in the CFS, as well as inconsistencies between entities' year-end management schedules/legal representation letters and the final government-wide legal representation letter. We will follow-up on progress made by Treasury as part of our fiscal year 2020 CFS audit.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism to reasonably assure that all the journal entries recorded in the Schedules of the General Fund general ledgers can be readily identified and traced, such as through a unique identifier, to determine the effect of a transaction on all applicable general ledger accounts and line items of the Schedules of the General Fund, including the budget deficit. (Recommendation 1)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism to reasonably assure that payment transactions recorded in the Schedules of the General Fund general ledgers capture all of the key information needed, including payment schedules if applicable, to readily trace transactions to the information certified by the federal agency. (Recommendation 2)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement additional reporting requirements with related guidance for federal agencies that better align with the General Fund financial reporting objectives and enable Fiscal Service to capture the effect of a transaction on all applicable general ledger accounts and line items of the Schedules of the General Fund, including the budget deficit. (Recommendation 3)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: We recommend that the Commissioner of Fiscal Service develop and implement a process that would enable Fiscal Service to obtain the information necessary to effectively assess the effect of the Statement of Difference on the Schedules of the General Fund for those federal agencies that have not implemented the Central Accounting and Reporting System. (Recommendation 4)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: We recommend that the Commissioner of Fiscal Service design and implement procedures to evaluate risks and monitor internal controls over financial reporting relevant to the Schedules of the General Fund. (Recommendation 5)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism for evaluating agencies' use of BETCs based on the enhanced guidance. (Recommendation 7)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should design and implement procedures to (1) obtain and review supporting documentation for reported activity included on Agency Submission Forms and (2) assess the overall completeness of federal agency activity reported on Agency Submission Forms. (Recommendation 8)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should design and implement procedures to periodically review all active Treasury accounts to determine whether they are valid and the related General Fund account balances are consistent with federal agency records. (Recommendation 10)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should enhance current procedures for reviewing negative balances to include Treasury accounts with indefinite periods of availability. (Recommendation 11)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB, to improve corrective action plans for (1) treaties and international agreements, (2) additional audit procedures for intragovernmental activity and balances, and (3) the Reconciliation Statements so that they include sufficient information to address the control deficiencies in these areas effectively.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), we determined that this recommendation remained open. Treasury believes that its current remediation plan, including its various corrective action plans (CAPs), is comprehensive, appropriate, and effective, with robust and ongoing monitoring processes in place. However, we continue to note that the CAPs in these three areas do not include sufficient steps to effectively address related control deficiencies involving processes used to prepare the CFS. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.