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 Commissioner of Internal Revenue should finalize the PDC program objectives so that they are clearly defined in consistent terms, and assure that the key program risks, measures, and targets are linked with the objectives. (Recommendation 1)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS partially agreed with recommendation. IRS said it would use consistent terms in developing measures that link to its PDC program objectives, but did not agree that program objectives are necessarily framed in terms of program risks. In December 2019, IRS provided new objectives linked with proposed measures to assess collection agencies. In February 2020, IRS said it intends to award new contracts in 2021 that will include performance measures linked to program objectives. To fully address GAO's recommendation, IRS also needs to identify targets for measures linked to program objectives.

Recommendation: The Commissioner of Internal Revenue should include the Department of the Treasury Inspector General for Tax Administration (TIGTA) costs in IRS's reporting of PDC program costs. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation. In October 2019 IRS said that including TIGTA costs in reporting program costs would be inconsistent with legislative requirements that define program costs as IRS's costs and with IRS cost-accounting practices. However, we maintain that the FAST Act set minimum reporting requirements to which IRS can add more information. Also, the existing cost accounting standards and practices to which IRS refers govern IRS's accounting for and reporting of costs incurred by IRS, not to fuller reporting of the PDC program's costs to the federal government. We will continue to pursue this recommendation and update its status in response to any changes.

Recommendation: The Commissioner of Internal Revenue should report the amount of collected revenue sent to the general fund of the Treasury and amounts retained by IRS to pay its costs. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with our recommendation and in October 2019 said it plans to report PDC revenue amounts going to the Treasury and to IRS's retained funds by February 2020. As of March 2020, we had not received documentation from IRS to demonstrate it had done so.

Recommendation: The Commissioner of Internal Revenue should analyze PDC program results to identify the types of cases that are not potentially collectible and should not be assigned to collection agencies. (Recommendation 4)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation and said such analysis is unnecessary due to a legal requirement to assign all such cases to collection agencies and because there is very little cost in doing so. Our report noted that IRS has the authority and responsibility for efficient program operations to not assign uncollectible debt cases. In February 2020, IRS said that the assignment and recall of cases add nothing to the cost. We disagree, noting that IRS has not supported this assertion. IRS incurred some portion of its PDC costs from assigning and recalling cases that collected no revenue. Even if these costs are minor, they would be greater than the amount collected. We maintain the importance of this recommendation because IRS has incurred tens of millions of dollars in costs with little or no revenue collected for most of the PDC cases that IRS has closed.

Recommendation: The Commissioner of Internal Revenue should analyze PDC program results and the cases not assigned to the PDC program to identify the types of inactive cases IRS will not pursue that could be assigned to collection agencies to improve PDC program results. (Recommendation 5)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed and noted that it already had the recommended analyses built into the PDC case identification process. IRS also provided documentation to GAO in December 2019 and its comments in February 2020 repeated its view that its process already identified other inactive cases that have not been assigned to PDC. IRS's documentation during the review and provided in December did not show how IRS analyzes its debt inventory and PDC results to identify inactive cases that are not being assigned to PDC but may be worth pursuing.

Recommendation: The Commissioner of Internal Revenue should clearly document and distinguish the complete list of identified risks to taxpayers in the PDC program risk register, and align the risks with PDC program objectives. (Recommendation 6)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019, on actions taken to implement the recommendation. IRS actions included a risk register with related information on the analyses and response to the listed risks.

Recommendation: The Commissioner of Internal Revenue should clearly document the severity of impacts of the taxpayer risks, as well as the likelihood of each taxpayer risk after responding to it, in the PDC program risk register, and use this information to prioritize risks to address and guide selection of risk responses. (Recommendation 7)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019, on actions taken to implement the recommendation. IRS actions included a risk register with related information on the analyses and response to the listed risks.

Recommendation: The Commissioner of Internal Revenue should clearly document how each risk response aligns with specific taxpayer risks in the PDC program risk register. (Recommendation 8)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019, on actions taken to implement the recommendation. IRS actions included a risk register with related information on the analyses and response to the listed risks.

Recommendation: The Commissioner of Internal Revenue should document how IRS's monitoring of the PDC program provides information on specific taxpayer risks and how well specific responses are working to address each risk, and should supplement IRS's monitoring of taxpayer complaints with Federal Trade Commission (FTC) complaint data. (Recommendation 9)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019 on actions taken to implement the recommendation, such as outreach to FTC on its system to record the complaints.

Recommendation: The Commissioner of Internal Revenue should more fully seek and document feedback from external stakeholders representing vulnerable taxpayers to identify and appropriately respond to possible PDC taxpayer risks. (Recommendation 10)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019 on actions taken to implement the recommendation, such as a system to record feedback received.

Recommendation: The Commissioner of Internal Revenue should clearly document an assessment of fraud risks related to the PDC program. (Recommendation 11)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with the recommendation and said that by June 2020, it would conduct a fraud risk assessment based on the Fraud Reduction and Data Analytics Act of 2015 and OMB guidance. We will update the status when we complete review of any documentation IRS provides on actions taken to implement the recommendation.

Recommendation: The Commissioner of Internal Revenue should ensure that its printed guidance to PDC taxpayers includes information about reporting scams to TIGTA. (Recommendation 12)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019 on actions taken to implement the recommendation.

Recommendation: To improve oversight of school finances and provide better information to schools and the public about its monitoring efforts, the Chief Operating Officer of the Office of Federal Student Aid should update the composite score formula to better measure schools' financial conditions and capture financial risks.

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: In September 2019, Education published updated regulations related to the financial responsibility composite score that include steps to address some of the limitations identified in our report. For instance, these regulations incorporate changes to better align the composite score calculations with recently updated accounting standards related to leases. In additional, these regulatory changes are designed to curb the ability of schools to manipulate their composite scores by clarifying what is considered "long-term debt" and requiring schools to disclose in their financial statements the terms of the debt and certify that the funds were used for capitalized assets rather than to fund operations. However, these regulatory updates do not fully address the current limitations of the composite score formula. For example, they do not reflect several other changes in accounting standards identified in our report or incorporate new financial metrics that would provide a broader indication of schools' financial health, such as liquidity, historical trend analysis, or future projections. Education has stated that it intends to explore further updates to the composite score methodology in future regulatory actions, and we will continue to monitor these efforts.

Recommendation: To improve oversight of school finances and provide better information to schools and the public about its monitoring efforts, the Chief Operating Officer of the Office of Federal Student Aid should improve guidance to schools about how the financial composite score is calculated, for example, by updating current guidance to include explanations about common areas of confusion and misinterpretation for schools.

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education agreed with this recommendation and that additional general guidance to schools would be helpful. The department also stated that it will update the guidance in its Federal Student Aid Handbook and may provide answers and related guidance to some frequently asked questions on its website. As of October 2019, Education had not completed these actions.