Management's Discussion & Analysis

Systems, Controls, and Legal Compliance

Systems

As Federal agencies demonstrate success in obtaining and keeping an unqualified opinion on their audited financial statements, the Federal Government continues to face challenges in implementing financial systems that meet Federal requirements, but progress has been made.  The number of agencies reporting compliance with the Federal Financial Management Improvement Act (FFMIA) in FY 2010 remains at 17, and the number of auditors reporting compliance with FFMIA remains at 14 (see Appendix F).  The annual compliances reported each year underscores the importance of current initiatives to standardize the financial management practices across the Federal Government.

Controls

Federal managers have a fundamental responsibility to develop and maintain effective internal control.  Effective internal controls help to ensure that programs are managed with integrity and resources are used efficiently and effectively through three objectives:  effective and efficient operations, reliable financial reporting, and compliance with applicable laws and regulations.  The safeguarding of assets is a subcomponent of each objective.

The OMB Circular No. A-123, Management’s Responsibility for Internal Control, is the policy document that implements the requirements of 31 U.S.C. 3512 (c), (d) (commonly known as the Federal Managers’ Financial Integrity Act or FMFIA).  Circular No. A-123 primarily focuses on providing agencies with a framework for assessing and managing risks more strategically and effectively.  The Circular contains multiple appendices that address, at a more detailed level, one or more of the objectives of effective internal control.  Appendix A provides a methodology for agency management to assess, document, test, and report on internal controls over financial reporting.  Appendix B requires agencies to maintain internal controls that reduce the risk of fraud, waste, and error in Government charge card programs.  Appendix C implements the requirements of the Improper Payments Information Act, which includes the measurement, reporting, and remediation of improper payments.

In addition to the FY 2010 agency financial statement audit results, the total number of material weaknesses decreased from 38 to 31 and the total number of repeat material weaknesses decreased from 29 to 26.  Improvements were made in the controls over the financial statement preparation process, Property, Plant, and Equipment reporting, and liability reporting.  Effective internal controls are a challenge not only at the agency level, but also at the governmentwide level.  GAO reported that at the governmentwide level, material weaknesses resulted in ineffective internal control over financial reporting.  While progress is being made at many agencies and across the Government in identifying and resolving internal control deficiencies, continued diligence and commitment are needed.

Legal Compliance

Federal agencies are required to comply with a wide range of laws and regulations, including appropriations, employment, health and safety, and others.  Responsibility for compliance primarily rests with agency management.  Compliance is addressed as part of agency financial statement audits.  Agency auditors test for compliance with selected laws and regulations related to financial reporting.  Certain individual agency audit reports contain instances of noncompliance.  None of these instances were material to the Government-wide financial statements. However, GAO reported that its work on compliance with laws and regulations was limited by the material weaknesses and scope limitations discussed in its report.