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Overview. Reporting RequirementsIntragovernmental Transactions (IGT)Examples Treasury RequirementsLevels of IGTDoD's Material WeaknessThe SolutionYour RoleResources. . Reporting Requirements. Generally Accepted Accounting Principles (GAAP) require the elimination of intragovernmental transactions from consolidated financial statements to prevent overstating accounts for intra/inter-entity activity.
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1. Kathy Sherrill
Office of the Under Secretary of Defense (Comptroller)
Accounting & Finance Policy & Analysis
703-614-7524 – kathy.sherrill@osd.mil
Intragovernmental Eliminations
2. Overview Reporting Requirements
Intragovernmental Transactions (IGT)
Examples
Treasury Requirements
Levels of IGT
DoD’s Material Weakness
The Solution
Your Role
Resources
3. Reporting Requirements Generally Accepted Accounting Principles (GAAP) require the elimination of intragovernmental transactions from consolidated financial statements to prevent overstating accounts for intra/inter-entity activity
IGT must be eliminated from the DoD and Government-wide financial statements
The basic idea is that a reader of financial statements is interested in seeing how the business did – business with yourself distorts that picture
Eliminating intra-entity balances has no impact on the bottom line, while eliminating the overstatement of assets, liabilities, revenues and expenses that occur when you carry intra-entity offsetting balances
IGT must be eliminated from the DoD and Government-wide financial statements
The basic idea is that a reader of financial statements is interested in seeing how the business did – business with yourself distorts that picture
Eliminating intra-entity balances has no impact on the bottom line, while eliminating the overstatement of assets, liabilities, revenues and expenses that occur when you carry intra-entity offsetting balances
4. Intragovernmental (IGT) Transactions Any transactions involving sales, services or transfers within or between two entities of the federal government
5. Examples of Intragovernmental Transactions Intragovernmental buy/sell transactions
Intragovernmental transfers
Employee benefits transactions
Intragov. Buy/sell examples:
Interfund Purchases
International Merchant Purchase Authorization Card (IMPAC) purchases from federal sources
General Services Agency (GSA) supply card purchases
GSA vehicle and space rental
Transportation purchased from US Transportation Command (USTRANSCOM), including those billed directly from USTRANSCOM or via PowerTrack
Supplies/services provided under Military Interdepartmental Purchase Request (MIPR) accepted category I (reimbursable)
Services provided under Inter/Intra-service Support Agreements
Transfer examples:
Assets transferred between federal partners (with or without resources)
Appropriation and Non-expenditure transfers
Employee Benefits:
Department of Labor
Office of Personnel ManagementIntragov. Buy/sell examples:
Interfund Purchases
International Merchant Purchase Authorization Card (IMPAC) purchases from federal sources
General Services Agency (GSA) supply card purchases
GSA vehicle and space rental
Transportation purchased from US Transportation Command (USTRANSCOM), including those billed directly from USTRANSCOM or via PowerTrack
Supplies/services provided under Military Interdepartmental Purchase Request (MIPR) accepted category I (reimbursable)
Services provided under Inter/Intra-service Support Agreements
Transfer examples:
Assets transferred between federal partners (with or without resources)
Appropriation and Non-expenditure transfers
Employee Benefits:
Department of Labor
Office of Personnel Management
6. Examples of Non-Federal Transactions Payments to individuals
Payments to vendors/contractors
Direct-cite MIPRs
Transactions with state/local governments
Transactions with Non-Appropriated Funds The key is: Is the entity funded with an appropriation from the Federal Government?
Note that some vendors/contractors use US, Federal or Government in their titles – this does not mean they are Federal entities. USDA Grad School is an example – this entity is non-federal!
Example of payments to individuals:
Payroll, travel, awards, leave etc.
Direct-cite MIPRs:
(Category II)
Note: Emphasize the difference between direct-cite and reimbursable MIPRs
The key is: Is the entity funded with an appropriation from the Federal Government?
Note that some vendors/contractors use US, Federal or Government in their titles – this does not mean they are Federal entities. USDA Grad School is an example – this entity is non-federal!
Example of payments to individuals:
Payroll, travel, awards, leave etc.
Direct-cite MIPRs:
(Category II)
Note: Emphasize the difference between direct-cite and reimbursable MIPRs
7. Treasury Requirements US Standard General Ledger (USSGL) reporting with attributes
“F” = intragovernmental
“N” = non-federal
Trading partner list for all “F” transactions
Reciprocal Categories
Reconciliation
Detail documents must be established within source systems with proper federal/non-federal identifiers
Trading partners must be discernable
“F” Transactions:
For all “F” transactions reported to Treasury a list of partners must be provided
IGT is reported by reciprocal categories:
Definition: Reciprocal categories = pairings of related USSGL accounts used to reconcile and eliminate like IGT (available on Treasury website – websites at end of briefing)
Examples of reciprocal categories:
Revenues/Expenses (and Capitalized Assets)
Accounts Receivable/Accounts Payable
Transfers In/Transfers Out
For a complete list refer to
Reconciliation:
Mandatory reconciliation with fiduciary partners (DoL and OPM)
DoD must prepare a report of level 1 differences
Requires CFO to certify balances reported!Detail documents must be established within source systems with proper federal/non-federal identifiers
Trading partners must be discernable
“F” Transactions:
For all “F” transactions reported to Treasury a list of partners must be provided
IGT is reported by reciprocal categories:
Definition: Reciprocal categories = pairings of related USSGL accounts used to reconcile and eliminate like IGT (available on Treasury website – websites at end of briefing)
Examples of reciprocal categories:
Revenues/Expenses (and Capitalized Assets)
Accounts Receivable/Accounts Payable
Transfers In/Transfers Out
For a complete list refer to
Reconciliation:
Mandatory reconciliation with fiduciary partners (DoL and OPM)
DoD must prepare a report of level 1 differences
Requires CFO to certify balances reported!
8. Levels of Intragovernmental Transactions Treasury recognizes 2 levels
Level 1 = Between DoD and Non-DoD Entities
Level 2 = Between DoD Components
DoD recognizes additional levels
Level 3 = Within DoD Components
Level 4 = Between DoD Agencies
Level 5 = Between Entities of one Agency
Level 6 = Within an Entity Examples:
Level 1: DoD to GSA, or
DoD to Dept. of Commerce, etc.
Level 2 = Between DoD entities:
Army to Navy, or
Other Defense Agencies to Air Force
Levels 4-6 are subdivisions of level 3 in DDRS:
Level 4:
Army GF to Army WCF, or
DLA GF to DLA WCF
Level 5 = Between business areas of the same fund:
DLA Distribution Depots to DLA Supply management, or
Army O&M to Army MILCON
Level 6 = Within a business area:
DLA Distribution Depots to DLA Distribution Depots, or
Army O&M to Army O&M
Note: All transactions below level 1 are eliminated from the DoD consolidated financial statements. The only IGT remaining in DoD consolidated statements are transactions between DoD and other Federal partners.
Note: Talk to your service provider to help you drill down in DDRS.Examples:
Level 1: DoD to GSA, or
DoD to Dept. of Commerce, etc.
Level 2 = Between DoD entities:
Army to Navy, or
Other Defense Agencies to Air Force
Levels 4-6 are subdivisions of level 3 in DDRS:
Level 4:
Army GF to Army WCF, or
DLA GF to DLA WCF
Level 5 = Between business areas of the same fund:
DLA Distribution Depots to DLA Supply management, or
Army O&M to Army MILCON
Level 6 = Within a business area:
DLA Distribution Depots to DLA Distribution Depots, or
Army O&M to Army O&M
Note: All transactions below level 1 are eliminated from the DoD consolidated financial statements. The only IGT remaining in DoD consolidated statements are transactions between DoD and other Federal partners.
Note: Talk to your service provider to help you drill down in DDRS.
9. Note: Credit goes to Dale Yeakel of DLA for creating the base chart – I’ve modified his chart.
This is a pictorial to show you what happens to IGT when reports are consolidated at the various levels.
Legend at bottom indicates the various levels of transactions in color and by number.
The picture shows you in color at what point transactions are eliminated from the financial statements.
Note that level 6 has no color and there is no level 6 line on the chart – that is because level 6 transactions are already eliminated from a business area financial statement: the only way to see them is by querying DDRS for level 6 eliminations:
For example: Look at any WCF (or GF) consolidating financial statement in DDRS – there will be columns for each business area, an eliminations column, and a consolidated column. The business area columns will contain transactions between the business areas (level 5) and all levels above. The total of the transactions between the business areas of that entity reflect in the eliminations column and are deducted from the consolidated total.
Level 6 transactions (within the same business area) are already eliminated from the business area column – you will never see them in a report – to see them you must query DDRS (trading partner reports)
Note: There are several trading partner reports are available in DDRS – they are extremely helpful – I highly suggest you make use of them! They are also helpful for variance analysis, as changes in the level of intra-entity activity between periods can explain a portion of your variance!Note: Credit goes to Dale Yeakel of DLA for creating the base chart – I’ve modified his chart.
This is a pictorial to show you what happens to IGT when reports are consolidated at the various levels.
Legend at bottom indicates the various levels of transactions in color and by number.
The picture shows you in color at what point transactions are eliminated from the financial statements.
Note that level 6 has no color and there is no level 6 line on the chart – that is because level 6 transactions are already eliminated from a business area financial statement: the only way to see them is by querying DDRS for level 6 eliminations:
For example: Look at any WCF (or GF) consolidating financial statement in DDRS – there will be columns for each business area, an eliminations column, and a consolidated column. The business area columns will contain transactions between the business areas (level 5) and all levels above. The total of the transactions between the business areas of that entity reflect in the eliminations column and are deducted from the consolidated total.
Level 6 transactions (within the same business area) are already eliminated from the business area column – you will never see them in a report – to see them you must query DDRS (trading partner reports)
Note: There are several trading partner reports are available in DDRS – they are extremely helpful – I highly suggest you make use of them! They are also helpful for variance analysis, as changes in the level of intra-entity activity between periods can explain a portion of your variance!
10. DoD’s Material Weakness DoD cannot support eliminations with the details required to pass an audit
No transaction level support
A large portion of IGT and partners estimated
Unsupported transactions to “force” IGT
To achieve an unqualified audit opinion DoD must overcome this obstacle
IGT and partners are estimated:
Sellers drive balances
Accommodation for entities with waivers
The impact when we don’t properly report IGT is:
Unsupported Entries:
Reclassifications between “F” and “N”
Sometimes we must accrue if there appears not to be enough IGT to eliminate or reclass
We may recognize invalid losses and gains
I’m sure you all have read the articles about the billions of dollars of adjustments – we will never pass audit as long as we’re doing this to any material extent
If the adjustments posted to force IGT are not “correct” we actually do misstate our bottom line:
Example: We cannot reconcile transfers in/out, so most simply eliminate the two against one-another and recognize a gain or loss for the difference – this gain or loss misstates the consolidated entity financial statements
(Hopefully, the other side of those missing tranfsers are on another DoD entity, and the gains/losses will be offset in the long run!)
If you think about it, you can come up with many other examples of the often material impact these adjustments can have on the entity, DoD and even the governmentwide statements
Emphasis: These are the entity’s financial statements, and therefore they are the entity’s IGT
In many cases DFAS compiles much of the detail trading partner data for you -
In some cases, DFAS makes the adjustments for you – you are responsible for these balances and for the resulting adjustments
Make it a priority to know what your trading partner balances are and do a sanity check!
If adjustments are required, think through possible causes of the imbalance and determine what entries to make based upon that analysis – don’t just mindlessly reclass!
If you disagree with balances charged to you by another partner – CHALLENGE them!
Open a dialogue with partners you consistently have material differences with - even without perfect systems we can get much closer if we all understand and work at itIGT and partners are estimated:
Sellers drive balances
Accommodation for entities with waivers
The impact when we don’t properly report IGT is:
Unsupported Entries:
Reclassifications between “F” and “N”
Sometimes we must accrue if there appears not to be enough IGT to eliminate or reclass
We may recognize invalid losses and gains
I’m sure you all have read the articles about the billions of dollars of adjustments – we will never pass audit as long as we’re doing this to any material extent
If the adjustments posted to force IGT are not “correct” we actually do misstate our bottom line:
Example: We cannot reconcile transfers in/out, so most simply eliminate the two against one-another and recognize a gain or loss for the difference – this gain or loss misstates the consolidated entity financial statements
(Hopefully, the other side of those missing tranfsers are on another DoD entity, and the gains/losses will be offset in the long run!)
If you think about it, you can come up with many other examples of the often material impact these adjustments can have on the entity, DoD and even the governmentwide statements
Emphasis: These are the entity’s financial statements, and therefore they are the entity’s IGT
In many cases DFAS compiles much of the detail trading partner data for you -
In some cases, DFAS makes the adjustments for you – you are responsible for these balances and for the resulting adjustments
Make it a priority to know what your trading partner balances are and do a sanity check!
If adjustments are required, think through possible causes of the imbalance and determine what entries to make based upon that analysis – don’t just mindlessly reclass!
If you disagree with balances charged to you by another partner – CHALLENGE them!
Open a dialogue with partners you consistently have material differences with - even without perfect systems we can get much closer if we all understand and work at it
11. The Solution The Intragovernmental Transactions Exchange (IGTE)
OMB Business rules
IGTE addresses only level 1 transactions
The DoD Intragovernmental Transactions System (IGTS)
Summarize buyer/seller data for supported IGT
Capture details where current systems cannot
Repository of all IGT for reconciliation
You will hear about our solution in another briefing shortly.You will hear about our solution in another briefing shortly.
12. Your Role in IGT Improvement Take ownership of the process
Provide input
Understand the impact of IGT
Make informed decisions
Challenge as appropriate
Waived entities
Ensure integrity of buyer data pushed to sellers
Validate that sellers match your data in DDRS
Waived entities do not “adjust”, they correct
Strive to know your trading partners at all levels
Provide/validate trading partner data for entry to DDRS
Note that this includes outside DoD (Level 1) data! If necessary do a datacall to properly identify
Review elimination details in DDRS
After each quarter identify partners with large differences and work with them
Note: While we allow sellers and waived entities to drive, you can and should challenge if you have support.
Strive to know your trading partners at all levels
Provide/validate trading partner data for entry to DDRS
Note that this includes outside DoD (Level 1) data! If necessary do a datacall to properly identify
Review elimination details in DDRS
After each quarter identify partners with large differences and work with them
Note: While we allow sellers and waived entities to drive, you can and should challenge if you have support.
13. Resources Treasury FMS FACTS I Regulations Website:
http://www.fms.treas.gov/factsi/regulations.html
Treasury FMS USSGL Website:
http://www.fms.treas.gov/ussgl
OMB Website:
http://www.whitehouse.gov/omb
GAO Website:
http://www.gao.gov
DoDFMR Volume 6b, Chapter 13:
http://www.dod.mil/comptroller/fmr