Federal Entity Reporting Requirements For The Financial Report Of The United States Government
This Treasury Financial Manual (TFM) chapter prescribes how federal entities provide data for the Financial Report of the United States Government (FR) using the Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS) along with additional details from the audited entity's financial statements. This chapter also includes a listing of the federal entities included in the FR, a description of the Intra-governmental Transactions (IGT) process, and requirements for submitting pre-closing GTAS Adjusted Trial-Balance (ATB). Please refer to Office of Management and Budget (OMB) Circular No. A-136 for the reporting requirements for federal entities' audited financial statements.
This TFM chapter does not include all reporting requirements for GTAS. Additional information can be found on the GTAS website.
Section 4710—Scope and Applicability
All federal entities must provide Fiscal Service with the required fiscal year-end data that is used to prepare the FR. All federal entities (significant or other) must submit GTAS ATB data and manual adjustments that crosswalk to the federal entity’s audited financial statements, as the GTAS Balance Sheet and the reclassified financial statements provide the connection to the data in the FR. The term reclassified financial statements is only used for the financial statements that have not been standardized (Statement of Net Cost (SNC) and Statement of Operations and Changes in Net Position (SOCNP)) between the entity's financial statement lines and the government-wide financial statement lines. The Balance Sheet has been standardized between the entity and government-wide level. With this standardization, there is no longer a need to crosswalk between the federal entities' financial statement lines and the government-wide because the Balance Sheet is a one-to-one relationship. GTAS will crosswalk the GTAS ATB data to the financial statement line items based on U.S. Standard General Ledger (USSGL) crosswalks. The statements are system-generated using GTAS ATB data and manual adjustments. Please refer to Note 38 of OMB Circular No. A-136 and section 4735.30 for information on the when a Reclassified Balance Sheet would be needed as well as the details on the reconciling between the federal entity’s audited financial statements and the reclassified financial statements.
The Chief Financial Officer (CFO) or CFO’s designee of each significant entity must review the approval of manual adjustments in GTAS, journal vouchers processed at the government-wide level on the federal entities' audited data, and intra-governmental certifications. Additionally, each significant entity must designate a Point of Contact (POC) to assist with financial reporting. Fiscal Service will send a data call to the 40 significant entities, and select other entities, requesting that the CFO of each federal entity designate the certifying officials and POCs for various required year-end functions. The CFO certifications and Financial Reporting Contacts POC forms list each designee from the data call and must be signed by the federal entity’s CFO.
Federal entities must submit pre-closing GTAS ATB via the GTAS application. Federal entities must submit a GTAS ATB for each Treasury Account Symbol (TAS) level using proprietary and budgetary USSGL accounts. See the USSGL website for current fiscal year (FY) reporting.
Fiscal Service compiles the information from the GTAS submissions for all federal entities into the government-wide financial statements. The Balance Sheet is a financial statement with an agreed upon set of standardized financial statement lines between the entity and government-wide financial statements. The SNC and the SOCNP are not standardized; therefore, they are referred to as reclassified financial statements (Balance Sheet, Reclassified SNC, and Reclassified SCNP) that are included in the consolidated FR.
Federal entities’ net cost amounts reported in the FR will differ from the net cost presented in entities' financial statements primarily because of the allocations of Office of Personnel Management’s benefit program costs, intra-governmental eliminations as adjusted by “buy/sell cost” and “buy/sell revenue” as well as imputed costs which impact both gross costs and earned revenue. A reconciliation will be supplied to significant federal entities that provides a crosswalk between the gross cost and earned revenues in the consolidated FR to the gross cost and earned revenue reported by the entity on their SNC.
Significant entities with a year-end other than September 30 are subject to alternate audit procedures and Treasury reporting as outlined in subsection 4735.40 below.
Please refer to subsection 4735.30d of this chapter and OMB Circular No. A-136 for supplemental information on sustainability financial statements.
Reporting requirements in this chapter are grouped as follows:
- Section 4735 includes FR data requirements,
- Section 4750 includes intra-governmental requirements, and
- Section 4755 includes GTAS requirements.
Section 405 of the Government Management Reform Act of 1994 [31 U.S.C. 331(e)(1)] requires that the Secretary of the Treasury annually prepare and submit to the President and the Congress an audited financial statement for the preceding FY. This statement must cover all accounts and associated activities of the executive branch of the federal government. Section 114(a) of the Budget and Accounting Procedures Act of 1950 [31 U.S.C. 3513(a)] requires each executive branch agency to furnish financial and operational information as the Secretary of the Treasury may stipulate.
Treasury and OMB consolidate the legislative and judicial branches in the consolidated financial statements as well. To ensure that all material amounts across the three branches of government are accounted for, Fiscal Service uses the data submitted in GTAS plus records supported journal vouchers based on audited financial statements, as well as the authoritative data from the Central Accounting Reporting System (CARS).
Section 4720—Terms and Definitions
For terms and definitions related to this chapter, please view the TFM Glossary.
Reporting Entity Purpose
To provide the Federal Accounting Standards Advisory Board’s (FASAB) Statements of Federal Financial Accounting Standards (SFFAS) No. 47, Reporting Entity determinations received by the federal entities, reviewed by the Working Group, and approved by the SFFAS No. 47 Steering Committee. The determinations are listed in Appendix 1b (Consolidation Entities, Disclosure Entities, and Related Parties).
Reporting Entity Background
A questionnaire was designed for implementation by compiling the key deciding factors throughout FASAB Standard No. 47 with the corresponding paragraphs in SFFAS No. 47 with each question. The questionnaire asked for the component reporting entity to be identified. Upon completion of the survey, the entity was led to a reporting determination of consolidation entity, disclosure entity, related party, or not required to report. Consistent with Appendices B & C of SFFAS No. 47, the survey requires component entities to document the rationale for their determinations as to other entities for each entity considered. It also requires entities to specify whether any other entities are component thereof (i.e., consolidation or disclosure), a related party or do not meet the criteria of SFFAS No. 47. Federal entities are required to confirm Reporting Agency determinations in Appendix 1b via an annual data call response. Notify Fiscal Service if a survey is needed to document changes in rationale or for a new Reporting Agency determination.
The survey supported the following determinations*:
- Component Reporting Entity—is used broadly to refer to a reporting entity within a larger reporting entity. Examples of component reporting entities include organizations such as executive departments, independent entities, government corporations, legislative entities, and federal courts. Component reporting entities would also include sub-components (those components included in the financial statements of a larger component reporting entity) that may themselves prepare financial statements. An example would be a bureau that is within a larger department that prepares its own stand-alone financial statements.
- Consolidation Entity—is an organization that should be consolidated in the financial statements based on the assessment of whether it: “(a) is financed through taxes and other non-exchange revenues, (b) is governed by the Congress and/or the President, (c) imposes or may impose risks and rewards to the federal government, and (d) provides goods and services on a non-market basis.” It also includes organizations that, if excluded, would result in misleading or incomplete financial statements.
- Disclosure Entity—is an organization with a greater degree of autonomy within the federal government than a consolidation entity. Some organizations may exercise powers that are reserved to the federal government as sovereign. Other organizations may not themselves carry out missions of the federal government but, instead, are owned or controlled by the federal government as a result of “(a) regulatory actions (such as organizations in receivership or conservatorship) or (b) other federal government intervention actions.” Under such regulatory or other intervention actions, the relationship with the federal government is not expected to be permanent and such entities generally would be classified as disclosure entities, when considering the characteristics taken as a whole.
- Related Party—Organizations are considered to be related parties in the financial statements if one party has the ability to exercise significant influence over the other party’s policy decisions. Only relationships of such significance that it would be misleading to exclude information about such relationships warrant disclosure.
*See SFFAS No. 47, Reporting Entity for more detail.
The top-down approach was used to identify potential entities that meet the criteria of SFFAS No. 47 from a government-wide perspective. To ensure completeness, the component should perform a bottom-up assessment to identify entities that may not have been identified through the top-down approach. Each component entity should perform an entity review annually to validate proper reporting at the entity level. For assistance in an entity level review, please contact Fiscal Service at GTAS.Team@fiscal.treasury.gov to receive the SFFAS No. 47 Entity Analysis Excel workbook. Notify Fiscal Service immediately if an entity analysis results in a determination(s) that differs from those outlined in Appendix 1b and include the basis for determination.
Component entities must notify Fiscal Service of any discrepancies between the auditor and the component entity as to the component entity’s reporting entity status determination. In addition, questions concerning which component entity a federal entity needs to be consolidated into must be discussed with Fiscal Service. Final reporting entity determinations must be agreed upon by Treasury and OMB.
Reporting Entity Procedure/Requirements
Federal entities must report information based on the SFFAS No. 47 determination. The determinations are available in Appendix 1b and will be used to report Appendix A: Reporting Entity of the Financial Report of the United States Government.
An entity with the determination of consolidation will submit an ATB in GTAS. This data will flow to the face of the government-wide statements presented in the FR.
SFFAS No. 34 recognizes that some federal reporting entities prepare and publish financial reports pursuant to the accounting and reporting standards issued by the Financial Accounting Standards Board (FASB). SFFAS No. 34 provides that certain entities' financial statements prepared in conformity with accounting standards issued by the FASB may be regarded as in conformity with generally accepted accounting principles (GAAP). Consolidation entities (that is, the consolidated government-wide reporting entity or a consolidated component reporting entity) may consolidate component or sub-component reporting entity financial statements prepared in accordance with SFFAS No. 34 without conversion for any differences in accounting policies among the organizations.
While reporting entities that prepare and publish financial reports pursuant to FASB standards are not required to convert reported amounts to account for any differences in accounting policies between FASB and FASAB, additional data/information may still be required to be reported to supplement government-wide disclosure and other reporting requirements. SFFAS No. 47, Footnote 27 allows that Treasury and OMB will determine if there is a need for coordinated guidance to ensure government-wide consistency.
FASAB explains in the SFFAS No. 47 the basis for its conclusions that certain requirements for information (such as intra-governmental balances to facilitate eliminations at the government-wide level) are not required through accounting standards, but instead could be required by guidance from OMB and/or Treasury (SFFAS No. 47, Par. A84).
Entities with a determination of disclosure or related party (see Appendix 1b) will continue to report Treasury Account Symbols (TAS), if applicable, but when utilizing the disclosure or related party, TAS transactions must be processed as non-federal (N). This information is reported by the consolidation entities and not a direct report by the disclosure or related party. Therefore, if the entity has a relationship with a disclosure entity included in the government-wide financial statements or related party, make sure to report the federal or non-federal designation as non-federal.
Note: Several entities have expressed an interest in preparing subcomponent financial statements. These entities may be found in Appendix 1c.
Section 4730—FR Reporting and Submission Dates
See the FY 2023 TFM Year-end Closing Bulletin for all the FR reporting and submission dates regarding, but not limited to, GTAS, intra-governmental transactions/balances, legal representation letters, Management Representation Letters (MRLs), annual restatements, adjustments, reclassification survey, and subsequent events.
Federal entity participation in the third quarter and/or year-end FR reporting submission and collaboration initiatives will be measured on the entity’s year-end Financial Report (FR) and Intra-governmental Transactions (IGT) Scorecards for the current FY. Entity performance measures include 1) timeliness; 2) timely/complete; 3) reconciliation of differences; 4) consistency and integrity; and 5) Significant Disclosures on key notes.
Federal entities should submit to Fiscal Service their POC information for internal representatives who are considered technical experts for financial reporting, restatements, budget deficit reconciliation, legal letters, MRL, Summary of Uncorrected Misstatements (SUM), and significant disclosures for key subject matter areas (key subject matter areas are listed in the FY 2023 TFM Year-end Closing Bulletin). These individuals will be the point of contact for close collaboration throughout interim analysis and year-end preparation of the FR according to section 4710 above. Contact information must include name, phone number, email address, and area(s) of expertise and be submitted to Fiscal Service at email@example.com.
4730.10—Third Quarter Reporting (Unaudited Financial Statements and Notes)
The purpose of these submissions is to enable Fiscal Service to conduct preliminary analysis on federal entity data to facilitate preparation of the FR.
Interim Financial Statements, Notes, Variance Analysis, and Budget Deficit Template
Significant entities must submit unaudited interim financial statements, notes, and a completed Budget Deficit template, as of June 30, in accordance with OMB Circular No. A-136. Comparative interim financial statements are limited to the Balance Sheet, SNC, and SCNP. Significant entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section III.2 and a completed Budget Deficit template (see the FY 2023 TFM Year-end Closing Bulletin for all due dates). All applicable documents are to be transmitted through MAX.gov.
Restatements, Adjustments, and Reclassifications Survey
To support the additional collaboration needed to report corrections of errors and changes in accounting principle, according to SFFAS No. 21, significant entities will download an annual Restatement, Adjustment, and Reclassification Survey via the GTAS website. This survey is to assess whether entities anticipate having any corrections of errors, changes in accounting principles, or changes in presentation for the current FY. Surveys are to be transmitted through MAX.gov for submission to Fiscal Service (see the FY 2023 TFM Year-end Closing Bulletin). The entity response will be measured on its year-end Financial Report (FR) and Intra-governmental Transaction (IGT) Scorecard for the current FY.
Significant Disclosures of Key Subject Matters
Fiscal Service will also require significant entities’ assistance with completing the analysis of ‘key” subject matters that present a greater risk of failing to meet the prescribed disclosure requirements and that are relatively new to the FR. “Key subject matters” are notes, Required Supplementary Information (RSI), or Other Information (OI) identified as being affected by new or updated FASAB/FASB standards and notes, RSI, and OI that include topics that are prevalent in the current socioeconomic climate. Fiscal Service will work with the significant entities in developing the list of “key” subject matters after the FR is published and before the TFM Year-end Closing Bulletin for the next reporting year is published.
For “key” subject matters, Fiscal Service will provide the Significant Disclosures questionnaire on the GTAS website (Resources section). Federal entity technical experts are required to provide feedback on the Significant Disclosures questionnaire on items of significance that occurred during the FY that should be considered by Fiscal Service for disclosure in the FR during its analysis and compilation process. Questionnaires are to be transmitted through MAX.gov for submission to Fiscal Service. Fiscal Service will also include a copy of the prior year note, RSI, and OI section from the FR and any applicable auditor comments with the questionnaire.
See the FY 2023 TFM Year-end Closing Bulletin for the dates the questionnaire will be available on the GTAS website and dates the completed questionnaires are to be returned to Fiscal Service via MAX.gov. Federal entity participation in the third quarter collaboration initiative will be measured on the entity’s year-end Financial Report (FR) and Intra-governmental Transactions (IGT) Scorecards for the current FY.
Key Subject Matters for FY 2023:
- Note 1,
- Cryptocurrency (Inventory),
- Federal Employee and Veteran Benefits Payable, and
4730.20—Year-End Reporting (Audited Financial Statements and Notes)
Year-End Financial Statements, Notes, Variance Analysis, and Budget Deficit Reconciliation template
All federal entities (significant and other) must submit audited financial statements and notes in accordance with OMB Circular No. A-136. Significant entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section III.2, and a completed Budget Deficit Reconciliation template in accordance with Section 4735.10 of this chapter (see the FY 2023 TFM Year-end Closing Bulletin for all due dates). All applicable documents are to be transmitted through MAX.gov.
Significant Disclosures of Key Subject Matters
Federal entities should be aware the significant disclosure Key Subject matters collaboration process is also a requirement at year-end. Fiscal Service will provide the year-end Significant Disclosures questionnaire on the GTAS website. Federal entity technical experts must provide feedback on the Significant Disclosures questionnaire for items of significance that should be considered by Fiscal Service for disclosure in the FR during the analysis and compilation process, along with the location of the disclosure in the entities’ financial statements Questionnaires, are to be transmitted through MAX.gov for submission to Fiscal Service. See the FY 2023 TFM Year-end Closing Bulletin for the dates the questionnaire will be available on the GTAS website as well as the dates the completed questionnaires are to be returned to Fiscal Service via Max.gov. Participation in this collaboration process will also be measured on federal entities’ year-end Financial Report (FR) and Intra-governmental Transactions (IGT) Scorecards.
Section 4735—FR Data Requirements
Significant entities must:
- Submit audited financial statements in an Agency Financial Report (AFR)/Performance and Accountability Report (PAR) in MAX.gov. Please refer to OMB Circular No. A-136 for details.
- Submit a GTAS ATB. GTAS will crosswalk the ATB data to populate a Reclassified Balance Sheet, Reclassified SNC, and Reclassified SCNP by reporting entity using the USSGL Reclassified Crosswalk. These reclassified financial statements need to be federal entities audited financial statements and any differences disclosed in Note 38: Reclassification of Financial Statement Line Items in OMB Circular No. A-136. Reference the Reclassified Crosswalks on the USSGL website for additional guidance.
- Submit an interim and year-end variance analyses in MAX.gov as required in OMB Circular No. A-136 Section III.2.
- Submit the interim unaudited financial statements (the third-quarter financial statements), notes, RSI, OI, Budget Deficit Reconciliation template, and the Restatement, Adjustment and Reclassification Survey in MAX.gov (see subsection 4730.10).
- Comply with the intra-governmental requirements that can be found in Section 4750.
- Review (with their auditors) the year-end Financial Report (FR) and Intra-governmental Transactions (IGT) Scorecards to determine if a prior-year journal voucher was processed. If so, then the significant entity should identify the reason for the journal voucher as well as how to prevent the adjustment in the current year.
- Comply with the collaboration process found in Section 4730 for Key Subject Matters and Restatements.
Contact Fiscal Service to determine the reporting procedures for any adjustments to the GTAS data and AFR/PAR after their publication, which is normally November 15. For contact information, see the GTAS Contacts page.
4735.10—Budget Deficit Reconciliation
Budget Deficit reporting in the FR is based on the published Monthly Treasury Statement (MTS) as of June 30 for third quarter and September 30 for fourth quarter, which is compiled from federal entities’ monthly reports to Treasury’s Central Accounting Reporting System (CARS). Those monthly reports to CARS may include, for example, the Classification Transactions and Accountability (CTA) report, the Statements of Transactions–SF 224, and the Statement of Accountability/Transactions–SF 1219/1220. The MTS, which conforms to the Budget of the U.S. Government, summarizes the financial activities of the federal government and off-budget federal entities.
The Budget Deficit Reconciliation validates the budget deficit reported in the FR (on the Statement of Changes in Cash Balance from Budget and Other Activities, and the Reconciliation of Net Operating Cost and Budget Deficit) against entity audited financial statements.
Using the Budget Deficit Reconciliation Template provided by Fiscal Service, entities must identify and explain any inconsistencies at both third quarter and at year-end. The Budget Deficit Reconciliation Template is divided into three sections. These sections leverage reconciliations that entities already perform, focusing on collecting budget receipts data for significant entities, and identifying undistributed offsetting receipts data for key contributing entities. Previously, a reconciliation of entity outlays was requested. Fiscal Service is now reconciling internally the MTS Outlays to entities’ GTAS SF-133 information. Fiscal Service may contact entities for assistance if questions should arise during this reconciliation. All entities should review the “Operating Rev to Budget Receipt” tab for data to reconcile. The “Earned Rev to Undist Offset” tab is only to be completed by the following entities: U.S. Court of Appeals for Veterans Claims, Department of Defense, Department of Health and Human Services, Office of Personnel Management, Social Security Administration, and Department of State. The “Operating Rev to Undist Offset” tab is to be completed only by: Department of Commerce, Department of the Interior, Executive Office of the President, and Federal Communications Commission.
Entities can refer to the GTAS website for instructions on how to complete the Budget Deficit Reconciliation Template. Entities must submit this reconciliation 45 business days after third quarter and again at fiscal year-end. All applicable documents are to be transmitted through MAX.gov.
4735.20—Federal Trading Partner Notes
Federal trading partners and amounts for each federal line item reported based on the reclassified financial statements will be derived from GTAS ATB data. Amounts identified as federal should be net of intra-departmental eliminations with the following exceptions:
- For U.S. Office of Personnel Management only, intra-departmental imputed costs reported with a trading partner code of unknown, and
- Regular expenditure transfers from Trust Fund accounts and Fiduciary Fund accounts to other general appropriated funds.
Identifying the trading partner enables analysis and elimination of federal activity/balances based on reciprocal categories at the government-wide level. See Appendices 1a and 1b for a complete list of Agency Identifiers (AIDs) and financial reporting entities (FR entities).
All General Fund of the U.S. Government (General Fund) activity will be reported to the appropriate reclassified financial statement line within RC 30–RC 48 activities. The General Fund activity based on the USSGL and federal/non-federal attributes will be reported to the appropriate reclassified financial statement line within RC 30–RC 48 (see Appendices 2 and 3 for the appropriate reclassification of reclassified financial statement lines) using a federal/non-federal attribute domain value of “G.” See Appendix 11 for more details on transactions with the General Fund.
4735.30—Reclassification of Significant Entities’ Financial Statements
Significant entities must submit GTAS ATB data. GTAS will then populate three reclassified financial statements based on the USSGL crosswalks. The USSGL crosswalks for the Reclassified Balance Sheet, Reclassified SNC, and the Reclassified SOCNP can be found in USSGL guidance (current fiscal year–Section VI-Crosswalks to Reclassified Statements). Entities can access the entity GTAS reports titled “Reclassified Balance Sheet, Reclassified SNC, and Reclassified SOCNP” which significant entities must use to complete Note 38: Reclassification of Financial Statement Line Items in OMB Circular No. A-136. For Note 38 requirements, please refer to the OMB Circular No. A-136, Section IV.2.1–Significant Reporting Entities.
Note: If you are a significant entity and a FASB reporter, please refer to Section 4735.40 for additional information related to the Note 38 requirements.
Significant entities report the line items on their financial statements based on what is most material and useful to them. These line items may not match line items in the reclassified financial statements for several reasons. For example, the reclassified financial statement line items may not apply to the federal entity, the amounts could be immaterial at the entity level, or the entity may find it useful to include more detail than the reclassified financial statement lines. Federal entities must submit ATB data to GTAS for the reclassified financial statement lines, regardless of materiality.
Significant entities that report a Statement or Note on Custodial Activity in their comparative, audited consolidated, financial statements should show an adjustment of the exchange revenue without associated costs and non-exchange revenue from the Statement or Note on the Custodial Activity to the SOCNP on Note 38: Reclassification of Financial Statement Line Items in OMB Circular No. A-136. From the Sources of Collections section of the Custodial Statement or Note (with the exception of customs duties, excise taxes, and taxes collected by the Department of the Treasury, the Department of Labor, and the Department of Homeland Security), reclassify all non-exchange revenue lines to “Other taxes and receipts” and exchange lines to “Miscellaneous earned revenue.” From the Disposition of Collections section, reclassify all federal lines to “Other Budgetary Financing Sources” and non-federal lines to “Other taxes and receipts.”
Federal entities must report the custodial revenue as non-federal “N” at the time of collection from the public (that is, the Sources of Collection section). The disposition of the custodial revenue to other federal entities must be reported as federal “F” in the Reclassified SNC or SOCNP when reporting in GTAS. Any federal entity receiving custodial revenue from the collecting entity must report this revenue as federal “F” in its Reclassified SNC or SOCNP when reporting in GTAS. If the collecting entity retains a portion of the custodial revenue, the entity must report this revenue as non-federal, “N” at the time of collection from the public. If the revenue is transferred between intra-departmental funds, those transactions should be reported as federal “F” in its Reclassified SNC or SOCNP when reporting in GTAS and must use its own trading partner AID. The federal entity must ensure the amounts reported with its own trading partner AID eliminate appropriately.
There may be situations in which custodial revenue collected in a Treasury Account Symbol (TAS) of one federal entity and, subsequently, transferred to another TAS (other than General Fund), is identified as inappropriate by Treasury and OMB. Additionally, there may be situations in which there is not currently a TAS for the federal custodial entity to record the custodial collection and subsequent distribution. For both situations, Fiscal Service has worked with OMB to assign a series (F3600-F3699) of clearing accounts to coordinate the reporting of custodial activity between the two federal entities (neither of which are the General Fund). For additional information on the requirements for establishing one of these accounts, please email GovernmentwideIGT@fiscal.treasury.gov. Please see TFM Volume I, Part 2, Chapter 1500 for additional details on establishing new custodial clearing accounts.
If federal entities have collections that do not meet Statement or Note on Custodial Activity reporting requirements, they should refer to the General Fund Receipt Account Guide.
Please see Appendix 10 of this chapter, Custodial and Non-entity Transactions, for the intra-governmental custodial activity guidance.
For additional guidance on custodial activity, as well as how to classify certain related transactions, see FASAB Standard No. 7.
4735.30b—Funds From Dedicated Collections
Funds from dedicated collections are financed by specifically identified revenues, often supplemented by other financing sources, which remain available over time. These specifically identified revenues and other financing sources are required by statute to be used for designated activities, benefits, or purposes and must be accounted for separately from the government’s general revenues in accordance with SFFAS No. 27 as amended by SFFAS No. 43. SFFAS No. 43 modified the definition of these funds by clarifying that at least one source of fund, external to the federal government, must exist for a fund to qualify as a fund from dedicated collections. SFFAS No. 43 also added an explicit exclusion for any fund established to account for pensions, other retirement benefits, other post-employment, or other benefits provided for federal employees (civilian and military).
Entities with material amounts of funds from dedicated collections must use the templates outlined in OMB Circular No. A-136, which show funds from dedicated collections reported on the SCNP on the consolidated basis and the note disclosure for funds from dedicated collection on both a combined and consolidated basis. Eliminations reflect intra-entity balances and transactions between the entity’s dedicated collections funds. Significant entities required to prepare financial statements in accordance with accounting standards other than those promulgated by FASAB will be contacted by Fiscal Service for dedicated collections information necessary for government-wide statements.
At the government-wide level, the U.S. government’s Balance Sheet shows separately the portion of the net position attributable to funds from dedicated collections and labels those lines accordingly. The Statement of Operations and Changes in Net Position shows funds from dedicated collections as consolidated and labels the statement accordingly, while the note disclosure for funds from dedicated collections discloses combined totals, intra-governmental eliminations within funds from dedicated collections, and consolidated totals. Please refer to OMB Circular No. A-136 for more details.
In addition, the reclassification crosswalk will be needed to identify the difference of revenue presented on an entity’s SCNP to the government-wide SOCNP. Please refer to the Reclassification of Financial Statement Line Items for Financial Report Compilation Process area of the OMB Circular No. A-136 for more details.
Significant entities must ensure that funds from dedicated collections are denoted on the Super Master Account File (SMAF) in GTAS as an “E” for the Reporting Type Code. To request an “E” Reporting Type Code for a specific TAS, send an email to GTAS.firstname.lastname@example.org. This will crosswalk the funds from dedicated collections amounts and activity to the applicable reclassified financial statement line items. For additional guidance, see OMB Circular No. A-136.
Criminal debt primarily consists of fines and restitution that result from a wide range of criminal activities, including domestic and international terrorism, drug trafficking, firearms activities, and white-collar fraud. When an individual is sentenced in a federal criminal case, the judge may order the defendant to pay certain financial obligations, which may include a case assessment, fine, restitution, penalty, bail bond forfeiture, or interest. The Department of Justice’s Executive Office for U.S. Attorneys is responsible for establishing policies and procedures for the collection of criminal monetary penalties. The U.S. Attorneys are responsible for the enforcement of judgments, fines, penalties, and forfeitures imposed in their respective districts. There are 93 U.S. Attorneys stationed throughout the 50 states, Puerto Rico, the Virgin Islands, Guam, and the Northern Mariana Islands. The U.S. Attorneys publish the Annual Statistical Report that contains statistical tables displaying both national and district caseload data, covering the many priorities of the U.S. Attorneys in both criminal prosecution and civil litigation. The data supporting the Annual Statistical Report is obtained from the Department of Justice (Justice) Consolidated Debt Collection System (CDCS). The CDCS is the system of record for debts being collected by Justice on behalf of others, including federal entities. The system is used by the U.S. Attorneys' Offices, Justice’s other litigating divisions, and contracted Private Counsel Offices to monitor and track delinquent civil and criminal debts owed to the federal government. The funds collected in federal restitution are disbursed back to the appropriate federal entities, while funds collected in bond forfeitures, fines and assessments are deposited into the Crime Victims Fund. Funds collected from penalties and certain costs are deposited in the General Fund of the U.S. Government. The U.S. Courts assist Justice with the receipt and distribution of financial obligations ordered in a criminal judgment and serve as a conduit between the defendant and Justice. The majority of payments made to satisfy criminal restitution are received at the Clerk of Court offices. The Clerk of Court offices have the payee details from the criminal judgment to ensure proper disbursement of payments.
Non-exchange revenues include income taxes, excise taxes, employment taxes, duties, fines, penalties, and other inflows of resources arising from the government’s power to demand payments from the public. Non-exchange revenue should be recognized when a specifically identifiable, legally enforceable claim to resources arises, to the extent that collection is probable (more likely than not) and the amount is reasonably estimable (SFFAS No. 7, par. 48). For accounts receivable resulting from non-exchange transactions, recognition is based on the completion of the assessment process that establishes an identifiable, legally enforceable claim to cash or other assets (SFFAS No. 7, par. 53). Assessments recognized as accounts receivable include court actions determining an assessment (SFFAS No. 7, par. 54). Federal accounting standards require that an allowance for uncollectible amounts be established to reduce the gross amount of receivables to its net realizable value (SFFAS No. 1, par. 45).
Public Access to Court Electronic Records (PACER) is an electronic public access service that allows registered users to obtain case and docket information online from federal appellate, district, and bankruptcy courts. The Judgment in a Criminal Case form issued by a court is a public record filed with the Clerk of Courts. The criminal judgment form and related case documents can be obtained via PACER. The Judgment in a Criminal Case form includes a schedule for Criminal Monetary Penalties, which details if any assessments, fines, or restitution have been established in the final judgment in a criminal case and lists the payees and amount of restitution ordered for each payee. This schedule also indicates if the fine or restitution are subject to interest. The Judgment in a Criminal Case form also includes the Schedule of Payments, which lists the specific details as to when payments are to commence and the frequency of when payments are due. When a federal entity is listed as a payee in the Judgment in a Criminal Case form, the legally enforceable claim to cash or other assets is established.
Significant entities and other entities that are owed restitution as the result of a judgment in a criminal case are required, if material, to report in Note 6: Accounts Receivable, Net in OMB Circular No. A-136.
The Statements of Social Insurance (SOSI) and the Statement of Changes in Social Insurance Amounts (SCSIA) are required by SFFAS Nos. 17, 25, 26, 28, and 37 to be presented as basic financial statements. The Social Insurance reporting agencies (SIRAs) are the Social Security Administration (SSA), the Department of Health and Human Services (HHS), the Railroad Retirement Board (RRB), and the Department of Labor (DOL).
Most of the social insurance information pertaining to Social Security and Medicare can be obtained from SSA (the 2022 Annual Report of the Board of Trustees of the Federal Old-Age and Survivors Insurance and Federal Disability Insurance Trust Funds) and from HHS (the 2022 Annual Report of the Boards of the Trustees of the Federal Hospital Insurance and the Federal Supplementary Medical Insurance Trust Funds, and the CMS (Centers for Medicare and Medicaid Services) Actuary Workbook). The remaining data for social insurance from SSA and HHS will come from their AFR/PAR. It is noted the social insurance information from RRB and DOL will come directly from their AFR/PAR. RRB, however, will provide to Fiscal Service a spreadsheet with the amounts of its current year SCSIA for data entry purposes. For additional guidance, see OMB Circular No. A-136.
In a fiduciary activity, the government collects or receives and subsequently manages, protects, accounts for, invests, and disposes of cash or other assets in which non-federal individuals or federal entities have an ownership interest that the government must uphold. Non-federal individuals and federal entities must have an ownership interest in the cash or other assets held by the government under provision of loan, regulation, or other fiduciary arrangement. The ownership interest must be enforceable against the government, and judicial remedies must be available for the breach of the government’s fiduciary obligation. Federal entities should account for this fiduciary activity, which includes the collection of cash or other assets and their distribution to the non-federal owners or their beneficiaries, in accordance with SFFAS No. 31. In accordance with the standard, there is relatively similar government activity that is specifically excluded from the SFFAS No. 31 reporting requirements, such as payroll withholdings and garnishments; unearned revenue; and seized property.
The standard requires that the government’s fiduciary activities and a description thereof be included as a note disclosure. In addition, the government must disclose that the fiduciary assets are not assets of the government and are, therefore, not recognized on the U.S. Government Balance Sheet. However, at the government-wide level, the U.S. Government Balance Sheet recognizes a liability for fiduciary Fund Balance with Treasury and a liability for fiduciary investments in U.S. Treasury securities that are included in the federal entities’ fiduciary assets. Federal entities must make sure to report the TASs that are fiduciary to Fiscal Service to ensure the data crosswalks properly to the AFRs/PARs.
However, both significant entities and other entities with fiduciary activity must enter the federal entity fiduciary activity note disclosure information in Note 38: Fiduciary Activities in OMB Circular No. A-136.
Significant entities must ensure that fiduciary activities are denoted on the SMAF in GTAS as a “F” for Reporting Type Code. To request a “F” Reporting Type Code for a specific TAS, send an email to GTAS.Team@fiscal.treasury.gov and a description of how the TAS will be used.
Note: The reporting requirements related to fiduciary activities, as required by SFFAS No. 31, are distinct and unrelated to the reporting and other requirements related to the “fiduciary” category of intra-governmental transactions as stated in Appendix 6 of this chapter.
4735.30f—Reporting of Government Account Series (GAS) Investments with Fiscal Service Purchased by Federal Entities Using Fiduciary or Non-fiduciary Funds
Treasury GAS securities purchased using a non-fiduciary fund are normally classified as intra-governmental. The investments in GAS securities by non-fiduciary funds and the associated USSGL accounts should be reported with a federal/non-federal attribute domain value of “F” with a corresponding federal trading partner of 020 for Treasury.
The purchase of Treasury GAS securities using a fiduciary fund is not classified as intra-governmental. The investments in GAS securities by a fiduciary fund and the associated USSGL accounts should be reported with a federal/non-federal attribute domain value of "F” with a corresponding federal trading partner of 020 for Treasury for budgetary reporting only. The balance will be excluded from the Balance Sheet when consolidating the FR when reported by an account with Reporting Type Code attribute domain value “F” (fiduciary).
Note: Treasury will still report the liability as federal debt and interest payable with federal/non-federal attribute domain value “N” to allow for appropriate Balance Sheet presentation on the FR.
4735.30g—Department Code Reporting for General Fund Activities
Federal entities that record activities with the General Fund must properly record the activity at the government-wide level to assist with the preparation of the FR. Refer to USSGL guidance (Section VI-Crosswalks to Reclassified Statements) for a description of each reclassified FR line, and Appendices 2 and 3 for a listing of reclassified FR line reciprocal category designations and the financial statement to which they relate. Please refer to Appendix 11 for full General Fund reporting guidance.
Federal entities should contact Fiscal Service, via email at GovernmentwideIGT@fiscal.treasury.gov, if they are unsure about what the correct trading partner assignment is for a particular transaction.
Z (intra-governmental)—This is an attribute domain value of a USSGL account balance that results from transactions that are intra-governmental in nature, but no reciprocal balances will be reported by any other federal entity. The attribute is limited to Reciprocal Category 29.
An example of a non-reciprocating activity is as follows:
- Liabilities temporarily recorded to clearing accounts related to intra-governmental activity.
Section 4735.30i — Federal Lease Accounting
Statements of Federal Financial Accounting Standards
SFFAS No. 54, Leases, as amended by SFFAS No. 58 and SFFAS No. 60, replaces proprietary lease accounting and disclosure standards for general purpose federal financial reports. SFFAS No. 54 is effective for reporting periods beginning after September 30, 2023. Early implementation is not permitted. Federal reporting entities should review SFFAS No. 54, as amended, and Federal Financial Accounting Technical Release (TR) No. 20. Questions and answers in TR No. 20 provide implementation guidance for applying the requirements of SFFAS No. 54.
Federal Lease Accounting Background
SFFAS No. 54 requires that federal lessees recognize a lease liability and a right-to-use lease asset (also referred to as a lease asset), and that federal lessors recognize a lease receivable and unearned revenues at the commencement of the lease term, unless the lease meets the definitional criteria of a short-term lease, contract or agreement that transfers ownership, or an intra-governmental lease. SFFAS No. 54 does not require Balance Sheet recognition of lease liabilities and right-to-use lease assets (or, for lessors, lease receivables and unearned revenues) when accounting for intra-governmental or short-term leases, but normal requirements for prepayments and receivables/payables continue to apply when accounting for intra-governmental and/or short-term lease activities based on the guidance provided in the Statement.
Per SFFAS No. 54, a lease is a contract or agreement whereby one entity (lessor) conveys the right to control the use of an underlying asset to another entity (lessee) for a period of time specified in a contract or agreement in exchange for consideration.
An intra-governmental lease is a contract or agreement occurring within a federal consolidation entity, or between two or more federal consolidation entities, as defined in SFFAS No. 47, Reporting Entity, whereby one entity (lessor) conveys the right to control the use of an underlying asset to another entity (lessee) for a period of time specified in a contract or agreement in exchange for consideration.
A short-term lease is a non-intragovernmental lease with a term of 24 months or less.
Leases per Procurement/Acquisitions versus Leases per Accounting
The definition of what constitutes a lease may vary depending on the perspectives and bodies of authority a federal organization is applying when managing contracts, agreements, or similar arrangements. Leases have different definitions that may apply to the fields of procurements/acquisitions and legal authorities (which can be unique to a particular federal entity) as well as budgeting.
For some procurements/acquisitions the legal definition of contract/agreement might be “a conveyance to the government of the right of exclusive possession of real property for a definite period of time by a landlord. It may include operation services provided by the landlord” (General Services Acquisition Manual, 570.102).
The proprietary accounting definition as defined by the Federal Accounting Standards Advisory Board (FASAB) is conveyance of the right to obtain and control access to economic benefits or services from use of the underlying asset as specified in the contract or agreement in exchange for consideration. The fact that a federal reporting entity may not have leasing authority from a legal perspective does not preclude a contract/agreement from being considered a lease (or containing a lease in a bundled or consolidated procurement) for proprietary accounting recognition purposes.
It is important for agencies to complete a comprehensive review of all significant contracts and agreements to identify characteristics of a lease for proprietary accounting recognition, financial reporting, and disclosure requirements. Current contracts (under today’s SFFAS Nos. 5 and 6’s terminology of leases) that may not be considered a capital lease or operating lease could be considered a right-to-use lease under new SFFAS No. 54 guidance. SFFAS No. 54 Par. 2 defines that right-to-use leases include contracts or agreements that, although not explicitly identified as leases, meet the definition of a lease. In addition, some operating leases not currently recognized on the Balance Sheet will be required to be recognized as right-to-use lease assets under SFFAS No. 54.
Primary characteristics of leases under SFFAS No.54 include:
- Having BOTH (1) the right to obtain economic benefits or services from use of the underlying asset as specified in the contract or agreement; and (2) the right to control access to the economic benefits or services of the underlying asset as specified in the contract or agreement (SFFAS No.54, Par. 3.).
- Control must be granted for a stated period of time, as specified in the contract or agreement (TR No. 20, Par. 5). Arrangements where control is granted for an indefinite period of time do not meet the definition of a lease.
- The rights to obtain benefits and control must be made in exchange for consideration (TR No. 20, Pars. 5, 14, & 15).
- When contracts or agreements contain both a lease (such as the right-to-use a building) and a non-lease component (such as a maintenance service for the building), the agency should still account for the underlying lease and non-lease asset as separate contracts or agreements, if applicable. However, any non-lease components should be accounted for as separate expenses and not recorded as part of the lease (See SFFAS No. 54, Par. 73 and 76).
For proprietary accounting purposes, the following are lease exclusions from consideration as a lease but might be considered a lease for procurement/acquisition purposes.
- Contracts or agreements explicitly for services (identifiable tasks are provided rather than a tangible asset) (SFFAS No. 54, Par. 4).
- Leases of assets prior to the start of the lease term (assets under construction) (SFFAS No. 54, Par. 5).
- Leases/Licenses of Internal Use Software (SFFAS No. 54, Par. 5).
- Contracts/agreements of underlying assets lasting indefinitely without cancellation options (Permanent easements, rights-of-way, and land rights) (TR No. 20, Par. 5).
- Contracts/agreements of underlying assets obtained without consideration (Permanent easements, rights-of-way, and land rights) (TR No. 20, Par. 5).
- Contracts/agreements of underlying assets in which the lessor (providing entity) retains certain rights that may limit the rights of a lessee (customer entity) to control economic benefits or services derived from using the underlying asset (TR No. 20, Par. 5).
- Contracts/agreements of underlying assets in which the providing entity retains the right to control access to the economic benefits or services of the underlying asset (TR No. 20, Par. 5).
- Contracts/agreements of underlying assets in which no payments or in-kind services are provided (TR No. 20, Par. 14).
- Contracts/agreements that (a) transfer ownership of the underlying asset to the lessee (customer entity) by the end of the contract or agreement and (b) do not contain options to terminate, but that may contain an availability of funds or cancellation clause that is not probable of being exercised. should be reported as a purchase of the underlying asset by the lessee (customer entity) or as a financed sale of the asset by the lessor (providing entity) (SFFAS No. 54, Par. 25).
Reporting Entity Procedure/Requirements
In preparation for implementing the reporting requirements for periods beginning after September 30, 2023, federal reporting entities must become familiar with SFFAS No. 54, as amended, as well as make necessary procedural and system changes. It is important to recognize that SFFAS No. 54, as amended by SFFAS No. 60 and TR No. 20, provides guidance for proprietary accounting related to the reporting of leases in general purpose federal financial reports, but the guidance does not extend to budgetary accounting. For budgetary accounting of leases, federal reporting entities should continue to follow guidance in OMB Circular No. A-11.
USSGL guidance will be developed with new USSGL accounts and updated crosswalks. These are located at: USSGL (treasury.gov). When issued, new and revised accounting scenarios can be found at: The U.S. Standard General Ledger - USSGL Implementation Guidance (treasury.gov).
Federal reporting entities will be requested to provide Treasury with evidence showing reasonable assurance of completeness of their leases under SFFAS No. 54, as amended for the government-wide financial statements.
4735.40—Special Basis of Accounting
SFFAS No. 34, The Hierarchy of Generally Accepted Accounting Principles, establishes what constitutes GAAP for federal reporting entities. SFFAS No. 34 recognizes that some federal component reporting entities prepare and publish financial statements (pursuant to the accounting and reporting standards issued by the FASB) and provides that such financial statements prepared in conformity with accounting standards issued by the FASB also may be regarded as in conformity with GAAP. Per SFFAS No. 47, Reporting Entity, consolidation entities (that is, the consolidated government-wide reporting entity or a consolidated component reporting entity) may consolidate component or sub-component reporting entity financial statements prepared in accordance with FASB GAAP without conversion for any differences in accounting policies among the organizations. As a result, entities reporting in conformity with FASB GAAP, consistent with SFFAS 34, may also report their data to GTAS in conformity with FASB GAAP.
Significant entities that are FASB reporters are required to provide Fiscal Service certain audited information that is necessary for the audit of the government-wide financial statements using MAX.gov (see Appendix B). This includes information for Note 5 (Investments), Note 20 (Dedicated Collections), Note 42 (COVID), and Note 38 (Reclassified Statements). The information to be provided and the manner of obtaining audit coverage must be determined in consultation with Fiscal Service.
Significant entities that are FASB reporters need to also report the information in OMB Circular No. A-136, Section II.3.8.45-Note 38: Reclassification of Financial Statement Line Items. Such information may be reported by the significant reporting entity in (i) its annual financial report within a note to the financial statements, (ii) a limited use audited financial statements that includes the Note 38, or (iii) an audited Note 38 (an audit of a special element). FASB reporters that are utilizing the Standardized Balance Sheet illustrated in OMB Circular No. A-136 are not required to produce Note 38 for the Balance Sheet. Significant entities that are FASB reporters with a calendar year-end should provide reclassification information to Fiscal Service with the audit assurance limited to the line items or note disclosures identified by Fiscal Service, as discussed below. The FASB reporting entities will also provide Treasury the associated crosswalk used to prepare Note 38. Please see the OMB Circular No. A-136 for complete details.
(1) Significant entities that are currently FASB reporters are:
- Federal Deposit Insurance Corporation,
- National Credit Union Administration,
- National Railroad Retirement Investment Trust,
- Pension Benefit Guaranty Corporation,
- Smithsonian Institution,
- Tennessee Valley Authority,
- U.S. Postal Service, and
- Farm Credit System Insurance Corporation.
Significant entities with a year-end other than September 30 (i.e., calendar year-end) are subject to all requirements of this TFM chapter. Significant entities with a calendar year-end will report their September 30 account balances in their GTAS ATB submission in accordance with the GTAS Reporting Window Schedule. This set of data, as of September 30, will be used to populate the reclassified financial statement lines through the USSGL crosswalk. These entities are required to have audit assurance on line items or note disclosures that contribute to the top 99% of the total FR line-item data. These entities will receive a second quarter report from Treasury, outlining which lines and/or notes are required to have audit assurance as of September 30 each year. Provide Fiscal Service a copy of the independent audit report that includes the results of the audit performed on the material line items and notes disclosures identified by Fiscal Service.
(2) Significant entities with a calendar year-end:
- Farm Credit System Insurance Corporation,
- Federal Deposit Insurance Corporation, and
- National Credit Union Administration.
The parent entity (transferor of the appropriation) must report all activity of the child in its financial statements, whether material to the child entity (recipient of the transfer) or not, unless one of the two exceptions (detailed below) applies. The parent entity is the trading partner entity for activity involving these TAS. For more detail on how to report trading partner information, please refer to Appendices 1a and 1b.
The two exceptions to the requirement for parent/child reporting (from OMB Circular No. A-136, revised) are:
- The parent is the Executive Office of the President.
- Funds transferred from the Judiciary to the Department of Justice’s (DOJ) U.S. Marshals Service for court security.
In these cases, the receiving entity (child) is responsible for reporting all budgetary and proprietary activity in its financial statements and is the trading partner entity. Please refer to Appendices 1a and 1b for details on reporting trading partner information.
GTAS requires the parent entity and the child entity to agree on which federal entity will report the TAS in the bulk file submission.
A Reciprocal Category is comprised of a set of reclassified financial statement line items that are the reciprocal of each other (for example, accounts payable/accounts receivable). These categories assist in the elimination of federal activity at the government-wide level to prepare the FR. Additionally, these reciprocal categories facilitate the reconciliation of activities between federal entities. Please see Appendix 2 for a complete list of reciprocal categories and the financial statements to which they relate.
Note: General Fund activities must report via GTAS ATB to be crosswalked to a reclassified financial statement line with a RC 30–48 designation for identifying General Fund activity at the government-wide level.
4735.70—Treaties and Other International Agreements
Treaties and other international agreements may create liabilities and contingencies requiring recognition or disclosure in the financial statements. As such, all federal entities should consider treaties and other international agreements in the analysis and preparation of the entities' annual financial statements.
Treaties and other international agreements are written agreements between the U.S. and other sovereign states, or between the U.S. and international organizations, governed by international law. The subjects of treaties span the whole spectrum of international relations: peace, trade, defense, territorial boundaries, human rights, law enforcement, environmental matters, and many others. The Department of State developed and continues to manage the Circular 175 Procedure (C-175 Procedure), which outlines the approval process for the negotiation and conclusion of international agreements to which the U.S. will become a party. State publishes a list of treaties and other international agreements of the U.S. in force as of January 1st each year in a document titled, Treaties in Force. Not all treaties and other international agreements are subject to the C-175 Procedure. Below are the exceptions:
- Trade agreements [CFR 181.4(g)], and
- Many routine agency-level implementing arrangements [22 CFR 181.4(a) and 22 CFR 181.3(c)].
As discussed in SFFAS No. 5, “A liability for federal accounting purposes is a probable future outflow or other sacrifice of resources as a result of past transactions or events.” SFFAS No. 5 also states that “The probability of a future outflow or other sacrifice of resources is assessed on the basis of current facts and circumstances. These current facts and circumstances include the law that provides general authority for federal entity operations and specific budget authority to fund programs. If budget authority has not yet been provided, a future outflow or other sacrifice of resources might still meet the probability test if (1) it directly relates to ongoing entity operations and (2) it is the type for which budget authority is routinely provided. Therefore, the definition applies both to liabilities covered by budgetary resources and to liabilities not covered by budgetary resources.”
Per State’s C-175 Procedure, federal entities negotiating and concluding treaties and other international agreements on behalf of the U.S. government are required to indicate whether a proposed treaty or other international agreement embodies a commitment to furnish funds, goods, services, or other measurable future financial obligations beyond or in addition to those authorized in an approved budget; and if so, what arrangements are being planned or carried out by the federal entity concerning consultation with OMB for such commitment. State will not authorize such commitments without confirmation that the relevant budget approved by the President requests or provides funds adequate to fulfill the proposed commitment, or that the President has decided to seek the required funds. All provisions of the C-175 Procedure apply whether a proposed treaty or other international agreement is to be concluded in the name of the U.S. government, or in the name of a particular federal entity of the U.S. government.
For financial reporting purposes, all treaties and other international agreements may be understood as falling into three broad categories:
- No present or contingent obligation to provide goods, services, or financial support (no recognition or disclosure),
- Present obligation to provide goods, services, or financial support (recognition), or
- Contingent obligation to provide goods, services, or financial support (may require recognition or disclosure).
No Present or Contingent Obligation to Provide Goods, Services, or Financial Support (no recognition or disclosure)
Treaties and other international agreements under the first category do not result in a liability or contingency when entered into force. Instead, these treaties or other international agreements may establish frameworks that govern cooperative activities, such as aviation safety with other countries, but leave to the discretion of the parties whether to engage in any such activities. In other cases, the agreements may contemplate specific cooperative activities, but create no present or contingent obligations to engage in them. Cooperative activities relevant to these treaties and other international agreements often involve actions that federal entities undertake as part of their regular operations, funded by their regular budgets.
Present Obligation to Provide Goods, Services, or Financial Support (recognition)
Treaties and other international agreements falling in the second category involve a present obligation, and therefore result in liability recognition. Such present obligation may relate to the U.S. Government providing financial and in-kind support, including assessed contributions, voluntary contributions, grants, and other assistance to international organizations in which it participates as a member. Examples of such agreements include:
- Agreements establishing international organizations, under which the U.S. Government undertakes obligations to pay assessed dues to the organization,
- Grant agreements under which the U.S. Government provides foreign assistance funds to other countries, and
- Claims settlement agreements under which the U.S. Government agrees to pay specific sums of money to settle claims.
Such agreements may not be entered without specific statutory authority to undertake the obligation to spend money. Liabilities arising from such agreements should be recognized for any unpaid amounts due as of the reporting date. The liabilities include amounts due from the federal entity to pay for benefits, goods, or services provided under terms of the agreements, as of the entity’s reporting date, whether such amounts have been reported to the entity. These liabilities may either be fully funded or established against future funding.
Contingent Obligation to Provide Goods, Services, or Financial Support (may require recognition or disclosure)
The last category encompasses treaties or other international agreements which result in contingencies that may require recognition or disclosure in the financial statements. Such contingencies may stem from commitments in a treaty or other international agreement to provide goods, services, or financial support when a future event occurs, or from litigation, claims, or assessments forged by other parties to the agreement. In such instances, conditions, situations, or circumstances exist involving uncertainty as to possible gain or loss to an entity that will ultimately be resolved when one or more future events occur or fail to occur. In accordance with SFFAS No. 5, a contingent liability should be recognized on the face of the basic financial statements when a past event or exchange transaction has occurred, and a future outflow or other sacrifice of resources is probable and measurable. If any of the conditions for liability recognition are not met, and there is at least a reasonable possibility that a loss or an additional loss may have been incurred, a contingent liability should be disclosed in the notes regarded as an integral part of the basic financial statements.
Disclosure should include the nature of the contingency and an estimate of the possible liability, an estimate of the range of possible liability, or a statement that such an estimate cannot be made. For circumstances where the recognition or disclosure of a contingent liability relates to litigation, claims, or assessments resulting from the U.S. Government’s involvement in a treaty or other international agreement, federal entities should summarize the financial treatment of such contingencies (recognition or disclosure) relative to the financial statements in the annual legal letter process. Any legal claim that is related to a treaty or other international agreement should be indicated as such on the legal letter form and in the appropriate column in the entity’s Management Schedule. For a summary of the proper financial treatment of contingent liabilities related to litigation, claims, and assessments, refer to subsection 4745.10—Legal Letter Reporting Requirements.
Federal entity management must determine whether the entity has treaties and other international agreements it is responsible for reporting. If the federal entity has treaties and other international agreements it is responsible for reporting, entity management must:
- Develop and implement effective internal controls to reasonably assure (1) the proper financial reporting of treaties and other international agreements, including a review of potential contingent liabilities; and (2) the establishment of related liabilities and note disclosures for both liabilities covered and not covered by budgetary resources.
- For each treaty and other international agreement, determine the appropriate category (i.e., no present or contingent obligation to provide goods, services, or financial support; present obligation to provide goods, services, or financial support; or contingent obligation to provide goods, services, or financial support).
- Review, with General Counsel (at least annually), the entity’s treaties and other international agreements relative to appropriate FASAB or FASB standards to identify, monitor, and report any related commitments and contingencies. In alignment with guidance defined in SFFAS No. 5, as amended, recognition or disclosure of a contingent liability is based on the likelihood and measurability of a future outflow or other sacrifice of resources.
4740—Management Representation Letter (MRL)
In accordance with OMB Circular No. A-136, Section IV.5., the written representations from the federal entities’ management and accompanying Summary of Uncorrected Misstatements (SUM) are required for the audits of federal entity financial statements used to compile the FR. Significant entities with a year-end other than September 30 need to provide a MRL to Fiscal Service (see the FY 2023 TFM Year-end Closing Bulletin for due dates). Significant entities that are FASAB and FASB reporters that report on the fiscal or calendar year-end are required to provide the representations shown in the current OMB Audit Bulletin, Section 8 and Appendix E. Federal entities should attach in Excel format a comprehensive SUM that includes uncorrected misstatements from the financial statement audit. Please refer to 4740.20 (Summary of Uncorrected Misstatements Process), guidance in OMB Circular No. A-136, Section IV.5, the current OMB Audit Bulletin, Section 8 (Written Representations from Management), Appendix E (Illustrative Written Representations from Management for the Financial Statements), and the current version of the Financial Audit Manual (FAM), Volume 2, Section 1001.
4740.10—Subsequent Events and MRL Representations
Subsequent events, for the purposes of this section, are events occurring after the written representations from entity management have been signed and the financial statements have been issued and before the date specified by Treasury (Financial Report of the United States Government audit report). These events may include, for example, the enactment of significant legislation or the occurrence of events affecting the realization of assets (such as receivables) or the settlement of estimated liabilities or contingencies (See SFFAS No. 39) where the events would have materially affected the amounts reported in the financial statements or would warrant additional disclosure had the report date been specified by Treasury.
The entity head, CFO, or others deemed responsible for significant entity management must email a subsequent events update to OMB, Fiscal Service, Treasury (Main), and GAO (see Contacts and the FY 2023 TFM Year-end Closing Bulletin). The notification must indicate which information reported as financial statements, notes, or RSI would be affected by the events and how the information would be affected. If the event requires a new or revised representation, the new or updated representation must be provided. If there are no significant events to report, then the notification must specify that there are “no changes.” Please see the OMB Circular No. A-136 for illustrative statements. Regardless of whether a significant entity reports a subsequent event, the subsequent events notification must state that the entity understands that the subsequent events update will be used by Treasury and OMB to prepare the FR and the FR MRL. (See OMB Circular No. A-136, Section IV.6, Written Representation from Management for wording requirements).
4740.20—Summary of Uncorrected Misstatements (SUM) Process
Significant entities must include a SUM as a part of their financial statement MRL (as stated in Section 4740). Significant entities with a year-end other than September 30 do not have to provide a SUM. The SUM is for federal entities’ current-year Balance Sheet, SNC, SCNP, Statement of Budgetary Resources, Statement of Social Insurance, and Statement of Changes in Social Insurance Amounts (if applicable). If there are no uncorrected misstatements, a representation to this effect is required in the MRL.
Federal entities are required to provide the adjusting entries to correct the misstatements. A summary of uncorrected misstatements and adjusting entries must be submitted in the standardized Excel format as shown in the current year version of the FAM, Volume 1, Section 595C. Additionally, as shown in the FAM, Volume 1, Section 595C, the SUM should include both the iron curtain and rollover methods. The adjusting entries should contain the following:
- The effect of the current-year’s uncorrected misstatements and the carry-forward effect of the prior-year’s uncorrected misstatements.
- USSGL account number and account description.
- Federal (F), General Fund (G), Non-reciprocating (Z), or Non-Federal (N) attribute for each USSGL account affected.
- A reference to an adjustment number or documentation reference.
- An indication as to whether management has agreed to record the adjustment in its financial statements.
- A statement as to whether the uncorrected misstatement is factual, judgmental, or projected.
- A description of the adjustment.
- The amount of the debit or credit.
- The line items affected in the consolidated financial statements.
- Uncorrected misstatements identified in the audit of the federal entity’s financial statements.
Please refer to the example below for reporting the adjusting entries for the summary of uncorrected misstatements to Fiscal Service.
For additional guidance, see the current OMB Audit Bulletin, Section 8 (Written Representations from Management) and Appendix E (Illustrative Written Representations from Management for the Financial Statements), and OMB Circular No. A-136, revised, on the OMB website and GAO’s current version of the FAM, Volume 1, Section 595C, on the GAO website.
4745—Legal Representation Letter Process
4745.10—Legal Letter Reporting Requirements
Significant entities' General Counsel must prepare interim and final legal representation letters that describe and evaluate pending or threatened litigation, claims, and assessments in which legal counsel has been engaged and has devoted substantial attention, in the form of legal consultation or representation, on behalf of the entity. When preparing the legal representation letter, a significant entity's General Counsel must also consider unasserted claims and assessments that management considers to be probable of assertion and that, if asserted, would have at least a reasonable possibility of an unfavorable outcome.
All pending and threatened litigation, as well as unasserted claims above the materiality level agreed upon by significant entity management and its auditor, must be reported using the applicable form found on DOJ’s website. When determining the materiality level for the legal representation letter, significant entities and their auditors should set the level sufficiently low so that the cases not included in the legal letter would not be material to the financial statements taken as a whole when aggregated with other items as described in GAO’s FAM, Volume 2, Section 1002.18. In aggregating cases, the significant entity and the auditor may use two levels of aggregation as discussed in FAM, Volume 2, Section 1002.19. First, similar cases are aggregated, treated as a group, and compared with the individual materiality level. Second, cases not included in the legal letter individually or as part of a group of similar cases are aggregated.
The legal representation letter must categorize cases, including cases to be paid from the Judgment Fund, as having a probable, reasonably possible, remote, or unable to determine chance of a negative outcome for the significant entity, consistent with the American Bar Association’s Statement of Policy Regarding Lawyer’s Responses to Auditor’s Requests for Information (December 1975). When preparing the legal representation letters, General Counsel should also reference guidance found in OMB Audit Bulletin.
For circumstances where litigation, claims, and assessments involve lead representation by outside counsel, e.g., DOJ, significant entity management, in conjunction with its General Counsel, must consult the lead counsel when assessing the likelihood of loss and estimated amount or range of potential loss for cases included in the significant entities’ legal representation letters. DOJ prepares an interim and final government-wide legal representation letter based on its review of the litigation, claims, and assessments reported by significant entities that have cases that are material to the FR. Fiscal Service performs a comparison of the “Pending or Threatened Litigation” and “Unasserted Claims and Assessments” forms included in DOJ’s government-wide legal representation letter to the corresponding forms and the “Management’s Schedule of Information Contained in Legal Letter Responses for Financial Reporting Purposes” (Management Schedule) included in the legal letter packages submitted by significant entities. If Fiscal Service identifies inconsistencies between DOJ’s and a significant entity's assessments of the likelihoods of loss or estimated amounts or ranges of potential loss for these cases, Fiscal Service will collaborate with the significant entity that reported the case to coordinate efforts between the entity and DOJ to resolve the inconsistencies.
In cases that have more than one entity impacted, entities must collaborate with each other on shared cases to ensure appropriate reporting. Responsibility for the case must be allocated among impacted entities to ensure that 100% of the contingency is accounted for.
Using the Management Schedule template found on the GTAS website, significant entity management must prepare an interim and final Management Schedule that summarizes the contingencies included in the legal representation letter prepared by General Counsel and documents how the information was used in preparing the entity’s financial statements. The following elements on the Management Schedule must agree with General Counsel’s assessments from each supporting legal representation letter form, or in unusual circumstances where they do not agree, an explanation must be provided on the “FS Gwide Mgmt Schd” worksheet in the Management Schedule template:
|Management Schedule Element||Litigation||Unasserted Claims and Assessments|
|Likelihood of loss (probable, reasonably possible, remote, unable to determine)||DOJ’s “Pending or Threatened Litigation” Form, Field 6 – An Evaluation of the Likelihood of an Unfavorable Outcome.||DOJ’s “Unasserted Claims and Assessments” Form, Field 4 – An Evaluation of the Likelihood of an Unfavorable Outcome.|
|Estimated amount or range of potential loss or indication that estimated amount or range is unknown||DOJ’s “Pending or Threatened Litigation” Form, Field 7 – An Estimate of the Amount or Range of Potential Loss.||DOJ’s “Unasserted Claims and Assessments” Form, Field 5 – An Estimate of the Amount or Range of Potential Loss.|
In addition, significant entity management must indicate the accrual or disclosure of each contingency on the Management Schedule as it relates to the preparation of the entity’s financial statements. Contingent liabilities related to pending or threatened litigation and unasserted claims must be recognized and disclosed in accordance with guidance defined in SFFAS No. 5, Accounting for Liabilities of the Federal Government, as amended, which is summarized in the below table.
|Likelihood of future outflow or other sacrifice of resources||Loss amount can be reasonably measured||Loss range can be reasonably measured||Loss amount or range cannot be reasonably measured|
|Probable: Future confirming event(s) are likely to occur.||Accrue the liability. Report on the Balance Sheet and Statement of Net Cost.||Accrue liability of best estimate or minimum amount in loss range if there is no best estimate, and disclose nature of contingency and range of estimated liability.||Disclose nature of contingency and include a statement that an estimate cannot be made.|
|*Reasonably Possible: Possibility of future confirming event(s) occurring is more than remote but less than probable.||Disclose nature of contingency and estimated amount.||Disclose nature of contingency and estimated loss range.||Disclose nature of contingency and include a statement that an estimate cannot be made.|
|Remote: Possibility of future event(s) occurring is slight.||No action is required.||No action is required.||No action is required.|
*The financial reporting treatment for cases where the likelihood of future outflow or other sacrifice of resources is assessed as “unable to determine” should be consistent with the disclosure requirements for reasonably possible cases.
When evaluating the likelihood of loss for contingent liabilities, significant entities should avoid excessive and misuse of the “unable to determine” assessment. The “unable to determine” likelihood of loss should only be used to categorize cases for which the General Counsel is unable to express an opinion due to inherent uncertainties. The financial reporting treatment for cases assessed as “unable to determine” should be consistent with the disclosure requirements for reasonably possible cases. Fiscal Service will require significant entities with a high percentage use of the “unable to determine” assessment to provide written documentation of their internal processes for using this assessment when evaluating legal cases.
When evaluating the estimated amounts or ranges of potential loss for litigation, claims, and assessments, significant entities that use the claim amount as an estimated loss should ensure that an analysis has been performed that supports the determination that the claim amount is the best estimate of loss. Significant entities are encouraged to review guidance defined in SFFAS No. 5, paragraphs 38-41, as well as the American Bar Association’s Statement of Policy Regarding Lawyer’s Responses to Auditor’s Requests for Information (December 1975).
Significant entity Inspector Generals (IGs) must submit an interim and final legal representation letter prepared and signed by General Counsel, as well as an interim and final Management Schedule prepared by management via email to Fiscal Service, DOJ, and GAO (see the FY 2023 TFM Year-end Closing Bulletin for due dates). Legal representation letters and the related Management Schedules are considered "Sensitive but Unclassified" and should not be uploaded on MAX.gov. The interim Management Schedule should represent information as of June 30 and the final legal representation letter must include all existing, pending, or threatened litigation and unasserted claims as of September 30. Only Management Schedules as of these dates should be submitted in order to remain consistent with the reporting period. To limit the number of emails required to complete the legal representation letter package submission, legal letter files must be combined into a single file PDF, (i.e., avoid including a separate PDF file for each case), and submitted via email. Management Schedules must be submitted in Excel format using the template provided by Fiscal Service. If the significant entity IG does not use the template provided by Fiscal Service, then the significant entity management must provide the additional details required to support the compilation of the consolidated financial report by preparing the template provided by Fiscal Service for each legal case in Excel format. Fiscal Service will accept this in Excel format as a separate submission, with the same due date as the previously mentioned legal representation letter package. Significant entities must provide contact information for entity representatives who are available to assist Fiscal Service with inquiries related to legal representation letter package submissions. Since significant entity's management, General Counsel, and IGs are involved in the preparation of the legal representation letter package, please provide contact information for each, or indicate that the contact(s) provided serves as sufficient representation for all areas. Federal entity participation in this collaboration process will be measured on the entity’s year-end Financial Report (FR) and Intra-governmental Transaction (IGT) Scorecard for the current FY.
The Export-Import Bank of the U.S., Smithsonian Institution, National Railroad Retirement Investment Trust, and calendar year-end federal entities (Farm Credit System Insurance Corporation, Federal Deposit Insurance Corporation, and National Credit Union Administration) are not required to submit an interim legal representation letter and Management Schedule. These significant entities' IGs, or management where applicable, are only required to submit a final legal representation letter and Management Schedule.
To ensure accurate and complete financial reporting and disclosures of contingent liabilities in the FR, Fiscal Service will review significant entities’ legal representation letter and Management Schedule submissions to confirm contingencies detailed in the legal representation letter have been appropriately summarized on the Management Schedule, and reported and disclosed in the entity’s financial statements in accordance with requirements in SFFAS No. 5, as amended. Significant entities must provide explanations for inconsistencies between the legal representation letter, Management Schedule, and the reporting of contingent liabilities in the financial statements on the “FS Gwide Mgmt Schd” worksheet in the Management Schedule template. Significant entities are required to reconcile the Management Schedule totals to the amounts reported in the entities’ financial statement on the “Recon-MS to Fin Stmts” worksheet in the Management Schedule template. An explanation for variances identified must be provided. Fiscal Service will follow up on any discrepancies identified in its analysis that have not been explained or justified by the significant entity.
4745.20—Other Required Information for Legal Representation Letters
Significant entity IGs, or significant entity management for some federal entities, must provide GAO, DOJ, and Fiscal Service information relating to subsequent events that resulted in a change in the likelihood of loss or the estimated amount or range of potential loss, or both, from the effective date of the final Legal Representation Letter through a date to be determined. All significant entity IGs, or significant entity management for some federal entities, must submit details of the subsequent events via email to GAO, DOJ, and Fiscal Service (Please see the FY 2023 TFM Year-end Closing Bulletin for all Legal Representation Letter due dates).
Subsequent event information is based on the significant entity’s materiality threshold. For additional guidance, see the current OMB Audit Bulletin, and OMB Circular No. A-136, revised, on the OMB website.
Section 4750—Intra-governmental Quarterly and Year-end Requirements
Intra-governmental transactions result from business activities conducted between two federal government entities, called trading partners. Accounting differences occur in government-wide financial reporting when trading partners record differing amounts for transactions that should eliminate or net to zero. All differences should be resolved by year-end. Trading partners must reconcile and resolve these differences on a periodic basis with their trading partners. The Intra-governmental Transaction (IGT) Guide (Appendix 5) contains the business rules and processes to properly record, report, and reconcile intra-governmental transactions, including the processes for dispute resolution. See the following appendices for guidance on specific types of intra-governmental transactions:
- Appendix 6—Investments and Borrowings
- Appendix 7—Benefits
- Appendix 8—Buy/Sell
- Appendix 9—Transfers
- Appendix 10—Custodial and Non-entity Transactions
- Appendix 11—General Fund of the U.S. Government
Note: The Federal Reserve System, which includes the Board of Governors, is not considered a consolidated entity in government-wide reporting entity under federal accounting standards (please note the Board of Governors is considered federal for tax purposes, however, for government-wide reporting, they are considered non-federal). Therefore, payments made to or collections received from the Federal Reserve System would be reported in the financial statements of the federal government and its component reporting entities. All activity with the Board of Governors of the Federal Reserve System and all of the Federal Reserve System must be reported as non-federal “N” activity.
Federal Executive Boards are not considered a consolidated entity in government-wide reporting under federal accounting standards and all activity with Federal Executive Boards must be reported as non-federal “N” activity for financial reporting purposes. Please refer to Appendix 1b for a list of Disclosure Entities, SFFAS No. 47.
4750.20—Additional Intra-governmental Reconciliation Requirements
The intra-governmental transactions reconciliation and resolution requirements are stated in OMB Circular No. A-136, revised.
4750.30—Federal Intra-governmental Transactions Accounting Scenarios
To aid in the reconciliation of intra-governmental differences, federal entities should follow the accounting scenarios found on the USSGL website. The scenarios provide posting logic for accounting transactions of select events occurring throughout the federal government and are made available as a source of guidance.
For non-fiduciary transactions, OMB requires reporting entities to reconcile and confirm intra-governmental activity as well as balances quarterly for the following reciprocal groupings:
- Services provided and reimbursables. Examples include, but are not limited to, legal, consulting, investigative, financial management, grants management, technology, reimbursables, and other similar services.
- Cost of products sold. Examples include, but are not limited to, supplies, manufactured items, inventory, office space, and equipment/vehicle rentals.
- Transfers, appropriations used, and collections for others, as well as unusual assets and liabilities related to appropriations. Examples include, but are not limited to, transfers between federal entities based on agreements or legislative authority, expended appropriations, taxes and fees collected, collections for others, receivables from appropriations, transfers payable, and custodial revenue.
The above listings of examples are not exhaustive; additional examples in each category may qualify as non-fiduciary transactions.
4750.30b—Related to Capitalized Purchases and Assisted Acquisitions
Federal entities that purchase capitalized assets, or previously capitalized assets/inventory from other federal entities must follow the Capital Asset scenario located in Intra-governmental Capital Asset and Inventory Buy/Sell Transactions Guidance.
Federal entities that participate in Assisted Acquisitions must follow the Assisted Acquisition scenario located in Assisted Acquisition Guidance.
4750.40—Intra-governmental Transactions Reconciliation and Resolution Process
Federal entities must use three-digit trading partner AID and a four-digit trading main account for all intra-governmental transactions. When federal entities report “appropriations transfers” within their departments, they must use their three-digit trading partner code. Federal entities should work with their federal trading partner to ensure the Trading Partner Agency Identifier (TP AID) and Trading Partner Main Account (TP Main Account) are valid as well as applicable to the activity being monitored.
4750.40a—Fiscal Service Intra-governmental Activity
Federal entities are expected to communicate and work with their respective trading partners before IGTs occur. Federal entities are expected to work with each trading partner before brokering intra-governmental activity to ensure strong controls are in place to effectively manage these transactions, which would lead to better reconciliation processes and fewer intra-governmental differences to reconcile and resolve. Federal entities are expected to minimize intra-governmental differences before they occur.
If after early and ongoing communication between trading partners, an intra-governmental difference exists, federal entities must reconcile and resolve these differences. Appendix 5 discusses the reconciliation and resolution process which includes the Intra-governmental Root Cause, Corrective Action Plan (CAP), and dispute resolution processes.
In preparation for the year-end submission, federal entities should validate and reconcile their data monthly to resolve intra-governmental differences in certain reciprocal categories, prior to their data submissions in GTAS.
An example of reconciling data includes the reconciliation of intra-governmental GTAS edits including:
- RC 07, Appropriation of Unavailable Trust or Special Fund Receipts (represented by GTAS Edit 33-UCAD Reciprocal Category 7 Transferred-In and Edit 34-UCAD Reciprocal Category 7 Transferred-Out),
- RC 08, Non-expenditure Transfers of Unexpended Appropriations and Financing Sources (represented by GTAS Edit 35-UCAD Reciprocal Category 8 Transferred-In and Edit 36-UCAD Reciprocal Category 8 Transferred-Out),
- RC 11, Non-expenditure Transfers of Financing Sources–Capital Transfers (represented by GTAS Edit 40-UCAD Reciprocal Category 11 Capital Transfers-In and Edit 41-UCAD Reciprocal Category 11 Capital Transfers-Out), Appropriations Received as Adjusted (represented by GTAS Edit 50-Normal Warrants Edit), and
- RC 40, Fund Balance with Treasury (represented by GTAS Edit 1-Fund Balance with Treasury).
Significant entities and selected other entities (as designated by “**” in Appendix 1a) are required to explain and certify all Material Differences Reports (MDR) Parts I, II, and III for Quarter 1, Quarter 2, Quarter 3, and Year-end. Federal entities will use the Intra-governmental Module in GTAS to view and explain as well as certify their Material Differences.
The Material Differences Window, which is used to explain and certify differences will open after the GTAS Bulk File Submission Window closes. These dates are set by Fiscal Service. The intra-governmental key dates as well as the GTAS reporting window schedule can be found on the GTAS website.
Federal entities must provide detailed explanations for Material Differences Reports Parts I, II, and III. Detailed explanations should include but are not limited to the following:
- The reason the difference exists,
- What is being done to reconcile the difference, and
- The expected completion date of eliminating the difference.
Federal entities may obtain the IGT Raw Data File from GTAS to be used for the research of differences. If a federal entity is not able to provide the detailed information listed above, Fiscal Service may follow up for a response. Fiscal Service will use its own discretion when analyzing explanations and follow up for clarification, if needed.
Federal entities will also be able to obtain the following quarterly reports from GTAS:
- Material Differences Report Part I (if applicable). This report displays differences equal to or greater than $100 million in all reciprocal categories (except RC 29, which is included in Part III). Federal entities will use subsection 4750.40b as guidance to select the explanation and the detailed information that must be provided.
- Material Differences Report Part II (if applicable). This report displays differences equal to or greater than $10 million and less than $100 million in all reciprocal categories (except RC 29) with the following FR Entities that are encouraged to report for inclusion in the FR:
- 0000 (Congress: House and Senate),
- 0100 (Architect of the Capitol),
- 0200 (U.S. Capitol Police),
- 0300 (Library of Congress),
- 0800 (Congressional Budget Office),
- 0900 (Other Legislative Branches),
- 1000 (The Judiciary),
- 2300 (U.S. Tax Court), and
- 9999 (Unknown Trading Partners/Unidentified).
While a type of difference like those listed in subsection 4750.40b is not required for Material Differences Report Part II, a detailed explanation of the difference is expected. Federal entities must select “Part II Differences” as the type of difference when explaining these differences in the Intra-governmental Module of GTAS.
- Material Differences Report Part III. This report displays amounts reported in RC 29 with the federal/non-federal domain value of Z for non-reciprocating intra-governmental activity. While a type of difference, like the types listed in subsection 4750.40b, is not required for Material Differences Report Part III, federal entities must select “Part III Differences” as the type of the difference and must provide Fiscal Service with an explanation of why this non-reciprocating intra-governmental activity is reported. An explanation of “non-reciprocating activity” is not considered acceptable. Federal entities must provide Fiscal Service with the specific type of activity being captured in each USSGL. Fiscal Service may follow up for clarification to ensure the non-reciprocating intra-governmental activity reported is used for the appropriate purpose.
- Comparative Status of Disposition Report. This is available after all of Part I Material Differences are certified and the Material Differences Window is closed. It contains comparative MDR Part I reporting between the federal entity and its trading partners by Reciprocal Category. CFOs use this report to address and resolve inconsistencies in amounts and explanations between the federal entity and its trading partners.
With federal entities explaining and certifying material differences, the assurance for Fiscal Service that entities comply during the IGT reconciliation and resolution process is established using three functions:
- Obtaining sufficient explanations and corrective actions, as applicable, to resolve the out-of-balance condition,
- Obtaining assurance that federal entities are performing quarterly intra-governmental reconciliations and resolutions in accordance with OMB Circular No. A-136, revised, and Appendix 5, and
- Ensuring federal entities are mutually completing the Intra-governmental Material Differences/Status of Disposition Certification Report for the same trading partner/Reciprocal Category material difference instances.
Note: Recurring differences should be limited to those situations that have been confirmed by the Fiscal Service.
4750.40b—Reporting Entity’s Explanation of Reporting in Material Differences Reports Part I
An explanation for Material Difference Part I reporting should be based on each identified difference in terms of the following categories:
(1) Reporting error—occurs when the reporting entity has incorrectly reported activity either by reciprocal category, trading partner, or amount. The entity that reported the error should use this explanation. The entity must identify and explain the total amounts and provide the adjustment amount, the corrective action (journal entry, etc.), and when the error will be corrected.
(2) Current-year timing difference—occurs when the reporting entity has reported activity in a different quarter than the trading partner reported the activity in the current-year. The reporting entity must identify the total of these amounts and explain whether an adjustment should be made.
(3) Prior-year timing difference—occurs when a reporting entity has reported activity in a prior FY and the trading partner reported the activity in the current FY. The reporting entity must identify the total of these amounts and explain whether an adjustment should be made.
(4) Accounting methodology difference—occurs when the reporting entity uses a different method than their trading partner to account for activity. The reporting entity must identify and explain its method of accounting and attempt to provide the dollar amount of the difference caused by the differing methodologies.
(5) Accrual methodology difference—occurs when the reporting entity uses a different accrual method than their trading partner to account for activity. The reporting entity must identify and explain its method of accrual and attempt to provide the dollar amount of the difference caused by the differing methodologies.
(6) Entity Verified—intended to indicate that a federal entity has verified its reported amounts and that the entity’s documents are in agreement with its quarterly source documentation; and the federal entity has confirmed that the policy and guidance related to transactions and balances have been followed. It also indicates the federal entity has reconciled this amount with its trading partner and knows why the difference, if any, exists. Selecting "Entity Verified" indicates that the trading partner accepts the onus for adjusting its amount to clear any difference going forward and the trading partner will use the category of “Reporting Error.” Both federal entities cannot have "Entity Verified" where a difference exists. Federal entities should provide amounts and a detailed explanation to support the selection of "Entity Verified."
(7) Unidentified—occurs when the reporting entity cannot validate the amount of the difference or the trading partner at the time of reporting. The total of unidentified reporting amounts must be identified and explained as to why they are unidentified.
Note: Unidentified also can include instances where differences are due to existing guidance that is currently under review in order to ensure elimination at the government-wide level between trading partners when applied correctly (for example, judgment fund and FICA transactions).
4750.40c—Intra-governmental Transactions Metrics and Scorecards
Fiscal Service has implemented scorecards and metrics to track reporting differences government-wide by federal entity. Scorecards will be updated quarterly and disseminated to significant entities and other entities as determined by Fiscal Service. The purpose of the metrics is to monitor progress on resolving or explaining material intra-governmental differences. Refer to Appendix 5, subsection 2.4, for further information on the timeline for these scorecards and metrics as well as related federal entity requirements.
4750.50—Year-end Intra-governmental Reconciliation Process Related to GTAS
In accordance with OMB Circular No. A-136, significant entities and other entities should reconcile their intra-governmental balances with their trading partners and resolve all resulting differences prior to submitting their final GTAS ATB. Note that at year-end, federal entities should leverage the pre-year-end report that is provided prior to the close of GTAS reporting window, and tools within GTAS (such as the Intra-governmental module and Raw Data File), to determine what outstanding IGT differences exist. Since IGT differences should be resolved prior to the close of the GTAS Reporting Window; it is imperative that, entities work directly with their trading partners to reconcile intra-governmental balances and resolve resulting differences. Additionally, significant entities and their auditors should review the prior year-end scorecard to determine if a prior-year journal voucher was processed. If so, then the significant entity should identify the reason for the journal voucher as well as how to prevent the adjustment in the current year.
Reconciling data (reported as Business Event Type Code (BETC) in Central Accounting Reporting System) against Entity Reported Adjusted Trial Balance Data (reported in GTAS) can be done two ways. They are listed below.
- In GTAS, navigate to the MY ATB STATUS module and click on the Failed Edits Tab, click on View Details. This view defaults to Failed Fatal Edits (for example, Edit 1). Click on Proposed Analytical to review any Failed Proposed Analytical Edits.
- Navigate to Run Reports Module, select Validations/Edits for Report Type, select either Failed Edits Detail or Failed Edits Summary (depending on needs), select the applicable reporting period information, run the report by Either User ID or Specified TAS, scroll down past Fatal Edits to find Proposed Analytical Edit Failures.
If no Failed Edits or Proposed Analytical Edits appear after GTAS ATB upload, then the data and ATB Data are reconciled, and no further action is necessary.
4750.60—Year-end CFO Procedures for Intra-governmental Transactions/Balances
Significant entities must comply with the following instructions using the comparative, audited consolidated and entity financial statements:
- Provide responses to the representations outlined in the detailed “CFO Representation” instructions found in Appendix 4 for each intra-governmental issue, and
- Ensure the data in the Intra-governmental Year-end Material Differences Reports are consistent with the information reported in the federal program entity’s financial statements.
Fiscal Service provides the CFO Representations Form for Intra-governmental Activity and Balances (including instructions) on the GTAS website.
Provide an electronic file of the CFO’s Representations for Intra-governmental Transactions and Balances along with any supporting documentation to the federal entity's IG, Fiscal Service, and GAO (see the FY 2023 TFM Year-end Closing Bulletin for due dates).
Section 4755—GTAS Requirements
4755.10—GTAS System Access
To obtain system access, users may contact the GTAS Treasury Support Center.
4755.20—GTAS Reportable Data
The FR includes the data from the GTAS submissions for all federal entities into a set of reclassified financial statements. All federal entities must submit all changes to the reclassified financial statements through GTAS. Note the preference is to submit the changes through a resubmission of the ATB. If this is not possible, then adjustments should be submitted through the GTAS manual adjustment process. The GTAS data must reconcile to the federal entity’s audited financial statements.
4755.30—GTAS Super Master Account File
The Super Master Account File (SMAF) contains the valid TAS balances and attributes for budgetary as well as proprietary ATB submission.
4755.40—Adjusted Trial Balance
Federal entities must prepare and submit pre-closing GTAS ATB at the TAS level using USSGL accounts and attributes. Non-executive federal entities that have not adopted the USSGL must crosswalk their general ledger accounts to the USSGL accounts before transmission.
The GTAS ATB must include USSGL accounts with the required attributes, and USSGL account balances must reflect the pre-closing adjusting entries needed to produce financial statements. The total sum of debit balances must equal the total sum of credit balances in the GTAS ATB. Report amounts in dollars and cents.
Significant entities and other entities must use the same USSGL data on the GTAS ATB that they use to prepare the current FY audited federal entity consolidated financial statements due to OMB. For detail on the specific requirements for the submission, please refer to the GTAS website.
4755.50—General Fund Receipt Accounts
Federal entities that classify amounts on their Classification Transactions and Accountability (CTA) report in General Fund Receipt Accounts symbols using their three-digit agency trading partner AID also must submit a GTAS ATB, and must prepare federal entity financial statements that include the General Fund receipt activity.
4755.60—Treasury Managed Trust Fund Accounts
Fiscal Service’s Funds Management Branch provides the lead program entity a monthly GTAS ATB, or equivalent, for the Treasury managed trust fund activity located at Fiscal Service for each of the Treasury managed trust funds listed in Figure 1. The monthly GTAS ATB prepared by Fiscal Service contains collection and disbursement transactions that are recorded in the Treasury managed trust funds as well as investment activity and balances. The monthly GTAS ATB will be provided to the lead program entities no later than the fifth workday after the end of the applicable month. The program entities are responsible for recording appropriated amounts from the trust funds and reporting the final Treasury managed trust fund ATB in GTAS.
Fiscal Service uses USSGL accounts from the USSGL TFM Supplement for current year reporting, with the proper attributes. The lead program entities identified in Figure 1 must include the Treasury managed trust fund ATB data in their GTAS Submission. Please email the Funds Management Branch with questions regarding the Treasury managed trust fund accounts to UTF@fiscal.treasury.gov.
4755.70—GTAS ATB Reports Transmission Methods
Each GTAS ATB preparer must submit the ATB data using the bulk file transfer method in GTAS. Federal entities must submit GTAS ATB for each active TAS (these include the TAS with no transactional activity but are active for CARS, see the Frequently Asked Questions for details). By certifying the GTAS ATB data, an entity is verifying the TAS is valid and its USSGL balances are accurate. For specific detail on GTAS ATB submissions, please refer to the GTAS website.
4755.80—Proprietary Balances in Canceled Accounts
GTAS will establish a default TAS (“C” domain value for availability type). The system-generated “C” TAS will have three components: the three-digit AID, availability type “C,” and a four-digit main account. The GTAS system will provide a “C” TAS on the GTAS Super Master Accounts File for each fund family represented on the SMAF. Federal entities may choose one or more “C” TAS on the SMAF to report assets.
If a federal entity is using a default fund symbol of its own creation, they must use the new “C” account in its place. However, if federal entities are using a current-year fund symbol, an “X” fund, or some variation of an active account, they may continue. Federal entities may also decide on their own when to move these assets from the original purchasing fund but must be accomplished no later than the federal entity’s final GTAS submission for period 12 of the fifth FY after the availability has expired.
Please see the FY 2023 TFM Year-end Closing Bulletin for a complete listing of FY 2023 reporting and submission dates.
Figure 1: Treasury Managed Trust Funds
Treasury Managed Trust Fund
Federal Supplementary Medical Insurance
Department of Health and Human Services (HHS)
Federal Hospital Insurance
Vaccine Injury Compensation
Federal Old-Age and Survivors Insurance
Social Security Administration (SSA)
Federal Disability Insurance
Airport and Airway
Department of Transportation (DOT)
Sports Fish Restoration and Boating
Department of the Interior
Oil Spill Liability
Department of Homeland Security
Black Lung Disability
Department of Labor (DOL)
Hazardous Substance Superfund
Environmental Protection Agency (EPA)
Leaking Underground Storage Tank
U.S. Army Corps of Engineers
U.S. Army Corps of Engineers
South Dakota Wildlife Restoration
U.S. Army Corps of Engineers
Patient-Centered Outcomes Research
|U.S. Victims of State Sponsored Terrorism Fund||Department of Justice|
Direct inquiries and deliver documents required by this chapter to:
Department of the Treasury
Bureau of the Fiscal Service
Financial Reporting Division
Also, deliver documents required by this chapter to:
Carolyn Voltz, CPA
Government Accountability Office
Scott Bell, Senior Staff Accountant
Department of the Treasury
Office of the Fiscal Assistant Secretary
Department of Justice