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 department-level financial statements. This chapter also includes the federal entities included in the FR, Intragovernmental 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 4701—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 to reconcile to the federal entity’s audited department-level financial statements and the reclassified financial statements, which provides the connection to the data in the FR.
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 governmentwide level on the federal entities audited data, and intragovernmental certifications. Fiscal Service will send a data call to the 40 Significant Entities, and select Other Entities, requesting that federal entities designate the certifying officials for various required year-end functions. Significant Entities with a year-end other than September 30 are subject to alternate audit procedures as outlined below in subsection 4705.25.
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 fiscal year (FY) 2019 reporting).
Fiscal Service compiles the information from the GTAS submissions for all federal entities into a set of reclassified financial statements (reclassified Balance Sheet, reclassified Statement of Net Cost, and reclassified Statement of Changes in Net Position) that are included in the consolidated FR. Please refer to subsection 4705.20d of this chapter and OMB Circular A-136 for supplemental information on sustainability financial statements.
Reporting requirements in this chapter are grouped as follows:
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 (Consolidated Entities included in the governmentwide General Purpose Federal Financial Reports (GPFFR), Disclosure Entities, and Related Parties).
An initial questionnaire was designed by compiling the key deciding factors throughout FASAB Standard No. 47, and listing them in branch logic sequence. The document referenced 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 federal entity was led to a reporting determination of consolidation entity (included in the governmentwide GPFFR), disclosure entity (included in the governmentwide GPFFR), related party, or not required to report.
The survey supported the following determinations*:
*See SFFAS No. 47, Reporting Entity for more detail.
The top down approach was used to identify federal entity determinations from a governmentwide perspective. Each component entity should perform an entity review to validate proper reporting at the entity level. For assistance in a federal entity level review, please contact Fiscal Service at firstname.lastname@example.org to receive the SFFAS No. 47 Entity Analysis Excel workbook. Notify Fiscal Service immediately if a federal entity analysis results in a determination(s) that differs from those outlined in Appendix 1b, and include the basis for determination. For FY 2019, consistent with Appendix C of SFFAS No. 47, the survey now requires component entities to document the rationale for its determinations as to other entities considered, and 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. To ensure completeness, component entities should perform a bottom up assessment to identify federal entities that may not have been identified through the top down approach.
Component entities must notify Fiscal Service of any discrepancies between the auditor and the component entity as to the component entity’s reporting entity. In addition, questions concerning which component entity a federal entity needs to be consolidated into should be discussed with Fiscal Service. Final reporting entity determinations must be agreed upon with Treasury and OMB.
Federal entities should 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.
A federal entity with the determination of consolidation will submit an ATB in GTAS, unless other means are determined for financial reporting. This data will flow to the face of the governmentwide 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 GPFFRs prepared in conformity with accounting standards issued by the FASB also may be regarded as in conformity with generally accepted accounting principles (GAAP). Consolidation entities (that is, the consolidated governmentwide 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.
Federal 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 governmentwide GPFFR or related party, make sure to report the federal or non-federal designation as non-federal.
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 4703—Definition of Terms
Active Treasury Account Symbol—Any Treasury Account Symbol (TAS), regardless of balances or transaction activity, that has a TAS status of “U-Unexpired” or “E-Expired.” Exceptions include situations such as available receipt accounts (balances are rolled into the expenditure main account), the TAS in the 7XXX main account series (not brought into the SMAF), and the TAS that should have canceled but did not due to outstanding balances or other issues.
Adjusted Trial Balance (ATB)—This is a list of USSGL accounts with attributes and pre-closing adjusted balances prepared at a specified date (i.e., year-end). Federal entities submit GTAS ATB by the TAS, which includes USSGL accounts with attributes. The USSGL account balances should reflect pre-closing adjusting entries. The total sum of the debit balances must equal the total sum of the credit balances in the ATB per the TAS. The ATB intradepartmental balances, for the federal entity, must eliminate. Federal entities must include the required attributes with the appropriate USSGL accounts (see the USSGL website for FY 2019 reporting requirements).
Agency—Refers to the reporting entities for inclusion in the FR. “Agency,” “department,” “ federal entity,” and “reporting entity” are used interchangeably, unless otherwise noted (see Appendix 1a and 1b).
Agency Financial Report (AFR)—This report summarizes a federal entity’s accomplishments relative to its performance goals and objectives, and provides an overview of its finances and operations for each fiscal year. It includes four sections: Management’s Discussion and Analysis, Financial Section, Other Information, and Appendices.
Agency Identifier (AID)—Three-digit code of the component Treasury Account Symbol (TAS) format. The code is assigned based on the language in the legislation that established the TAS. AID does not necessarily indicate reporting entity responsibility, which is denoted by the FR Entity.
Attribute—A modifier that further describes a USSGL account to meet a specific reporting requirement. Federal entities capture this information at the transaction level. The USSGL website contains applicable GTAS attributes for FY 2019 reporting.
Budget Subfunction Code (BSF)—A three-digit GTAS code that classifies budget resources by function and subfunction. It groups budget authority and outlays of budget and off-budget federal entities in terms of the national needs being addressed. For a complete list of BSF codes (also known as functional classification codes), see OMB Circular No. A-11.
Business Event Type Code (BETC)—Up to an eight-character code that indicates the type of activity being reported (borrowing, repayment, offsetting collection, receipt, disbursement, etc.). It is used in combination with the TAS to determine the transaction effect on the Fund Balance with Treasury.
Calendar Year-end Entity—Federal entities that operate on a calendar year basis that are considered significant to the FR if they have a line item or note disclosure that is equal to or greater than $1 billion, but are only required to have audit assurance on line items or note disclosures that contribute to the top 95% of the total FR line item data.
Central Accounting Reporting System (CARS)—The Bureau of the Fiscal Service’s central accounting reporting system for budget execution, accountability, and cash/other asset management as reported by federal program entities.
Federal Entity—Refers to the reporting entities for inclusion in the FR. Terms for these organizations (such as agencies, departments, corporations, non-profits, bureaus) may be used interchangeably with the term Federal Entitiy, unless otherwise noted (see Appendix 1a and 1b).
Fiduciary Fund Accounts—The Statement of Federal Financial Accounting Standards (SFFAS) No. 31, Accounting for Fiduciary Activities defines a fiduciary activity as “activity a federal entity collects or receives and subsequently manages, protects, accounts for, invests, and/or disposes of cash or other assets in which non-federal individuals or entities (or “non-federal parties”) have an ownership interest that the federal government must uphold. Non-federal parties must have an ownership interest in cash or other assets held by the federal entity under provision of law, regulation, or other fiduciary arrangement. The ownership interest must be enforceable against the federal government. Judicial remedies must be available for the breach of the fiduciary obligation.”
Treasury Account Symbols that are designated as fiduciary, per SFFAS No. 31, should be reported as non-federal. Please note that most fiduciary funds are Deposit Funds.
Fiduciary Transactions—Intragovernmental transactions that consist of Fiscal Service investments and borrowings; Federal Financing Bank (FFB) borrowings; Department of Labor (DOL) employee benefit transactions; and Office of Personnel Management (OPM) employee benefit transactions.
It is noted the word “fiduciary” is used in a different context than used in Statements of Federal Financial Accounting Standards (SFFAS) No. 31, Accounting for Fiduciary Activities, discussed in subsection 4705.20e.
Financial Report of the United States Government (FR)—The Financial Report of the United States Government provides the President, Congress, and the American people with a comprehensive view of the federal government's finances, i.e., its financial position and condition, revenues and costs, assets and liabilities, and other obligations and commitments. The FR also discusses important financial issues and significant conditions that may affect future operations.
Financial Reporting Entity Code (FR Entity)—A four-digit code representing individual federal entities in GTAS that denotes reporting responsibility for federal entity financial statements, ATB data, and Material Differences Explanations in GTAS.
General Fund Receipt Account (GFRA)—A receipt account credited with all funds from collections that are not identified by law for another account for a specific purpose. These collections are presented in the President’s Budget of the United States Government as either governmental (budget) receipts or offsetting receipts. These include taxes, customs duties, and miscellaneous receipts. There are numerous General Fund Receipt Accounts that are described in the Federal Account Symbols and Titles (FAST) Book. See the FAST Book website for more information.
General Purpose Federal Financial Reports (GPFFR)—Used as a generic term to refer to the report that contains the reporting entity's financial statements which are prepared pursuant to generally accepted accounting principles. In the federal government, the report for the U.S. governmentwide reporting entity is known as the consolidated Financial Report of the U.S. Government. For component reporting entities, it is usually included in the Performance and Accountability Report (PAR), the Agency Financial Report (AFR), or the annual management report.
Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)—GTAS is used by federal entities to submit a pre-closing ATB for proprietary and budgetary data simultaneously in one bulk file submission.
Intradepartmental Balance—This USSGL account balance results from a transaction between trading partners in the same federal entity.
Intragovernmental Transactions or Balances—These transactions or balances result from business activities conducted by two different federal government entities included in the FR.
Management Representation Letter (MRL)—A letter addressed to a federal entity’s external auditor, signed by senior management. The letter attests to the accuracy of the financial information that the federal entity has submitted to the auditors for their analysis.
Non-reciprocating (Z)—An attribute of a USSGL account balance that results from transactions that are intragovernmental, but no reciprocal balances will be reported by another federal entity.
Other Entities—Federal entities other than Significant Entities. See Appendices 1a and 1b for a complete listing. The complete list can also be found in Appendix A of the FR as Additional Entities.
Performance and Accountability Report (PAR)—This report summarizes a federal entity’s accomplishments relative to its performance goals and objectives, and provides an overview of an entity’s finances and operations for each fiscal year.
Probable Likelihood of Loss—This term implies that the future event or events are more likely than not to occur, with the exceptions of pending or threatened litigation and unasserted claims. For pending or threatened litigation and unasserted claims, the future confirming event or events are likely to occur. If a negative outcome is probable, the federal entity must record a liability on its books for the estimated amount of loss. The estimated liability may be a specific amount or a range of amounts. If some amount within the range is a better estimate than any other amount within the range, then the federal entity should recognize that amount as a liability and should disclose the range of possible loss as well as the nature of the contingency in its financial statement notes. If no amount within the range is a better estimate than any other amount, then the federal entity should recognize the minimum amount in the range as a liability and should disclose the range and a description of the nature of the contingency in its financial statement notes. See Federal Accounting Standards Advisory Board (FASAB) SFFAS Nos. 5 and 12.
Reasonably Possible Likelihood of Loss—This term implies that the chance of the future event or events occurring is more than remote but less than probable. If it is reasonably possible that the federal entity will incur a loss, the entity must disclose the nature of the contingency and an estimate of the possible liability, an estimate of the range of the possible liability, or a statement that such an estimate cannot be made (see SFFAS Nos. 5 and 12).
Reciprocal Category (RC)—This is a set of reclassified financial statement federal line items or a grouping of USSGL accounts. The set is used to perform eliminations at the governmentwide level (see subsection 4705 and Appendices 2 and 3).
Reclassified Financial Statement—This is a standardized federal entity financial statement format used across the government. GTAS will crosswalk the GTAS ATB data to the reclassified financial statement line items (for the reclassified Balance Sheet, Statement of Net Cost, and Statement of Changes in Net Position) based on the USSGL crosswalks. The statements are system-generated using GTAS ATB data. Please refer to Note 44 of OMB Circular No. A-136 for details.
Remote Likelihood of Loss—This term implies that the chance of the future event or events occurring is slight. If only a remote chance of loss is possible, the federal entity need not record a liability nor provide a note disclosure (see SFFAS Nos. 5 and 12).
Reporting Entity—The federal entities that comprise the reporting entities of the U.S. Government. The reporting entity list can be found in Appendix A of the FR.
Guidance for what organization should be reported upon by a reporting entity is in the SFFAS No. 47, Reporting Entity and subsection 4701.10 of TFM Volume I, Part 2, Chapter 4700, which is effective for the current FY 2019.
Reporting Type Code—A TAS is either designated as E-Dedicated Collections, F-Fiduciary, or U-Undesignated by Treasury in both CARS and GTAS. If the fund is designated as E it is consolidated in the FR and it is, also, designated as part of the Funds from Dedicated Collections footnote. If the fund is designated as F it is not consolidated in the FR and it is only included in the Fiduciary Activities footnote. If the fund is designated as U it is consolidated in the FR and included in all applicable footnotes.
Significant Entities—These federal entities consist of the CFO Act entities and additional entities identified by Treasury that are material to the FR. Federal entities are deemed material to the FR if they have data that feeds to reclassified financial statement line items or note disclosures that are greater than $1 billion. See Appendix 1a for the complete list of Significant Entities.
Special Fund Receipt Accounts—Receipt accounts credited with funds from collections that are identified by law but included in the federal funds group rather than classified as trust fund collections. These collections are presented in the President’s Budget as either governmental (budget) receipts or offsetting receipts.
Summary of Uncorrected Misstatements (SUM)—The federal entity’s auditor should communicate factual, projected, and judgmental misstatements identified during the audit to the appropriate level of management and those charged with governance, as required by AU-C 450 and AU-C 260. The auditor should request management to correct all factual misstatements. If management corrects one or more of the identified misstatements to the financial statements, the auditor should use the SUM (before discussion with management) to create a new SUM (after discussion with management) for any remaining uncorrected misstatements. The auditor should attach the SUM without the auditor’s calculations, evaluation, and conclusion (or a listing of uncorrected misstatements if the number and amount of the misstatements are insignificant) to the management representation letter as discussed in Financial Audit Manual 1001.
Super Master Account File (SMAF)—The SMAF contains the valid TAS balances and attributes used for budgetary and proprietary ATB submissions. See the GTAS website for more information.
Suspense Accounts—Federal entities use these accounts to temporarily hold collections and in certain suspense accounts, to hold disbursements. They use these accounts pending clearance to the applicable receipt or expenditure account in the budget. An “F” preceding the last four digits of the fund symbol identifies a suspense account.
Trading Partner Agency Identifier (TPAID)—The three-digit bulk file attribute used to identify the reporting entity’s trading partner (see Appendix 1a and 1b).
Trading Partner (TP)—A federal entity that is party to intragovernmental transactions with another federal entity.
Trading Partner Code—The bulk file attribute used to identify the trading partner entity (see Appendices 1a and 1b). This consists of the TPAID and the Trading Partner Main Account (TPMA).
Trading Partner Main Account (TPMA)—The four-digit bulk file attribute used in conjunction with the Trading Partner Agency Identifier (TPAID) to identify the reporting entity's trading partner.
Treasury Account Symbol (TAS)—An identification code assigned by the Department of the Treasury. The TAS represents individual appropriations, receipts, and other fund accounts.
Treasury Appropriation Fund Symbol (TAFS)—This combination of numbers denotes the responsible federal entity, period of availability, and fund classification according to a prescribed system of account classification and identification. A TAFS is a subset of a TAS. A TAFS has budgetary USSGL accounts and is used to report budgetary authority.
United States Standard General Ledger (USSGL)—The USSGL provides a uniform Chart of Accounts and technical guidance to be used in standardizing federal entity accounting. See the USSGL website for more information.
Section 4704—FR Reporting and Submission Dates
See Figure 2 for the FR reporting and submission dates regarding GTAS, intragovernmental activity/transactions, legal representation letters, Management Representation Letters (MRLs), and subsequent events.
4704.10—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.
Federal entities must submit unaudited interim financial statements 21 business days after the end of third quarter. Comparative interim financial statements are limited to the Balance Sheet, Statement of Net Cost, and Statement of Changes in Net Position. Along with the three financial statements, federal entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section IV.2. Federal entities must submit unaudited notes, variance analysis and other supplemental disclosure information, e.g. RSI, RSSI, OI, 45 business days after the end of third quarter. All applicable documents are transmitted through MAX.gov. Notes and supplemental information may also be transmitted directly to Fiscal Service in accordance with Fiscal Service requests. Fiscal Service will also require federal entities’ assistance with completing the analysis of notes that present a greater risk of failing to meet the prescribed disclosure requirements. Examples of these notes are:
Federal entities should submit to Fiscal Service their contact information for internal representatives who are considered technical experts in the subject matter areas listed above, and will be the point of contact for close collaboration throughout interim analysis and preparation of the FR. Contact information (name, phone number, email address, and subject matter area(s) of expertise) should be submitted to Fiscal Service at email@example.com no later than 21 business days after the end of the third quarter. Fiscal Service will provide the federal entity technical experts as identified by the federal entity in the Significant Disclosures template, a copy of the final published version of the above listed note(s) from the prior-year FR (Word document), as well as auditor comments on each note (if applicable) received throughout the prior-year FR preparation process. Federal entity technical experts are required to provide feedback on the Significant Disclosures template 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. In addition, federal entities are required to provide current-year updates, i.e., changes to existing wording, addition of new material information, etc., to the prior-year notes using a Word document with the Track Changes feature in Microsoft Word. Auditor comments received on the above notes listed during the prior-year FR preparation process are provided to the federal entity technical experts to use as a guide for understanding auditor perspectives and expectations during review of the FR. The intention is to use this understanding to resolve in advance any issues for the current FY that can be anticipated based on auditor feedback on prior-year disclosures in the FR. Federal entity participation in this collaboration initiative will be measured on the entity’s fifth quarter scorecards for the current FY. Federal entities should be aware that Fiscal Service will resend items noted above as a follow up within one week of GPFFR due date, and the requirements will be the same as the third quarter collaboration process.
Section 4705—FR Data Requirements
Significant Entities must:
Contact Fiscal Service to determine the reporting procedures for any adjustments to the GTAS data and AFR/PAR after November 15. For contact information, see the GTAS Contacts page.
4705.10—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 intradepartmental eliminations with the following exceptions:
Identifying the trading partner enables analysis and elimination of federal activity/balances based on reciprocal categories at the governmentwide level. See Appendix 1a and 1b for a complete list of Agency Identifiers and FR entities.
All 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 5 for more details on transactions with the General Fund.
4705.20—Reclassification of Significant Entities’ Financial Statements
Significant Entities must submit GTAS ATB data. GTAS will then populate the reclassified financial statements based on the USSGL crosswalks for the three reclassified financial statements. The USSGL crosswalks for the Balance Sheet, Statement of Net Cost, and Statement of Operations and Changes in Net Position can be found in USSGL guidance (Section VI-Crosswalks to Reclassified Statements). These reports can be accessed in GTAS and are titled “Reconciliation Reports – Reclassified Balance Sheet, Statement of Net Cost, and Statement of Operations and Changes in Net Position.” Significant Entities must use these GTAS reports to complete Note 44: Reclassification Adjustments of AFR Due to FR Compilation in OMB Circular No. A-136.
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.
SFFAS No. 7, paragraph 353, states:
Disposition of revenue to Other Entities: custodial transfers—Revenue, primarily non-exchange revenue, may be collected by an entity acting on behalf of the General Fund or another entity within the government on whose behalf it was collected. The collecting entity accounts for the disposition of revenue as part of its custodial activity. These custodial transfers, by definition, do not affect the collecting entity’s net cost of operations or operating results, nor are they part of the reconciliation between its obligations and net cost of operations. (The receiving entity recognizes the revenue as non-exchange or exchange revenue depending on its nature, according to the applicable revenue standards.)
For exchange revenue with virtually no cost, see SFFAS No. 7, paragraph 140. The custodial revenue is reported by the collecting entity on the Statement of Custodial Activity or on the Custodial Activity Note.
However, for exchange revenue collected for others with related cost incurred, federal entities should follow the guidance from SFFAS No. 7, paragraph 137, which states:
As a general rule, exchange revenue transferred to others must be offset against the collecting entity’s gross cost to determine its net cost of operations. Exchange revenue reduces the net cost of operations incurred by the entity in producing outputs, regardless of whether the entity keeps the exchange revenue for its own use or transfers it to another operating entity or the General Fund. Likewise, exchange revenue reduces the net cost of the entity’s operations to the taxpayer regardless of its disposition. Therefore, all exchange revenue related to the cost of operations must be deducted from gross cost to determine the net cost of operations for the entity.
It is noted that the General Fund does not engage in Buy/Sell intragovernmental transactions or exchange activity with associated costs. In exceptional circumstances, the General Fund will have exchange revenue without associated costs; these circumstances must be evaluated by Fiscal Service on a case by case basis.
Furthermore, SFFAS No. 7, paragraph 138, states:
Any exchange revenue that is transferred to others, however, does not affect the collecting entity’s net position. Therefore, as required by the standards for other financing sources, such exchange revenue is recognized as a transfer-out in calculating the entity’s operating results.
At the governmentwide level, these collections are recognized as revenue.
Significant Entities that report a Statement or Note on Custodial Activity in their comparative, audited consolidated, department-level 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 Statement of Operations and Changes in Net Position on Note 44: Reclassification Adjustments of AFR Due to FR Compilation 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 Statement of Net Cost or Statement of Operations and Changes in Net Position when reporting in GTAS. Any federal entity receiving custodial revenue from the collecting entity must report this revenue as federal “F” in its reclassified Statement of Net Cost or Statement of Operations and Changes in Net Position 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 intradepartmental funds, those transactions should be reported as federal “F” in its reclassified Statement of Net Cost or Statement of Operations and Changes in Net Position 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 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 of these 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.
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.
4705.20b—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).
At the governmentwide level, the U.S. Government Balance Sheet shows separately the portion of the net position attributable to funds from dedicated collections which can be presented as consolidated or combined (preferably combined) and labeled accordingly. The standard further requires the disclosure of condensed information on assets, liabilities, and net cost for all funds from dedicated collections. The disclosure may be presented as combined or consolidated (preferably combined) amount, and the presentation must be labeled accordingly. If a federal entity decides to present the Balance Sheet net position as consolidated, it must disclose a crosswalk from the consolidated to combined net position amounts in the Funds from Dedicated Collection Note. The crosswalk will be concurrence to process a journal voucher at the governmentwide level, converting the Balance Sheet net position from consolidated to combined.
Significant Entities must ensure that funds from dedicated collections are denoted on the SMAF in GTAS as an “E” for the Reporting Type Code. This will crosswalk the funds from dedicated collections amounts and activity to the applicable reclassified financial statement line items.
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 to report in Note 6: Accounts Receivable, Net in OMB Circular No. A-136.
The Statements of Social Insurance and the Statement of Changes in Social Insurance Amounts 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 2019 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 2019 Annual Report of the Boards of the Trustees of the Federal Hospital Insurance and the Federal Supplementary Medical Insurance Trust Funds). The remaining data for social insurance from SSA and HHS will come from their AFR/PAR. The social insurance information from RRB and DOL will come directly from their AFR/PAR.
In a fiduciary activity, the government collects or receives and subsequently manages, protects, accounts for, invests, "and/or" 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 governmentwide 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.
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 intragovernmental transactions as stated in subsections 4706.15 and 4706.25.
4705.20f—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 is normally classified as intragovernmental. 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.
Treasury GAS securities purchased using a fiduciary fund is classified as public/non-federal. 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 “N” and no trading partner.
4705.20g—Department Code Reporting for General Fund Activities
Federal entities use a federal/non-federal indicator value of “G” strictly for recording transactions with the General Fund of the U.S. Government (General Fund). Do not confuse the General Fund with the Department of the Treasury. They are not synonymous, and federal entities must distinguish one from the other when designating an appropriate trading partner code. The General Fund has an AID of 099, a FR Entity code of 9900, and a federal/non-federal indicator of G. The Department of the Treasury has an AID of 020, a FR Entity code of 2000, and a federal/non-federal indicator of F.
In addition, federal entities may only use the General Fund as a trading partner for a buy/sell transaction in exceptional circumstances for exchange revenue without associated costs; however, these circumstances must be evaluated by Fiscal Service on a case-by-case basis.
GFRAs are credited with all funds from collections that are not identified by law for another account for a specific purpose. Federal entities should refer to the General Fund Receipt Account Guide for examples of how to record trading partner codes in GFRAs. Federal entities that are collecting receipts into GFRAs should be aware that although GFRAs belong to the General Fund, the General Fund does not have all of the details of all the accounting events in the GFRAs. This is because the General Fund derives a majority of its data through transactions performed within the CARS. Therefore, in order to prevent intragovernmental differences with the General Fund, federal entities must notify the General Fund of any applicable non-CARS reported data attributed to their entity by the eighth business day following the end of a quarter. This information must be sent via email to GeneralFund@fiscal.treasury.gov using the General Fund Agency Submission Form. The form as well as instructions can be found on the General Fund website. The information submitted on the form will include, but is not limited to, a general description of the type of transactional data being sent, the USSGL accounts involved, and the applicable amounts by USSGL accounts.
Some examples of activities with the General Fund as a trading partner are:
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.
Federal entities that record activities with the General Fund must properly record the activity at the governmentwide 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.
Z (Intragovernmental)—This is an attribute domain value of a USSGL account balance that results from transactions that are intragovernmental 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:
4705.25—Special Basis of Accounting
Significant Entities under SFFAS No. 34, The Hierarchy of Generally Accepted Accounting Principles, that use accounting standards other than FASAB standards (for example, Financial Accounting Standards Board), as the basis for their audited financial statement data are in conformity with GAAP. These federal entities do not have to convert any differences in accounting policies prior to sending the data to GTAS.
(1) Significant Entities that are currently FASB reporters are:
Significant Entities with a year-end other than September 30 are subject to all requirements of this TFM chapter. Significant Entities with a year-end other than September 30 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 95% of the total FR line item data. These entities will receive a quarterly report from Treasury so they know which lines 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 year-end other than September 30:
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:
In these cases, the receiving entity (child) is responsible for reporting all 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 governmentwide 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 governmentwide level.
4705.50—Management Representation Letter (MRL)
In accordance with OMB Circular No. A-136, Section V.5., the written representations from the federal entities’ management and accompanying Summary of Uncorrected Misstatements (SUM) are required for the audits of federal entity GPFFR used to compile the FR. Significant Entities with a year-end other than September 30 need to provide a MRL to Fiscal Service (see Figure 2 for due dates). All representations are required by generally accepted auditing standards, OMB’s audit bulletin, and TFM Volume I, Part 2, Chapter 4700. If they are not applicable to the federal entity, please state that in the representation. This is needed to ensure that each representation is analyzed and not missed unintentionally. Federal entities should attach in Excel format a comprehensive SUM that includes uncorrected misstatements from the general purpose financial statement audit. Please refer to 4705.55 (Summary of Uncorrected Misstatements Process), guidance in OMB Circular No. A-136, Section V.5, OMB Audit Bulletin No. 19-01, Section 8 (Written Representations from Management), Appendix E (Illustrative Written Representations from Management for the General Purpose Financial Statements), and the Financial Audit Manual Volume 2, Section 1001.
4705.50a—Other Required Information for Management Representation Letters
Significant Entity CFOs also must provide Fiscal Service information regarding any subsequent changes to their MRL’s and published financial statements. The subsequent events email should indicate “no changes”, or “changes” due to the written representation from management or subsequent events affecting the federal entity financial statements. Subsequent event information is based on the federal entity’s materiality threshold. Send this information via email (contacts listed at the end of this chapter) to Fiscal Service, Treasury (Main), OMB, and GAO (see Figure 2 for due dates and OMB Circular No. A-136, Section V.5 for wording requirements).
4705.55—Summary of Uncorrected Misstatements (SUM) Process
Significant Entities must include a SUM as a part of their general purpose financial statement MRL on the general purpose financial statement MRL (as stated in subsection 4705.50). 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, Statement of Net Cost/Income Statement, Statement of Changes in Net Position, 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 Financial Audit Manual, Section 595C, and should contain the following:
Please refer to the example below for reporting the adjusting entries for the summary of uncorrected misstatements to Fiscal Service.
4705.60—Legal Representation Letter Process
4705.60a—Legal Letter Reporting Requirements
Significant Entity Inspector Generals (IGs) must submit an interim and final Legal Representation Letter prepared by the entity General Counsel summarizing and evaluating legal actions against the entity. Significant Entity IGs must submit the interim and final Legal Representation Letters and Management Schedules of Information Contained in Legal Letter Response for Financial Reporting Purposes (Management Schedules) to Fiscal Service, DOJ, and GAO (see Figure 2 for due dates). When preparing the Legal Representation Letters, General Counsel should reference guidance found in OMB Bulletin No. 19-01. All pending and threatened litigation and unasserted claims above a $500 million threshold must be reported using the applicable form (according to the type of case or group of cases reported) found on DOJ’s website. Legal Representation Letter files sent by email must be PDF files (zipped files are not accepted). The federal entity’s Legal Representation Letter must be accompanied by a Management Schedule prepared by management that summarizes the content of the Legal Representation Letter as disclosed in the federal entity’s financial statements. Management Schedules must be in Excel format. Please refer to the following example of a Management Summary Schedule.
The federal entity’s 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, as appropriate, for the entity consistent with American Bar Association guidance. Significant Entities must recognize a contingent liability on their financial statements or must disclose it in the financial statement notes if it meets the contingent liability criteria as defined in SFFAS No. 5, Accounting for Liabilities of the Federal Government, as amended. To ensure accurate reporting, contingencies detailed in the Legal Representation Letter must be consistent with the disclosures in the federal entity’s general purpose financial statement. If a discrepancy greater than ten percent is identified between the federal entity’s general purpose financial statement and the entity’s Management Schedule, federal entities will be required to provide an explanation to Fiscal Service. For guidance, refer to OMB Bulletin No. 19-01, as amended, as it relates to Legal Representation Letters.
Federal entities should refer to SFFAS No. 5, when assessing the likelihood of loss for a contingency. Federal entities should avoid excessive and misuse of the term “unable to determine” when assessing the likelihood of loss. This likelihood should only be used to categorize cases for which the Legal Counsel is unable to express an opinion. If the likelihood of a loss for a case is notated on the Management Schedule as “unable to determine,” federal entities must disclose in the notes to the financial statements the information that was evaluated that lead to that assessment. If a note disclosure is not included, the federal entity must provide justification as to why a disclosure is not necessary. Federal entities with a high percentage use of the term “unable to determine” will be asked to provide written documentation of their internal processes for using the “unable to determine” likelihood of loss status for legal cases.
The Export-Import Bank of the U.S., Smithsonian Institution, 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. The aforementioned federal entities are required to submit a final Legal Representation Letter and the accompanying Management Schedule. The final Legal Representation Letter must include all existing, pending, or threatened litigation and unasserted claims as of September 30. The Legal Representation Letter including signatures as well as the accompanying Management Schedule must be submitted electronically to DOJ, Fiscal Service, and GAO (see Figure 2 for dates). Submit the legal representation letter in PDF and the Management Schedule in Excel format (subsequent event reporting requirements are applicable to ALL federal entities). Please include contact information for federal entity representatives who may assist Fiscal Service with inquiries related to legal representation letter submissions. Since multiple areas are involved in the preparation of the legal representation letter package (federal entity management, Legal Counsel, and IGs), please provide contact information for each area, or indicate that the contact(s) provided serves as sufficient representation for all areas.
4705.60b—Other Required Information for Legal Representation Letters
Significant Entity IGs must provide GAO, DOJ, and Fiscal Service information relating to subsequent events. Entities are required to report subsequent events that resulted in a change in the likelihood of loss or the amount of loss, or both, from the effective date of the final Legal Representation Letter through a date to be determined. All federal entity IGs must submit details of the subsequent events via email to GAO, DOJ, and Fiscal Service (see Figure 2 for due dates).
Subsequent event information is based on the federal entity’s materiality threshold. For additional guidance, see OMB Bulletin No. 19-01, as amended, and OMB Circular No. A-136, revised, on the OMB website.
4705.65—Treaties and Other International Agreements
For accounting purposes, Treaties and other international agreements may be understood as falling into three broad categories:
Treaties and other international agreements are negotiated against the backdrop of the Antideficiency Act (ADA), which prohibits the authorization or creation of an expenditure or obligation in excess of the amount available unless authorized by law. In many cases, such treaties and other international agreements establish frameworks that govern cooperative activities 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 obligations to engage in them are made subject to the availability of funds, such that failure to engage in the activities would not involve a breach of the agreement or result in the U.S. incurring any financial liability or penalty. 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.
A small number of treaties and other international agreements fall in the second category, involving specific obligations by the U.S. to pay money to other countries or international organizations. Examples of such agreements include:
Such agreements may not be entered into without specific statutory authority to undertake the obligation to spend money. As a result, the responsible reporting entity establishes a liability for assessments received and unpaid, as well as for pledges made and accepted by an international organization. These liabilities may either be fully funded or established against future funding.
The last category often encompasses those treaties or other international agreements in which the U.S. has agreed to a binding dispute settlement to resolve disagreements that may arise in respect of the treaty or other international agreement. Dispute settlement mechanisms do not necessarily result in the U.S. spending money; however, a tribunal’s binding dispute settlement decision may obligate the U.S. to spend money. When a claim is filed against the U.S. under a treaty or other international agreement that provides for binding dispute settlement, the responsible reporting entity must establish a contingent liability and, if applicable, include a required note disclosure in its financial statement footnotes, in accordance with accounting standards, as appropriate. This is carried out, captured, and reported in the annual legal letter processes.
Federal entities negotiating and concluding treaties and other international agreements on behalf of the U.S. Government must follow requirements outlined in the Circular 175 Procedure (C-175 Procedure) developed by the Department of State (State), reflected in 11 Foreign Affairs Manual (FAM) 720 et seq. Per the C-175 Procedure, a request for authorization to negotiate and conclude a treaty or other international agreement takes the form of an action memorandum addressed to the Secretary of State, or other principal to whom such authority has been delegated. The action memorandum may request the authority to negotiate, authority to conclude, or authority to negotiate and conclude a treaty or other international agreement. In addition, the action memorandum must 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 made a determination 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 entity of the U.S. Government.
In accordance with auditing standards, federal entity external financial statement auditors must develop test procedures to assess the adequacy of internal controls surrounding the establishment of a liability or note disclosure, as well as to confirm the accuracy of amounts presented. In addition, federal entity auditors or attorneys must conduct a review of potential risk for contingent liabilities arising from treaties and other international agreements that have not yet resulted in litigation. If at any point throughout the duration of the treaty or other international agreement, litigation should arise from a triggering event (SFFAS No. 5, paragraph 26), State, or other U.S. Government entity the agreement was concluded in the name of, would follow federal guidance and internal procedures for reporting any relevant information in its legal letters. Significant Entities must recognize a contingent liability on their financial statements or must disclose it in the financial statement notes if it meets the contingent liability criteria as defined in SFFAS No. 5, as amended.
Section 4706—Intragovernmental Quarterly and Year-end Requirements
Intragovernmental transactions result from business activities conducted between two federal government entities, called trading partners. Accounting differences occur in governmentwide financial reporting when trading partners record differing amounts for transactions that should eliminate or net to zero. Trading partners must reconcile and resolve these differences on a routine basis with their trading partners. The Intragovernmental Transaction (IGT) Guide (Appendix 6) contains the business rules and processes to properly record, report, and reconcile intragovernmental transactions, including the processes for dispute resolution.
Note: The Federal Reserve System, which includes the Board of Governors, is not considered a consolidated entity in governmentwide reporting entity under federal accounting standards (please note the Board of Governors is considered federal for tax purposes, however, for governmentwide 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 (refer to Appendix 1b for list of Disclosure Entities, SFFAS No. 47). All activity with the Board of Governors of the Federal Reserve System must be reported as non-federal “N” activity.
4706.15—Additional Intragovernmental Reconciliation Requirements
The intragovernmental transactions reconciliation and resolution requirements are stated in OMB Circular No. A-136, revised (see the OMB website).
4706.20—Federal Intragovernmental Transactions Accounting Scenarios
Federal entities can refer to the USSGL website to see accounting scenarios for selected intragovernmental activities.
For non-fiduciary transactions, OMB requires reporting entities to reconcile and confirm intragovernmental activity as well as balances quarterly for the following reciprocal groupings:
4706.25a—Related to Capitalized Purchases
Federal entities that purchase capitalized assets, or previously capitalized assets/inventory from other federal entities must follow the Capital Asset scenario located in Intragovernmental 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.
4706.30—Intragovernmental Transactions Reconciliation and Resolution Process
Federal entities must use three-digit trading partner AID for all intragovernmental transactions. When federal entities report “appropriations transfers” within their departments, they should use their three-digit trading partner code. Effective FY 2019, all the TAS, including no-year TAS, are required to report the four-digit trading partner main account.
4706.30a—Fiscal Service Intragovernmental Activity
Federal entities are expected to work with their respective trading partners to reconcile and resolve intragovernmental differences. Appendix 6 discusses the reconciliation and resolution process which includes the Intragovernmental Root Cause, Corrective Action Plan (CAP), and dispute resolution processes.
Significant Entities and selected Other Entities (as designated by “**” in Appendix 1a) are required to explain and certify all Material Differences Reports Parts I, II, and III-Z for Quarter 1, Quarter 2, Quarter 3, and Quarter 5. Quarter 4 explanations are not required. Federal entities will use the Intragovernmental 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. Federal entities may obtain the IGT Raw Data File from GTAS to be used for the research of differences.These dates are set by Fiscal Service. The intragovernmental 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-Z. Detailed explanations should include but are not limited to the following:
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:
While a type of difference like those listed in subsection 4706.30b is not required for Material Differences Report Part II, a detailed explanation of the difference is expected. Federal entities may select “Part II Differences” as the type of difference when explaining in the Intragovernmental Module of GTAS.
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:
Note: Recurring differences should be limited to those situations that have been confirmed by the Fiscal Service.
4706.30b—Reporting Entity’s Explanation of Reporting in Material Differences Reports Part I
An explanation of Part I reporting should be based on each identified difference in terms of the following categories:
(1) Accounting/reporting error—occurs when the reporting entity has incorrectly reported activity either by reciprocal category, trading partner, or amount. The total of these amounts must be identified and explained. If the entity is in error, then provide the adjustment amount as well as 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 total of these amounts must be identified. 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 total of these amounts must be identified. 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 method of accounting must be identified and explained as well as 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 method of accrual must be identified and explained as well as 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. 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 governmentwide level between trading partners when applied correctly (for example, judgment fund and FICA transactions).
4706.30c—Intragovernmental Transactions Metrics and Scorecards
Fiscal Service has implemented scorecards and metrics to track reporting differences governmentwide 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 intragovernmental differences. Refer to Appendix 6, subsection 2.4, for further information on the timeline for these scorecards and metrics as well as related federal entity requirements.
4706.40—Year-end Intragovernmental Reconciliation Process Related to GTAS
In accordance with OMB Circular No. A-136, Significant Entities and Other Entities should reconcile their intragovernmental balances and resolve intragovernmental differences with all available information before submitting their GTAS ATB. Additionally, Significant Entities and their auditors should review the prior-year fifth quarter 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.
In preparation for the year-end submission, federal entities should validate and reconcile their data monthly to resolve intragovernmental differences in certain reciprocal categories, prior to their data submissions in GTAS.
The data to reconcile consists of:
Reconciling data (reported as 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.
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.
4706.45—Year-end CFO Procedures for Intragovernmental Transactions/Balances
Significant Entities must comply with the following instructions using the comparative, audited consolidated and department-level financial statements:
Fiscal Service provides the CFO Representations Form for Intragovernmental Activity and Balances (including instructions) on the GTAS website.
Provide an electronic file of the CFO’s Representations for Intragovernmental Transactions and Balances along with any supporting documentation to the federal entity's IG, Fiscal Service, and GAO (see Figure 2 for due dates).
Section 4707—GTAS Requirements
GTAS requires reporting proprietary and budgetary USSGL account balances. Details can be found by visiting the GTAS website.
4707.05—GTAS System Access
To obtain system access, users may contact the GTAS Treasury Support Center
4707.10—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 AFR/PAR.
4707.10a—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.
4707.10b—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.
4707.10c—Reporting Instructions for 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.
4707.10d—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 3. 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 for FY 2019 reporting, with the proper attributes. The lead program entities identified in Figure 3 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.
The reporting in GTAS is similar to the reporting for the quarterly file submissions. Refer to subsection 4705.30.
4707.10f—GTAS ATB Reports Transmission Methods
Each GTAS ATB preparer can 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). For specific detail on GTAS ATB submissions, please refer to the GTAS website.
4707.10g—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 Agency Identifier, 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 its 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.
Figure 2: Reporting and Submission Dates
|July 30, 2019||Federal entities must submit unaudited interim financial statements, limited to the Balance Sheet, Statement of Net Cost, and Statement of Change in Net Position to MAX.gov.|
|August 8, 2019||Fiscal Service will provide the federal entity technical experts the Significant Disclosures Template, final published version of note(s) from the prior-year FR identified as presenting a greater risk of failing to meet prescribed disclosure requirements, as well as auditor comments on each of these note(s) (if applicable) from the prior-year FR preparation process. See subsection 4704.10 for complete details.|
*August 22, 2019
Significant Entity IGs must submit the interim Legal Representation Letters and Management Schedules to Fiscal Service, DOJ, and GAO.
|September 3, 2019||In accordance with OMB Circular No. A-136, Section IV.2, federal entities must submit a variance analysis and unaudited notes and other supplemental disclosure information, e.g. RSI, RSSI, and OIR. SIRA must include updates to social insurance with this requirement.|
|September 6, 2019||Federal entity technical experts are required to provide feedback on the Significant Disclosures template as well as any narrative updates from prior-year FR. See subsection 4704.10 for complete details.|
October 4, 2019
GTAS opens for September 30, 2019, ATB submission.
October 17, 2019
GTAS expenditure TAS must be certified by 5 p.m. ET.
|October 22, 2019
||DOJ will provide the interim governmentwide Legal Representation Letter to GAO, OMB, and Treasury.|
October 25, 2019
DOL reports the draft Social Insurance data for Black Lung and Unemployment Insurance, and RRB reports the draft Social Insurance data for Railroad Retirement to MAX.gov.
|November 8, 2019||The GTAS Period 12 Revision window closes at 5 p.m. ET.
November 14, 2019
GTAS Period 12 Extension window closes at 2 p.m. ET.
|November 18, 2019||Year-end Material Differences Reports (MDRs) are available in GTAS to be explained and certified. The Raw Data File is also available in GTAS.|
|November 19, 2019||Final PARs and AFRs are due to MAX.gov by 6 p.m. ET.|
|November 19, 2019||
1. Significant Entity IGs must submit the final Legal Representation Letters and management schedules to Fiscal Service, DOJ, and GAO by 6 p.m. ET.
2. Significant Entities must submit the Management Representation Letter in conjunction with the Uncorrected Misstatements (SUM) via email to Fiscal Service and GAO. Upload the required documents to OMB via the MAX.gov website. (Please see subsection 4705.50.)
|December 3, 2019||Federal entity technical experts are required to provide feedback on the Significant Disclosures template as well as any narrative updates from prior-year FR. See subsection 4704.10 for complete details.|
|December 3, 2019
||Federal entity CFOs submit their Representations for Intragovernmental Activity and Balances to entity's IG, Fiscal Service, and GAO. All year-end MDRs must be certified in GTAS.|
|TBD||Significant Entities receive the Comparative Status of Disposition from GTAS.|
Federal entity FR review period. Comments are due at noon.
Significant Entity IGs must provide Fiscal Service information relating to subsequent events that occurred from the effective date of their final Legal Representation Letters through a date to be determined. Send this information via email to Fiscal Service, DOJ, and GAO.
|February 7, 2020||DOJ will provide the final governmentwide Legal Representation Letter to GAO, OMB, and Treasury.|
Significant Entity CFOs must provide Fiscal Service information about subsequent changes to Management Representation Letters and financial statements that have occurred from the date of the financial statements audits and up through a date to be determined. Send this information by noon via email to Fiscal Service, Treasury (Main), OMB, and GAO.
Financial Report of the U.S. Government is published.
* Represents the “no later than date.” Federal entities should submit data as early as possible.
Intragovernmental Key Dates may be found on the GTAS website.
GTAS Deadlines may be found on the GTAS website.
Figure 3: 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:
Jaime Saling, Director
Financial Reports and Advisory Division
Bureau of the Fiscal Service
PO Box 1328
Parkersburg, WV 26106-1328
Also, deliver documents required by this chapter to:
Carolyn Voltz, CPA
Government Accountability Office
441 G Street, NW, Room 5X23
Washington, DC 20548
Carol S. Johnson, Policy Analyst
Office of Management and Budget
Office of Federal Financial Management
725 17th Street, NW
Washington, DC 20503
Scott Bell, Senior Staff Accountant
Office of the Fiscal Assistant Secretary
Department of the Treasury
1500 Pennsylvania Ave, NW
Washington, DC 20220
Department of Justice
Federal Trading Partner Codes for the Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)
|1b||Determination of Consolidation Entity included in the governmentwide General Purpose Federal Financial Reports (GPFFR), Disclosure Entity included in the governmentwide GPFFR, or Related Party for the Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)|
Reciprocal Categories Crosswalk to Financial Statements
Intragovernmental Transactions (IGT) Categories of Reciprocal U.S. Standard General Ledger (USSGL) Proprietary Accounts
CFO Representations for Intragovernmental Activity and Balances Instructions
Recording Intragovernmental Transactions (IGT) with the General Fund of the U.S. Government
Intragovernmental Transaction (IGT) Guide
Appendices are available in the PDF version only.